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HomeMy WebLinkAbout09-4021I 'a DANITA LISK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. Qr> - C?Gd ?IYI 7 T-?r'Grl DAVID LISK, Defendant IN DIVORCE NOTICE TO DEFEND 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 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY SAIDIS, RJOWER SL LINDSAY ATMIMIMM, 26 West High Street Carlisle, PA Carol J. Linds , Attorney Id. 4 6 26 West High reel Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff DANITA LISK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. O t- 40 21 DAVID LISK, Defendant IN DIVORCE COUNTI COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Danita Lisk, an adult individual, residing at 57 "F" Street, Carlisle, Cumberland County, Pennsylvania, since 1996. 2. The Defendant is David Lisk, an adult individual, residing at 60 Center Street, Carlisle, Cumberland County, Pennsylvania, since February 7, 2009. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 5, 1998 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the FLOWER SAMIS, UNDS" 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. . 4& COUNT II CUSTODY 8. The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein. 9. Plaintiff seeks custody of the following child: Joshua Lisk, age 11. The child was born out of wedlock. The child is presently in the custody of Mother who resides at 57 "F" Street, Carlisle, Cumberland County, Pennsylvania. During the past five years, the child has resided with the following persons and at the following addresses: Name Plaintiff and Defendant Plaintiff Address 57 "F" Street, Carlisle, PA 57 "F" Street, Carlisle, PA Dates From birth until February 7, 2009 February 7, 2009 to the present The mother of the child is Danita Lisk, currently residing at 57 "F" Street, Carlisle, Cumberland County, Pennsylvania. She is married. The father of the child is David Lisk, currently residing at 60 Center Street, Carlisle, FLOWER & LINDSAY 26 West High Street Carlisle, PA Cumberland County, Pennsylvania, with his brother. He is married. 4. The relationship of Plaintiff to the child is that of Mother. 5. The relationship of Defendant to the child is that of Father. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. The child would benefit from the parties sharing legal custody. b. The child would benefit from residing in the marital home. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant her joint physical custody and primary legal custody of the child. SAIDIS, FLOWER & LINDSAY Carol J. Lindsa , ire Attorney Id. AAA9y 26 West High reet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff FLOWER SAID, LINDSAY 26 West High Street Carlisle, PA ADA. VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. j C?-an Lisk Date: RJOWER SAIDIS, LINDSAY MMUMEM 26 West High Street Carlisle, PA .s , OF F'LED,'a :.•}?E ZQ09 J?,??? ? ? r,'' 3; 39 oil Ty