HomeMy WebLinkAbout00-08274
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KENNETH E. LlOYD,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00 -cF.;I. 7'-1
C'Ol'l ~
SANDRA!. LlOYD,
Defendant
: CIVILACTION-LAW
: COMPLAINTINDIVORCE
NOTICE
TO: Sandra 1. Lloyd, Defendant
37 SouthmontDr,
Enola, P A 17025
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against you by
the court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage ,counselors is available in the office of the
Prothonotary at the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAlMFOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Lawyer Referral Service
2 Liberty Avenue
Carlisle; P A 17013
(717)249-3166
Document #: 189296.1
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KENNETHE. LlOYD,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 60 - ?,J 7'/ Ct;;..e t...e.u--
SANDRAJ. LlOYD,
Defendant
CIVIL ACTION - LAW
COMPLAINT IN DIVORCE
COMPLAINT IN DIVORCE
l. The Plaintiff is Kenneth E. Lloyd, an adult individual residing at 92 Autumn Lane,
Enola, Cumberland County, Pennsylvania 17025.
2. The Defendant is Sandra J. Lloyd, an adult individual residing at 37 Southmont Dr.
Enola, Cumberland County, Pennsylvania 17025.
3. Plaintiff and Defendant have been a bona fide residents of the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 2, 1980 in Camp Hill, P A.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Rights Act of the
Congress of 1940 and its amendments.
6. Plaintiff s social security number is 202-46-6905 and Defendant's social security
number is 19648-4843.
7. There have been no prior actions of divorce or for annulment between the parties.
8. Plaintiffhas been advised that counseling is available and that Plaintiff may have the
right to request that the court require the parties to participate in counseling.
Document #: 189296.1
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9. The Plaintiff and Defendant are the parents of two adult children.
COUNT!
Divorce
10. The averments of paragraphs l-9 hereof are incorporated herein by reference.
ll. The marriage is irretrievably broken.
12. The parties have been living separate and apart since October 4, 2000.
13. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and
Defendant.
COUNT II
Equitable Distribution
l4. The averments of paragraph l-13 are incorporated herein by reference.
15. During the marriage the parties acquired marital property, assets, and debts which
Plaintiff requests the Court equitably distribute and assign.
WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce, enter an order
equitably distributing marital property and enter such other orders as are appropriate and just.
Date: Itj :<.21 (7)
METZGER, WICKERSHAM, KNAUSS & ERB
By r/hJJJMJ ri 1IiiLb I
Melissa L. Stickel, Esquire
Attorney I.D. 85869
3211 North Front Street
Harrisburg, P A 1711 0-0300
(717) 238-8187
Attorneys for Plaintiff
Document #: 189296.1
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VERIFICATION
I, Kenneth E. Lloyd, hereby certify that the facts set forth in the foregoing Complaint in
Divorce are true and correct to the best of my knowledge, information and belief, and that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. !j4904 relating to unsworn
falsification to authorities.
Date
//Af~b~
Kenne
Document #: 189296.1
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KENNETHE. LlOYD,
: IN THE COURT OF COMMON PLEAS FOR
: CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff,
v.
: NO. 00-8274 Civil Term
SANDRAJ. LlOYD,
: CIVILACTION-LAW
Defendant
: COMPLAINTINDlVORCE
PLAINTIFF'S PRAECIPE TO DISCONTINUE
Kindly mark the above action by Plaintiff Kenneth E. Lloyd discontinued.
METZGER, WICKERSHAM, KNAUSS & ERB, P.e.
By: Gf')u 11 fv.n d &(1} I P
Melissa L. Stickel, Esquire
Attorney I.D. No. 85869
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Plaintiff
Dated: December 5. 2000
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CERTIFICATE OF SERVICE
I, Melissa L. Stickel, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Plaintiffs Praecipe to Discontinue
with reference to the foregoing action by first class mail, postage prepaid, this (:;fit day of
December, 2000 on the following:
H. Allison Wright, Esquire
Maria P. Cognetti & Associates
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
~d. Jncrbl
Melissa L. Stickel, Esquire
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