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Home My WebLink About07-2844LIZBETH LEREW, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0 '? - ~ ~`/ ~ Curs-~ ~~"" DARYL E. LEREW , :CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 within twenty (20) days. 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. far 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY DIVISION OF PROPERTY L,AWYER'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, PA 17013 (717) 249-3166 {800) 990-9108 c LIZBETH LEREW, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. ~ 7 - a ~ ~ `t Cccr~! T1.--- DARYL E. LEREW , :CIVIL ACTION-LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(D) OF THE DIVORCE CODE AND NOW, this ~~` day of , 2007, comes the Plaintiff, LIZBETH LEREW, by and through her attorney, William T. Smith, Esquire and avers the following: 1. The Plaintiff is LIZBETH LEREW, an adult individual, sui juris, who currently resides at 313 S. Frederick Street, Mechanicsburg, Cumberland County, Pennsylvania .17055. Plaintiff s Social Security Number is 183-64-6621. 2. The Defendant is DARYL E. LEREW, SR., an adult individual, sui juris, who currently resides at 2625 Herr Street, Harrisburg, Dauphin County, Pennsylvania 17103. Defendant's Social Security Number is 197-54-4898. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 19, 1998 in Camp Hill, Pennsylvania. 5. There has been no prior actions of divorce or annulment between the parties in this or any other jurisdiction except for the filing of a divorce complaint under section 3301 (d) of the Divorce Code. 6. Plaintiff and Defendant have been separated since April 14, 2007. 7. The grounds for divorce are: The marriage is irretrievably broken. 8. Plaintiff and Defendant have no children. 9. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. 10. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a Divorce Decree being handed down by this Court. WHEREFORE, Plaintiff requests this Honorable Court enter a final Decree in Divorce. Respectfully submitted, LAW OFFICES OF WILLIAM T. SMITH w ~~ Dated: S. 7 • ~ 7 By: iw\ ~. WILLIAM T. SMITH, ESQUIRE Attorney LD. No. 06887 3747 Derry Street Harrisburg, PA 17111 (717) 561-2677 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 C. S. §4904, relating to unsworn falsification to authorities. Dated: ~/ 'l i th Lerew ~_ N C.J ~~ ~ ~ ~ .y ~ ~~ X41 O - _,: ~ i:~ i ~1 ~: .. ~ '-C ~ C (y' -•- - ~ a r "~ LIZBETH LEREW, IN THE COURT OF CO14iMOy~ PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-2844 Civil Term DARYL E. LEREW , :CIVIL .ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, HEREBY CERTIFY that a true and correct certified copy of the foregoing Divorce Complaint has been sent by United States Mail, postage pre-paid, registered, certified, return receipt requested delivery No. 7155 5474 4100 4271 8476 to the following person: Daryl E. Lerew, Sr. 2625 Herr Street Harrisburg, PA 17103 Dater `~ 1 ` `~ 7 William T. S ' Attorney LD. # 06887 3747 Derry Street Harrisburg, PA 17111 (717} 561-2677 Attorney for Plaintiff ~. ~ ~ ~ Law J maces of WiNiam T. Smith ~ w,, ~-: , ~7~7 Darry Street E Harrisk~ur~, pA 17111 _ a • • ~ - A. S1~nat1 ( Addressee or ^ Apsnt) ''s` `i,`_ 7155 5474:43~'4271 847 ~. r~.e~rosd y: (atsee .~-~» RETURN RECEIPT REQUESTED _ ~ C. OMs of Osl sry ~~ A~tlcb Addrnpd To: rr ~~ ~ t--i- D.Aldnsa rlsst(t ~ uaedars.ndrl ~rrr~~~en~nr~~~~nnr~+nn~~~n~un~~i~r~nr~r~r~r~n~~n Secondary Addres uee / Av/ M~b~'i~ ~a/.as• v~r~r clsnr) ~ c"i ryl E . Le rew ~ r 2625 Herr St __ _ - - -- Harrisburg ~A 'i 71 Q3-1815 DMiwry Address ~~City _- State ZIP • 4 Cods