HomeMy WebLinkAbout09-5872DIANA LOHMAN
Plaintiff
V.
SHAUN LOHMAN
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. O 9- 6-9--7o2- C V I I
CIVIL ACTION - LAW
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 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, One Courthouse Square, Carlisle, PA
17013.
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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
DIANA LOHMAN
Plaintiff
V.
SHAUN LOHMAN
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0 j g- 7
CIVIL ACTION - LAW
DIVORCE
COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Diana Lohman, by and through her attorneys, Joseph D.
Caraciolo, Esquire and Foreman & Caraciolo, P.C., and makes the following Complaint in Divorce
and, in support thereof, avers as follows:
1. The Plaintiff, Diana Lohman, is an adult individual who currently resides at 108 1/2
Third Street, Boiling Springs, Cumberland County, Pennsylvania.
2. The Defendant, Shaun Lohman, is an adult individual who currently resides at 1535
English Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth
of Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married by formal ceremony on January 18,
2001 in Lebanon County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. At the appropriate time, Plaintiff will submit an affidavit alleging that the parties
have been living separate and apart for a period of at least two years.
8. The Plaintiff has been advised that counseling is available and that the Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. This action is not collusive.
10. There is one minor child to this marriage, Kayla Lohman, born December 17, 2000,
the custody of whom has been stipulated and docketed to Number 2007-6691 in Cumberland
County, Pennsylvania.
WHEREFORE, the Plaintiff, Diana Lohman, respectfully requests that this Honorable
Court enter a decree of divorce in this matter.
FOREMAN & CARA.IOW, P.C.
Date: O V- (/ 1 ova I
,PSEPH D. CARA"CIOLO, ESQUIRE
12 Market Street, Sixth Floor
Harrisburg, PA 17101
(717) 236-9391, I.D. #90919
DIANA LOHMAN IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
SHAUN LOHMAN CIVIL ACTION - LAW
Defendant DIVORCE
VERIFICATION
I verify that the statements made in this Complaint 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. § 4904, relating to unsworn falsification to authorities.
Dated: Signature: 4AA
Diana Loh", Plaintiff
AP Y
2009 27: I
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