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KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
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CHRISTINE LEMKE,
Plaintiff
V.
TIMOTHY LEMKE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10- 1857
CIVIL LAW
DIVORCE
Civi I Term
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 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: 1 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 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, PA 17013
(717) 249-3166 OR (800) 990-9108
0391.50 P A A-rry
co 1887
P-T .138437 t
KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
CHRISTINE LEMKE,
Plaintiff
V.
TIMOTHY LEMKE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL LAW
DIVORCE
COMPLAINT FOR DIVORCE
COUNT I
Request for a No-fault Divorce Under S3301(c)
or Under 63301(d) of the Domestic Relations Code
1. Plaintiff is CHRISTINE LEMKE, who currently resides
at 3022 Harvard Avenue, Camp Hill, Cumberland County, PA 17011.
2. Defendant is TIMOTHY LEMKE, who currently resides at
130 Spring Drive, Dillsburg, PA 17019.
3. Plaintiff has been a bona fide resident in the
Commonwealth for at least six (6) months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on September
20, 1986 in Cumberland County, Pennsylvania.
5. The parties have been living separate and apart since
February 21, 2009.
6. There have been no prior actions for divorce or for
annulment between the parties.
7. The marriage is irretrievably broken.
8. 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.
9. The Defendant is not a member of the armed services
and has not been at any time during the marriage.
WHEREFORE, Plaintiff respectfully requests this Court to
enter a Decree of Divorce pursuant to § 3301(c) or § 3301(d) of the
Domestic Relations Code.
COUNT II
Request for Equitable Distribution of Marital Property
Under 93502 of the Domestic Relations Code
10. Plaintiff hereby incorporates Paragraphs 1 through
9 of her Complaint as if fully set forth herein.
11. The parties are owners of marital property subject
to equitable distribution.
12. Plaintiff requests the Court to equitably divide,
distribute or assign the marital property between the parties and
the marital debts of the parties without regard to marital
misconduct in such proportions as the Court deems just after
consideration of all relevant factors.
J
WHEREFORE, Plaintiff requests this Honorable Court enter
an Order of Equitable Distribution of marital property and marital
debts pursuant to §3502 of the Domestic Relations Code.
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DATE : 3l
KENN TH P. LEWIS, ESQUIRE
Atto ney I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
V
VERIFICATION
I hereby verify that the statements made in the foregoing
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.
Dated: 3 ) Z Z-o ) D
CHRISTINE LEMKE