HomeMy WebLinkAbout07-3771
JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. D7 - 3 771 &e u L T iia-'wi
TRACY L. LAMBERT,
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 also 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 SO 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 LAWYERAT 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
32 South Bedford Street
Carlisle, PA 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action- Law
: No. 07- 2'17/
e, ,, r,-.
: IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(c) or 3301(d)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, James Lambert, Jr., by and through his
JAMES LAMBERT, JR.,
Plaintiff
V.
TRACY L. LAMBERT,
Defendant
counsel, Michael J. Whare, Esquire and avers as follows:
1. Plaintiff is James Lambert, Jr., an adult individual, who currently resides at
3640 Hwy. 231, Lacy's Springs, Alabama.
2. Defendant, is Tracy L. Lambert, an adult individual, who currently resides at
111 '/z Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania.
3. Defendant has been a bona fide resident in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 29 2004, in East Petersburg,
Lancaster County, Pennsylvania and separated on or about May 7, 2007.
5. There have been no prior actions of divorce or 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 in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
Decree in Divorce and such other Orders as may be just and appropriate.
Date: & elf, O"7
Respectfully submitted,
Michael I Whare,^uire
Attorney for Plaintiff
3 7 East Pomfret Street
Carlisle, PA 17013
Supreme Ct. Id No. 89028
(717) 243-3561
VERIFICATION
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 4? ames Lamb , Plaintiff
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JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
TRACY L. LAMBERT,
Defendant
No. 07-3771
IN DIVORCE
AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. The parties to this action separated on February 1, 2005 and have continued to
live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
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 unswom falsification to authorities.
Date: - `,
1?qles Lam eft, Jr., Plaintiff
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JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07-3771
TRACY L. LAMBERT,
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 also 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 SO 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 LAWYERAT 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
32 South Bedford Street
Carlisle, PA 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07-3771
TRACY L. LAMBERT,
Defendant
IN DIVORCE
AMENDED COMPLAINT UNDER SECTIONS 3301(c) or 3301(d)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff; James Lambert, Jr., by and through his
counsel, Michael J. Whare, Esquire and avers as follows:
Plaintiff is James Lambert, Jr., an adult individual, who currently resides at
3640 Hwy. 231, Lacy's Springs, Alabama.
2. Defendant, is Tracy L. Lambert, an adult individual, who currently resides at
494 Frogtown Road, Pequea, Lancaster County, Pennsylvania 17565.
3. Defendant has been a bona fide resident in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 29 2004, in East Petersburg,
Lancaster County, Pennsylvania and separated on or about February 1, 2005.
5. There have been no prior actions of divorce or 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 in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
Decree in Divorce and such other Orders as may be just and appropriate.
Date: -/6-D7
Respectfully submitted,
Michael J. Whare, squire
Attorney for Plaintiff
37 East Pomfret Street
Carlisle, PA 17013
Supreme Ct. Id No. 89028
(717) 243-3561
JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07-3771
TRACY L. LAMBERT,
Defendant
IN DIVORCE
VERIFICATION
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 unworn falsification to authorities.
Date: o -7 ' - -4 d.,. ,
es Lambert, Jr., PlainJW
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JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07-3771
TRACY L. LAMBERT,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
22, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §
4904, relating to unworn falsification to authorities.
Date: r?' /"" Otn-t 'J_
es Lambert, Plaintiff
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JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : Civil Action- Law
: No. 07-3771
TRACY L. LAMBERT,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed
with the Prothonotary.
I verify that the statements made in this Affidavit 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:,)` D
es Lambert, Plaintiff
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JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
: No. 07-3771
TRACY L. LAMBERT,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
22, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this Affidavit 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.
Dated
Trac ert, Defendan t
?, ??rs
JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. 07-3771
TRACY L. LAMBERT,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed
with the Prothonotary.
I verify that the statements made in this Affidavit 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: O1 s) 6
Trac L ert, Defendant
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JAMES LAMBERT, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
TRACY L. LAMBERT,
Defendant
No. 07-3771
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for
entry of a divorce decree:
1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Filed June 22, 2007, was
served on the Defendant by certified mail, endorsed restricted delivery-return
receipt requested and signed on June 27, 2007 (attached hereto as proof of
service).
3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the
Divorce Code: by the Plaintiff on February 12, 2008; by the Defendant on
January 31, 2008.
4. Related claims pending: None.
5. (b) Date Plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the
Prothonotary: February 14, 2008.
W W
Date Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the
Prothonotary: February 14, 2008.
Respectfully submitted,
Date: 0 --? $ ??X t, /-t
Michael I Wh e, Esquire
37 East Pomfret Street
Carlisle, Pa 17013
(717) 243-3561
Supreme Court ID # 89028
Attorney for Plaintiff
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JAMES LAMBERT, JR.,
Plaintiff
V.
TRACY L. LAMBERT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action- Law
No. 07-3771
IN DIVORCE
PROOF OF SERVICE
omplete items 1, 2, and 3. Also complete
em 4 if Restricted Delivery is desired.
°rint your name and address on the reverse
;o that we can return the card to you.
Attach this card to the back of the mailplece,
or on the front if space permits.
1. Article Addressed to:
I t ?'?a p ? ne S?cee?'
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D. Is delive f address different from item IWO Y&
If YES, enter delivery address below: >"INlo
3. Service type
fi Certified Mall 13 &prses Mail
O Registered ® Return Receipt for Merchandin
13 Insured mail ? C.O.D. v
4. Restricted Delivery? (Extra Fee) pp Yea
2. Article Number
(rmnsfer from service label) 710, oaab 000 Dcab u 4
PS Form 3811, February 2004 Domestic Return Rsosipt 102595-02-M.1540
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
VERSUS
Tk&(--Y L.. LamEa :
DEF97NnAt-r
No. aCP-7 -3-7-11 CivzL rEp,
DECREE IN
DIVORCE
AND NOW, IT IS ORDERED AND
DECREED THAT 7AmES L-AmAERT- . To. , PLAINTIFF,
AND 1 n y L, L-,d#i8 RT- DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
E
PROTHONOTARY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
rr PENNSYLVANIA
Plaintiff
Vs File No. <:;?00 7
/
? L L OL ? 6-v- 4- IN DIVORCE
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
prior to the entry of a Final Decree in Divorce,
or x after the entry of a Final Decree in Divorce datedC? ',2 G ,
hereby elects to resume the prior surname of ? ; SS a-1 I , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 V.S. 70 .
Date:C3 2
Signature
i e of name being resumed
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF G&-m b e rl a 4 a(
On the day of M a rc?k , 200 g, before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
NOTARIAL SEAL
PROTHONOTARY, NOTARY PUBLIC
CARLISLE CUMBERLAND COUNTY COURTHOUSE
MY COMMISSION EXPIRES JANUARY 4, 2010
Prothonotary or Notary Public -/f
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