HomeMy WebLinkAbout03-5783
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 03-57[3 C(~l/
NANCY L. ADAMS,
Plaintiff,
LARRY E. ADAMS,
Defendant,
: CNIL ACTION - AT LAW
: 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 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 grouod for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage couoselors is available in the Office of
the Prothonotary at the Cumberland Couoty Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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
2 LIBERTY AVENUE
CARLISLE, P A 17013
(717) 249-3166
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. D:3 -- 61t~
: CIVIL ACTION - LAW
: IN DIVORCE
NANCY L. ADAMS,
Plaintiff
LARRY E. ADAMS,
Defendant
COMPT.A TNT TN DTVORCF.
The Plaintiff, Nancy L. Adams, by and through her attorneys, The Law Offices
of Patrick F. Lauer, Jr., LLC, makes the following Complaint in Divorce:
1. The Plaintiff, Nancy L. Adams, is an adult individual who resides at
1024 Walnut Street, Cumberland County, Lemoyne, Pennsylvania 17043.
2. The Defendant, Larry E. Adams, is an adult individual whose is
currently living at 1024 Walnut Street, Cumberland County, Lemoyne, Pennsylvania.
3. The Parties have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing ofthis Complaint.
4. The Plaintiff and the Defendant were married on September 25, 1982 in
Harrisburg, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between
the parties.
COUNT I - INDIGNITIES
6. Paragraphs One (1) through five (5) are incorporated herein by reference
as if set forth in full.
7. Plaintiff avers that Defendant, Larry E. Adams, has offered such
indignities to the person of the Plaintiff as to render her condition intolerable and life
burdensome.
8. The instant action is brought by the Plaintiff as an innocent and injured
spouse and is without collusion between the parties.
9. The Defendant is not in any branch of military servIce and IS not
entitled to relief under the Soldiers and Sailors Civil Relief Act.
10. Plaintiff makes no request to counseling pursuant to S3302 of the
Divorce Code.
WHEREFORE, Plaintiff prays that a Decree be granted by your Honorable
Court divorcing Nancy L. Adams, the Plaintiff, from the bonds of matrimony between
herself and the said Defendant.
COUNT 11- IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE
PURSUANT TO SECTIONS 3301(c) or 3301(d)OF THE DIVORCE CODE
11. The averments of Paragraph One (1) through Ten (10) are incorporated
herein and made a part hereof as though the same had been set forth in full.
12. Plaintiff believes and, therefore, avers that the marriage entered into
between the parties on September 25, 1982, is and has been irretrievably broken.
13. Plaintiff makes no request for counseling pursuant to ~2203 of the
Divorce Code.
WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree
of Divorce in this matter.
Respectfully submitted,
If} - 3 () - 20i.J3
Date: I'
NANCY L. ADAMS
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
LARRY E. ADAMS,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
VF.~TFTr.A'fTON
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: la/30( n"'2,
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NANCY L. ADAMS,
Plaintiff,
v.
LARRY E. ADAMS,
Defendant,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. 03-5783 Civil Term
CIVIL ACTION -- AT LAW
IN DIVORCE
PRAECIPE TO WITHDRAW DIVORCE COMPLAINT
TO THE PROTHONOTARY:
Kindly withdraw the divorce complaint in the above captioned
case.
Respectfully submitted,
arlit<' . Ma'r ley, Esquire
Law Off'ces of Patrick F. Lauer, Jr., L.L.C.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
Date: November 7, 2005
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