HomeMy WebLinkAbout04-2770KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
MILTON H. FRANKLIN,
Plaintiff
V.
CYNTHIA FRANKLIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. C) { - a77'J
CIVIL FLAW - 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 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, Hanover & High
Streets, 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
1-800-990-9108
KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
MILTON H. FRANKLIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND rCOUNTY, PENNSYLVANIA
V. NO.
l/?l p'
CYNTHIA FRANKLIN, !r? O
Defendant CIVIL LAW - DIVORCE
COMPLAINT IN DIVORCE
COUNT I
Request for a No-fault Divorce Under 63301(c)
of the Domestic Relations Code
1. The Plaintiff is MILTON H. FRANKLIN, an adult
individual currently residing at 36B 11th Street, New Cumberland,
Cumberland County, Pennsylvania, 17070.
2. Defendant, CYNTHIA FRANKLIN, is an adult individual
currently residing at 36B 11th Street, New Cumberland, Cumberland
County, Pennsylvania, 17070.
3. Defendant 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
19, 2003 in Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6. There are no children born of the marriage.
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.
WHEREFORE, Plaintiff respectfully requests this Court to
enter a Decree of Divorce pursuant to § 3301(c) of the Domestic
Relations Code.
Respectfully submitted,
DATE: 6/16/04 ?1
KE ET F. LEWIS, ESQUIRE
Attorney for Plaintiff
VERIFICATION
I hereby 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. Section
4904, relating to unsworn falsification to authorities.
Dated: 6/16/04 `
MILTON H. FRANKLIN
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Curtis R. Long
Prothonotary
office of the i3rotbonotarp
Cumberfanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
n 14 - .Z. 7 70 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573