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Home My WebLink About03-5127 Andrew C. Sheely, Esquire "127 S. "Market Street . P.O. Box 95 Mechanicsburg, PA 17055 PA 10 NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DANIEL E. LUCAS, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : vs. CIVIL ACTION - LAW AMY D. LUCAS, : 03 - .5/;"'7 CIVIL TERM 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. You are warned that if you fail to do so, the case may proceed against you and a decree in 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 with 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 Courthouse, Carlisle, pennsylvania. 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 )~~ BY d.../_-,,~CU~ ~~~s~eelY, Esquire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for plaintiff Andrew C. Sheely, Esquire '127 S. ~Market street .P.o. Fox 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DANIEL E. LUCAS, SR., plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW Defendant 03 - SI ~ I CIVIL TERM AMY D. LUCAS, : IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is DANIEL E. LUCAS, SR., an adult individual who currently resides at 15 East Simpson Street, Mechanicsburg, Cumberland County, pennsylvania. 2. Defendant is AMY D. LUCAS, an adult individual who resides at 4807 East Trindle Road, Apt. 2, Mechanicsburg, Cumberland County, pennsylvania. 3. plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 31, 1995 in Virginia. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. '. 8. The marriage between the parties is irretrievably broken. 9. Plaintiff avers that he is the innocent and injured spouse, and that the Defendant has offered such indignities to Plaintiff so as to render his condition intolerable, life burdensome, unhealthy and impossible for a meaningful relationship or reconciliation. 10. This action is not collusive. 11. The parties separated on or about september 9, 2003. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Date: september~2003 Respectfully submitted, (]~ --.. An rew C. Sheely, Esquire Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 2 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904. relating to unsworn falsification to authorities. Date: September ~5, 2003 ?;;J} ( ~ ~ E. LUCAS, SR. - Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, FA 17055 FA 1D NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DANIEL E. LUCAS, SR.. plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMY D. LUCAS, 03 - CIVIL TERM Defendant IN DIVORCE AFFIDAVIT Daniel E. Lucas, Sr., being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. %J f ~2>>t Daniel E. Lucas, Sr. ~ ?:>(') ~ ~ ~ - of. I..l ~ .... Ei' D -l e o(! ~ w (') 1...."71 0 C (~, "" ">', rill';.; "" ___1 ,,, T' 1 r ~'.' ~ . ;~l Z:i_1 7: i".) "-l,-rl VJ" 0' " -<. jf~ ~ ~C) ~ ~~,~~ 'S. C~ W ~5rn -' C~_ ....,. :-1 c:- e~ . ~ ~b -< N -< Andrew c. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DANIEL E. LUCAS, SR., Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW AMY D. LUCAS, Defendant : 03 - 5127 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS ANDREW C. SHEELY, being duly Sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon AMY D. LUCAS, Defendant, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt card, on Septembe ~JC! ANDREW C. SHEELY SWORN to and subscribed before me this ~t:day of October, 2003. &~~/Y7, rA7A~_ Notary Public ~ Commission Expires: ~8fAL ~~~~ My Con..' /., ~ Nor. t8, 2008 T,lop)",n" (717) 697-7050 ANDREW C. SHEELY AITORNEY AT LAW 127 Saudl Market Street P.O, Box 95 Mechanicsburg, Pennsylvania 17055 Fox, (717) 697,7065 Amy D, Lucas Restricted Delivery For Addressee Only 4807 East Trindle Road, Apt. 2, Mechanicsburg, Pa 17055 September 26, 2003 FILE RE: 0,3 - 5127 In Divorce Dear Ms, Lucas: Enclosed for service upon you in accordance with the Pennsylvania Rules of Civil Procedure is a time stamped copy of the divorce complaint recently filed on behalf of your husband, Daniel E. Lucas, Sr. The Divorce Complaint was filed on September 26, 2003, In order to conclude the divorce, a period of ninety (90) days must expire after the date you receive this letter and the enclosed divorce complaint. At the end of the ninety (90) day period, I will forward an affidavit of consent and waiver of formal notice form to you As such, the divorce could be final by the end of December. If you have an attorney, please have him or her contact me as Soon as Possible, Very truly yours, ACS/bmk Enclosure c: Daniel E, Lucas, Sr, Certified Mail No: 7001 2! ANDREW C. SHEELY · Complete items 1, 2, aM 3, Also ~omplete item 4 if Restricted Delivery Is deSIred. · Print your name and address on the reverset so that we can return the card to you. · Attach this card to the back of the mailpieco, or on the front if space permits. 