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Home My WebLink About10-0852LORRAINE E. STITT, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 10 - 8U OtVi I (erm DANIEL STITT, : CIVIL ACTION - LAW 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 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 on the first floor of the Cumberland County Courthouse, Carlisle, Cumberland County, PA. 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 LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Court Administrator at (717) 780-6624. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. 43Q(.50 PO CC 89.174 'G Melanie L. Erb, Esquire 2132 Market Street Camp Hill, PA 17011 717-975-9446 Merbkdcdlaw.net LORRAINE E. STITT, Plaintiff V. DANIEL STITT, Defendant ?1- : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 10 L : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Lorraine Stitt, by and through her attorney, Melanie L. Erb, Esquire and the Dethlefs-Pykosh Law Group, LLC, who brings this Complaint in Divorce and avers as follows: 1. Plaintiff is Lorraine Stitt, an adult individual currently residing at 713 Alberta Ave., Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Daniel Stitt, an adult individual currently residing at 958 Limekiln Rd, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff avers that Defendant has also been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 5. The parties were married on October 7, 1995 in Broomall, Delaware County, Pennsylvania. 6. There have been no prior actions of divorce or annulment between the parties. 7. The marriage is irretrievably broken 8. Plaintiff avers that neither party is an active member of the United States Military or its allies. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff waives that right. 10. Plaintiff avers that Defendant has been advised of the availability of counseling and that Defendant may have the right to request that the Court require the parties to participate in counseling. 11. Plaintiff avers the grounds for divorce: a. The marriage is irretrievably broken; b. The parties consent to the divorce; or in the alternative, c. The parties have lived separate and apart for a period or two (2) years. WHEREFORE, Plaintiff, Lorraine E. Stitt, respectfully requests this Honorable Court grant a Decree in Divorce pursuant to Section 3301 (c) or (d) of the Divorce Code. COUNT II EQUITABLE DISTRIBUTION 12. Paragraphs 1 thru 11 are incorporated herein by reference as though set forth in full. 13. Plaintiff and Defendant have acquired property during the marriage which is subject to equitable distribution. 14. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiff, Lorraine E. Stitt, respectfully requests this Honorable Court to divide all marital property pursuant to Section 3501 and 3502 of the Divorce Code prior to the entry of a final divorce decree. Respectfully Submitted, MelanWL?.i&b,Esquire Attorney I.D. No. 84445 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 717-975-9446 Attorney for Plaintiff VERIFICATION I, LORRAINE E. STITT, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. I_ b-Io - 4"'.- uf'?? INE E. STITT DATE LORRAINE E. STITT, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 10-852 DANIEL STITT, : CIVIL ACTION - LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Mark T. Silliker, Esquire, attorney for Daniel Stitt, do hereby accept service of the Complaint in Divorce on behalf of Defendant, as per his request. Date: Mark T. Silliker cry ;... LORRAINE E. STITT, ) IN THE COURT OF COMMON PLEAS Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) No. 10-852 DANIEL STITT, ) DIVORCE Defendant ) d z' ENTRY OF APPEARANCE ? f71 TO THE PROTHONOTARY: u? ? y Please enter my appearance on behalf of the De dant Daniel #8 Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 mst@mtravislaw.com Attorney for Defendant WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Defendant Daniel Stitt. 40;?? Mark T. Silliker, Esquire ID No. 33671 Silliker and Reinhold 5922 Linglestown Road Harrisburg, PA 17112 717-671-1500 .t LORRAINE E. STITT, Plaintiff V. DANIEL STITT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 10-852 DIVORCE CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document was served on the below persons by first class U.S. Mail, postage prepaid: Melanie L. Erb, Esquire Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 Michael S. Travis 9 `? 3904 Trindle Road Camp Hill, PA 17011 Attorney for Defendant LORRAINE E. STITT, ) IN THE COURT OF COMMON PLEA t T; Plaintiff ) CUMBERLAND COUNTY, PENNSII N14 -+ V. ) No. 10-852 DANIEL STITT, ) DIVORCE .' Defendant Cl) q NOTICE OF DEFENDANT'S REQEUST FOR MARITAL COUNSELING TO THE PROTHONOTARY: Without waiving objection to venue in Cumberland County, as York County appears to be the correct venue*, Defendant, Daniel Stitt requests marital counseling pursuant to Pa.R.C.P 1920.45(c)(1). f ichael S. Travis 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 mst@mtravislaw.com Attorney for Defendant * Defendant intends to request a transfer of venue to York County under Pa.R.C.P 1006(a) or (d). VERIFICATION The statements made in this Notice of Request are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Sect. 4904 relating to unsworn falsification to authorities. Daniel Stitt, efendant r LORRAINE E. STITT, ) IN THE COURT OF COMMON PLEAS Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) No. 10-852 DANIEL STITT, ) DIVORCE Defendant ) CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document was served on the below persons by first class U.S. Mail, postage prepaid: Melanie L. Erb, Esquire Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 'iael S. Travis 3904 Trindle Road Camp Hill, PA 17011 Attorney for Defendant