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HomeMy WebLinkAbout01-0358 FX,_ JAMES R. LEWIS, JR., :COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. v /- 3 S8 CIVIL TERM CIVIL ACTION -LAW DENISE E. LEWIS, Defendant : 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 LHW OFFICES SNELBAKER, BRENNEMAN & SPARE SNELBAKER, BRENNEMAN & SPARE, P.C. By: Atto neys f laintiff ~. JAMES R. LEWIS, JR., Plaintiff v. DENISE E. LEWIS, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.o/-3-~~~ CIVIL TERM CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT ONE -DIVORCE 1. Plaintiff JAMES R. LEWIS, JR. is an adult individual residing at 213 Railroad Avenue, Mechanicsburg, Pennsylvania 17055. 2. Defendant DENISE E. LEWIS is an adult individual residing at 213 Railroad Avenue, Mechanicsburg, Pennsylvania 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on September 27, 1980 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties LAW OFFICE6 SNELBAKER. BRENNEMAN & SPARE hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph 4, above. 6. Neither party is a member of the armed forces of the United States of America. 7. The marriage is irretrievably broken. ,_ 8. The 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. 9. The Plaintiff requests this Court to enter a decree of divorce based upon irreconcilable differences. WHEREFORE, JAMES R. LEWIS, JR. requests this Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 included in this Complaint are incorporated herein by reference. 11. Plaintiff and Defendant have legally and beneficially acquired various property and assets since the date of their marriage on September 27, 1980. 12. Plaintiff and Defendant have not agreed to any equitable distribution of their property and assets. WHEREFORE, Plaintiff JAMES R. LEWIS, JR. requests this Court to order equitable distribution of the parties' marital property. WHEREFORE, the Plaintiff requests this Court to: LAW OFFICES SNELBAKER. BRENNEMAN & SPARE (a) Enter a decree of divorce divorcing the Plaintiff from the bonds of matrimony; -2- r (b) Order equitable distribution of marital property; (c) Order such other relief as this Court deems just and reasonable. SNELBAKER, BRENNEMAN & SPARE, P.C. By: Philip H. 'pare, squire 44 West Main Street Mechanicsburg, PA 17055-0318 (717)697-8528 Attorneys for Plaintiff James R. Lewis, Jr. LAW OFFICE6 SNELBAKER. BRENNEMAN & SPARE Date: January ~~ , 2001. -3- w VERIFICATION I verify that the statements made in the foregoing 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. O James R. Lewis, Jr. Date: January ~7, 2001. LFW OFF6EE SNEL6AKER. BRENNEMAN St SPARE JAMES R. LEWIS, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 01-358 CIVIL TERM DENISE E. LEWIS, Defendant :CIVIL ACTION -LAW IN DIVORCE NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. COUPITER-AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE Check either (a)_or (b): ^ (a) I do not oppose the entry of a divorce decree. [~(b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ~i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ^ (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not laim them before a divorce is granted. ~(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. LAW OFFICES I verify that the statements made in this Counter-Affidavit are true and correct. I sNEL6AKER, understand that false statements herein are made sub'ect to the enalties of 18 Pa.C.S. 4904 BRENNEMAN ~ P & SPARE relating to unsworn falsification to authorities. nQ-^~ Date: ! L.~ ~ ~ DI ~ e.(iL''~Q Denise E. Lewis