1. Article Addressed to: Amy D. Lucas RESTRICTED DELIVERY ~~~ 4807 East Trindle Road Mechanicsburg, PA 17050 '4t 2. Article Number (Transfer from S6rVfce label) PS Form 3811, August 2001 R'[jExJ.M~U.ii , o Return "R~ for ~erchandise o Insured Mall 0 C.O.D. I 4. Restricted Delivery? (Extra Fee) Yes 7001 2510 0000 3029 3780 Domestic Return Receipt 102595-01-M-2509 C) c." c:> " -' 2 s: -0 IT" rnn' 7-:(' ?J)\~',; ::..c,,' r.2c ~'~. J:. :2 , ! I \ \ \ \ \ <;fi \ 0" ,...; 7~i.JJ -'}~,\23 l'~('\ '-"';.:1:' ~;-:~ ~fl -:::-.:.., -'.~ -'i-t :<. T',... :~.::r. ? f" Andrew c. Sheely, Esquire 127 S. Market street P.O. Box 95 Mechanicsburg, FA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (FaX) DANIEL E. LUCAS, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMY D. LUCAS, 03 - 5127 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 26, 2003. 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: 10-;}7-0b Di:ri. (L~~ .~---- - Andrew c. shee~y, Esquire 127 S" Market: street: P.O. Box 9S Mechanicsburg, PA 17055 PA ID NO. 62469 717-6$7-7050 (Phone} 717-697-7065 (FaX) DANIEL E. LUCAS, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMY D. LUCAS, : 03 - 5127 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 26, 2003. I acknowledge that I accepted service of the divorce complaint on September 29, 2003. 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.A. Section 4904 relating to unsworn falsification to the authorities. IO/J7/0S DATE: / / ~ I - , CR~)7 ~lLt iL-t'Z;2- Amy D. Lucas ,~- ..- Andrew C. Sheely, Esquire 127 S. Market Street P.D. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DANIEL E. LUCAS, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMY D. LUCAS, 03 - 5127 CIVIL TERM Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301 tCl 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 decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: iO-d-'I-05 ~;t (d~~ Daniel E. Lucas, Sr. Andrew C. Sheely, Esquire 127 S. Market street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (FaX) DANIEL E. LUCAS, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMY D. LUCAS, 03 - 5127 CIVIL TERM Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301 IC) 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 decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: (0(J7Io5 l U; u.../ '7'LY IlL Lcc",-e~ Amy D. ~ucas Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DANIEL E. LUCAS, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW AMY D. LUCAS, : 03 - 5127 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Di vorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Certified mail, Restricted delivery, on September 29, 2003. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by plaintiff on October 27, 2005 and by Defendant on October 27, 2005. (b) (1) Date of execution of the Section 3301 (d) of the Divorce Code: filing and service of the plaintiff'S respondent: Not applicable. 4. Related claims pending: affidavit required by Not applicable: (2) Date of affidavit upon the None. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary. October ~ ,2005. Divorce Date Defendant's Waiver of Notice in sect~on 3301 (C) was filed with the Prothonotary. October ~ . 2005. ~ ~.~y, Esquire +.+.+.+. +.+.+.+.+. +. +. +.+. +. ~ +. +.+. +. +. +. +.+.+.+.+.+.+. +. +.+.+.+.+.+.+.~ . IN THE COURT OF COMMON PLEAS : OFCUMBERLANDCOUNTY STATE OF PENNA. DANIEL E. LUCAS, SR., PLAINTIFF 03 No. 5127 VERSUS AMY D, LUCAS, CIVILACTION - LAW IN DIVORCE DEFENDANT DECREE IN DIVORCE AND NOW, ~)~\ 2005 DANIEL E, LUCAS, SR. DECREED THAT AND AMY D LUCAS ARE D]VORCED FROM THE BONDS OF MATR]MONY, , ]T ]S ORDERED AND , PLA]NT]FF, , DEFENDANT, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . THE COURT RETA]NS JUR]SD]CT]ON OF THE FOLLOW]NG CLA]MS WHICH HAVE BEEN RA]SED OF RECORD ]N TH]S ACT]ON FOR WHICH A F]NAL ORDER HAS NOT YET BEEN ENTERED; /~/ /// /" . .;/ .. By tHE COURT: // '~b>U mm ?2~ NONE . . . . . . . . . . . . . . . . ot+. +. + 'to Of , "" ,/ ROTHONOTARY +. +.+.+.+.+.+. Of +.+. +.+.+.+.+.+.+.+.+. ++'+'+''1' +. 'f+''f+' '+' +. +. +. +. +. +. +. +. +. + '+:+. 'I' +. +. +. +. +. +. . . . . . . . . J, . . . . . . . . . . . . . . . . +. +. +.+ * 7 ~1~!/t 5(} [:,11 ~ f?: ,~~ 1ih7P{7 51l ('-;/ . ~~ ~