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HomeMy WebLinkAbout09-1240KATINA LAMBERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WILLIAM LAMBERT, JR., : NO. 2009 - 1670CrvIL TERM Defendant DIVORCE NOTICE TO DEFEND 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 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 at the Cumberland County Courthouse, 1 Courthouse Square, 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 A 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. Pennsylvania Lawyer Referral Line Lawyer Referral Services Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 KATINA LAMBERT, Plaintiff V. WILLIAM LAMBERT, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2009 - CIVIL TERM : DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE NOW comes Plaintiff and for cause of action against Defendant who says: Plaintiff is Katina Lambert, who resides in Newburg, Cumberland County, with a street and mailing address of 108 Minick Drive, Newburg, Pennsylvania 17240. 2. Defendant is William Lambert, Jr., who resides in Newburg, Cumberland County, with a street and mailing address of 108 Minick Drive, Newburg, Pennsylvania 17240. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this complaint. 4. Plaintiff and Defendant married on April 27, 2001 in Franklin County, Pennsylvania. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the Court to require the parties to participate in counseling. 8. Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The causes of action and sections of the Divorce Code under which the Plaintiff is proceeding are: A. Section 3301(c) The marriage is irretrievably broken. B. Section 3301(d)• The marriage is irretrievably broken and the parties have been living separately and apart since October 2008. If the parties do not agree to proceed under Section 3301(c) of the Divorce Code, then Plaintiff will submit an Affidavit alleging that the parties have lived separately and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a Decree of Divorce, divorcing the parties from the bonds of matrimony. Respectfully Submitted, NEUHARTH LAW OFFICES Paul M. Ferguson Supreme Ct. No.: 203293 Attorney for Plaintiff P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 VERIFICATION I verify that the statements made in this document 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 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. A Date Kat a Lamb ert ? ? , `-- ?. ? ?- N J.l w? s? ` pN ? y "X ?` , ( vV ? - KATINA LAMBERT, Plaintiff V. WILLIAM LAMBERT, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2009 - A OCIVIL TERM : DIVORCE NOTICE OF INTENTION TO RESUME MAIDEN NAME Notice is hereby given that the Plaintiff in the above-captioned matter hereby elects to resume and hereafter use her previous name of Katina Witmer. Katina LambertTo be known as: a ma Witmer "L?" COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN SS On this,9-i'3' day of Rbrualt , 2009, before me, a Notary Public, personally appeared Katina Witmer, known to a to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purposes therein contained. In witness whereof, I have hereunto set my hand and official seal. Notary PPlic NOTARIAL SEAL STACI L STRICKLAND Ely #KRSk" goo "WIM,IN on "?!!AIq it. !ot! ?p tAMATOO 'R ? a?ioY! 11t1lO I J?INI?A'1 , OpOS ONS2 03MAND tOS ,Rf pW? 01*3 no+eaimmO yM? ?Y KATINA LAMBERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WILLIAM LAMBERT, JR., : NO. 2009 - 1240 CIVIL TERM Defendant DIVORCE AFFIDAVIT OF SERVICE I, Paul M. Ferguson, of Neuharth Law Offices, hereby state that on March 9, 2009, 1 mailed by First Class U.S. Mail and by Certified Mail, No. 7008 1830 0002 4201 0868, Return Receipt Requested, Addressee Only, a copy of the Complaint in Divorce to Defendant William Lambert, Jr. at 108 Minick Drive, Newburg, Pennsylvania 17240, the last known mailing address of Defendant, which documents were received on March 4, 2009, as evidenced by the attached Domestic Return Receipt. (See Attached Exhibit A). Paul M. Fergusofi Supreme Ct. ID #: 203293 Attorney for Plaintiff Neuharth Law Offices P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 a _ . `- ¦ Complete Items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse that we can return the card to you. ¦" h this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ? ? ? IOI. t1 C?C3 h..bQ 1?Tf J ?', ? , .Q(fh lGl? V(/'(i 1C /0 Iva 'j L?n I - 17a Yo A. 0 Agent B. Received by Prhrted Name) C. D *b Ivey 3? 09 D. la delivery address different from item 1? ? Yes If YES, enter delivery address below: 0 No 3 Servloe 71" 0 O" M Mail 13 Eprese Map O Registered O Return Receipt for Merchandee 0 Insured Mail 0 C.O.D. 4. Restricted DepvertR (Extra Fee) 0 Yes 2. Article Number (Tmr,rww sler hom serHCe MW 7008 1830 0002 4201 0868 PS Form 3611, FiWwy 2M Darnmi o PA m Receipt lomeesae+a ?sw Exhibit A ?++ L,.... ? ... _ K.': 't'2 ?. ? r;? - r- ' -. ?.:: ? ... KATINA LAMBERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WILLIAM LAMBERT, JR., : NO. 2009 - 1240 CIVIL TERM Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on March 2, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 90 days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce. 4. 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 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 Kati ha Lambert FILM-OF=FICE OF THE PROTHONOTARY 2009 JUN 12 AM 10: 0 5 GUM- PS'ASYLVK-4A KATINA LAMBERT, Plaintiff V. WILLIAM LAMBERT, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2009 - 1240 CIVIL TERM DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 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 Waiver 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. Dat a ina Lambert PLED-OF ICE OF THE PROTHONOTARY 2009 JUN 12 AM 10'U 5) CUML? ?JJNTY P EN`NiSYLVAI A KATINA LAMBERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WILLIAM LAMBERT, JR., : NO. 2009 - 1240 CIVIL TERM Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on March 2, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 90 days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce. 4. 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 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 Willi Lambert, Jr FILED-OFFICE OF THE PPC Hr.1-NOTA,9Y 2009 JUN 12 AM 10: 0 5 PEi?J-a>YLViN^ A KATINA LAMBERT, Plaintiff V. WILLIAM LAMBERT, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2009 - 1240 CIVIL TERM : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE I . 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 Waiver 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. 76? Date illi Lambert, Jr. F#L OFF E OF THE PROTHION AMY 2009 JUN 12 Ali 10: 05 PE'NIN , LV,4i,' + KATINA LAMBERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW WILLIAM LAMBERT, JR., : NO. 2009 - 1240 CIVIL TERM Defendant 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. Ground for Divorce: Irretrievable breakdown under 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on March 4, 2009. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: by Plaintiff. June 5, 2009; by Defendant: June 7, 2009. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in 3301 Divorce was filed with the Prothonotary: June 12, 2009. Date Defendant's Waiver of Notice in 3301 Divorce was filed with the Prothonotary: June 12, 2009. Paul M. Ferguson ' Supreme Ct. No.: 203293 Attorney for Plaintiff Neuharth Law Offices P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 Fla-FICF OF THE PROTHONOTARY, 2004 JUN 12 AM 10: 0 7 CuNib: PENN'S?'LVA,fVA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATINA LAMBERT, Plaintiff V. WILLIAM LAMBERT, JR., Defendant NO. 2009 - 1240 DIVORCE DECREE C7-3. •rs?p. A , AND NOW, I4it is ordered and decreed that KATINA LAMBERT plaintiff, and WILLIAM LAMBERT, JR. defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: None. J. Prothonotary Attest: ld - ©9 y7 u ,, a_ c