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JENNIFER M. LUEBBERS,
Plaintiff,
VS.
GERALD LUEBBERS,
Defendant,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 99 - 1?90S CIVIL TERM
IN DIVORCE
NOTICE
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, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS
FEES OR EXPENSES BEFORE A DECREE OF 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 AssocmTInN
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
?y
Date:
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
Carol J. ind ay, squ'
ID#44
11 East High Street
Carlisle, PA 17013
(717) 243-5513
JENNIFER M. LUEBBERS,
Plaintiff,
VS.
GERALD LUEBBERS,
Defendant,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 99 - &90-S CIVIL TERM
IN DIVORCE
COMPLAINT in DIVORCE
Jennifer M. Luebbers, Plaintiff, by attorneys, FLOWER, FLOWER & LINDSAY, P.C., respectfully
represents:
1. The Plaintiff is Jennifer Luebbers, who currently resides at P.O. Box 231, Cumberland
County, Mt. Holly Springs, Pennsylvania, where she has resided since 1999.
2. The Defendant is Gerald Luebbers, who currently resides at 122 Pine Grove Road,
Cumberland County, Gardners, Pennsylvania, where he has resided since 1984.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 22, 1982, at Carlisle, Cumberland County,
Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the parties in this
or in any other jurisdiction.
6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is
irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code.
7. Plaintiff has been advised of the availability of marriage counseling and of the right to request
that the Court require the parties to participate in marriage counseling, and does not request
counseling.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
Carol J. say, Esquire
ID#44
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Date:I _?i 07
VERIFICATION
I, the undersigned, hereby verify that the statements made herein 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.
Jennife M. Luebbers
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Date:
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