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DANIEL W. LUCAS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
MICHELLE D. LUCAS, : NO. 99- 5?2&/ CIVIL TERM
Defendant : IN DIVORCE
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 the 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 Court House, High and Hanover Streets, Carlisle,
IF YOU DO NOT FILE A CLAIM FOR 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone: (717) 249-3166
DANIEL W. LUCAS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
MICHELLE D. LUCAS, : NO. 99- -416 1 CIVIL TERM
Defendant : IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE OD
1. Plaintiff is Daniel W. Lucas, who currently resides at 7 Yankee Drive, Mt. Holly
Springs, PA 17065, Cumberland County, Pennsylvania, since 1994.
2. Defendant is Michelle D. Lucas, who currently resides at 4338 Carlisle Road,
Gardners, PA 17324, Cumberland County, Pennsylvania, since July 1999.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on June 12, 1998, at Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties
hereto in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has 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.
8. Plaintiff requests the Court to enter a Decree of Divorce.
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn
falsification to authorities.
Date: _ 8 -,;7-19
Daniel W. Lucas, Plaintiff
ANDREWS & JOHNSON
Ronald E. John n
Attorneys for t
78 W. Pomfr tre
Carlisle, PA 17013
(717) 243-0123