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Home My WebLink About04-5000GWEN M. LUKENS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. OLI, S6JV Civil Term JASON E. LUKENS, ACTION IN DIVORCE Defendant 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 244-3166 ORIGINAL GWEN M. LUKENS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 91- 50" Civil Term JASON E. LUKENS, : ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Gwen M. Lukens, a competent adult individual, who has resided at 5340 Oxford Circle, Apt 44, Mechanicsburg, Cumberland County, Pennsylvania, since May 2004. 2. Defendant is Jason E. Lukens, a competent adult individual, who is believed to reside at RD#4, Box 4419, Duncannon, Perry County, Pennsylvania, 17020. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on April 7, 2001 in Perry County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities, Date: ?I-? /6 1 )aaV-'-'- A A wen(ftukens, Plaintiff Respectfully submitted, fe Adams, Esquire . No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?-, ?\ ?? ?. ? ?? ? `Z W ? ? t !l G> GJ la it ^?lI ??'. C? ?? . ""T'. ?z. <<- ?,?? ` ' ?:, GWEN M. LUKENS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 04 - 5000 Civil Term JASON E. LUKENS, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this October 14, 2004, I, Jane Adams, Esquire, hereby certify that on October 13, 2004, a certified true copy of the Notice to Defend and Divorce Complaint was served, via certified mail, return receipt requested, addressed to: Jason Lukens RR4 Box 4419 Duncannon, Pa. 17020 DEFENDANT t, r Respectfully 1.D.)No. 79465 I&South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF N -? ?a ?.? s- - ? -? t? _, ?;__:; -- -?„r, ,. ?<? ?, _ ; , _ : ?, ,:: ;,; a ?, ` N GWEN M. LUKENS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 04 - 5000 Civil Term JASON E. LUKENS, ACTION IN DIVORCE Defendant PETITION FOR SPECIAL RELIEF AND NOW COMES, Gwen M. Lukens, by and through her counsel, Jane Adams, Esquire, and asks this Court for Special Relief pursuant to the Divorce Code as follows: 1. Plaintiff is Gwen M. Lukens, who currently resides at 5340 Oxford Circle, Apt 44, Mechanicsburg, Cumberland County, Pa., 17055. 2. Defendant is Jason E. Lukens, whose last known address is RD#4, Box 4419, Duncannon, Perry County, Pennsylvania, 17020. 3. The parties were married on April 7, 2001. 4. A divorce was filed in the above-captioned matter on May 6, 2004. 5. During the marriage, the parties lived at the marital home, which is located at 50 S. 39th Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 6. The marital home was listed for sale with Matthew R. Hockley of Century 21 and the parties recently entered into a sales agreement regarding the property. 6. During the marriage, the parties owned two vehicles, a 2000 Toyota Tacoma and a 1997 Saturn SL; these two vehicles were purchased during the marriage. 7. Wife is self-employed and provides cleaning services; adequate transportation is essential to her livelihood. 8. Husband is not currently employed. 9. During the marriage, Wife maintained the monthly payments on the Toyota Tacoma, maintained the insurance, and all other costs attributable to this vehicle. 10. Wife is requesting sole and exclusive possession of the Toyota Tacoma truck for the following reasons: a. Wife drove the Toyota Tacoma Truck throughout the marriage and used the vehicle in her cleaning business. She maintained all loan and insurance payments. The truck is essential to maintaining her employment. Husband is currently not employed. b. On the morning of December 28, 2004, between approximately midnight and 7 a.m., Husband removed the vehicle, which is jointly titled, from the parking lot of Wife's apartment complex. Such action seriously jeopardized Wife's employment. A payment towards the truck was due on January 4, 2005. During the time Husband had possession of the truck, he did not make any payments towards the car loan or insurance. c. Wife peacefully obtained physical possession of the vehicle in a public place on January 11, 2005. She still has serious concerns that Husband may try to obtain possession of the vehicle thereby jeopardizing her ability to maintain gainful employment. 11. Wife is requesting that Husband be ordered to cooperate with the sale of the marital home for the following reasons: a. Although Husband did sign a sales agreement regarding the marital home, Husband has made several representations to Wife that he would not cooperate with the sale of the marital home or sign any documentation to effectuate the sale of the marital home. b. Before the home was listed for sale, a Sheriff's Sale had been scheduled regarding the property. c. Neither party is currently living in the home. d. Husband said to Wife "I am going to get you any way I can" and has made representations to her that he would not sign the Deed or the closing documents. e. If the sale of the Marital Home does not occur due to Husband's failure to cooperate, great cost and expense would accrue to the parties, thereby constituting waste of the remaining marital assets. 12. Failure to grant these above requests would irreparably harm Plaintiff, and immediate relief is required. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant her Petition for Special Relief and any other relief this Honorable Court deems necessary and appropriate. Respectfully submitted, Date: T . 0. 79465 S uth Pitt Street Carl' le, Pa. 17013 (7245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint 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 falsification to authorities. < K 1 Q?1 wen M. Lukens, Plaintiff ?., r i') vi ?l C_ ? _? _ ? l?_ r.? -?;,} !: :; ? _ r,, -= .? , - c`? G.. . GWEN M. LUKENS, Plaintiff VS. JASON E. LUKENS, Defendant AND NOW, this January 26, 2005, I, Jane Adams, Esquire, hereby certify that on or about January 25, 2005, a certified true copy of the Notice to Defend and Divorce Complaint was served, via certified mail, return receipt requested, addressed to: Jason Lukens R.D. #4 Box 4419 Duncannon, Pa. 17020 DEFENDANT • Complete Items 1; 2, and 3. Also complete Item 4 If Restricted 0*My Ie deNred. • Print you narna and addrew on the reveme so that we can letiun the card to you. ¦ Attach this card to the heck of the malVeoe, or on the front H space permits. t. Ankle Addressed to: UAeoA, Lukens R.'b .4 -Sox 441q IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 5000 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE ?t9hGZWlt?D4nf PA 0020 O Apaa D. Rao kvd try (Pdebd AW* C. Dab of Deavery ? D. isd*mysddlwAlfarera4omhaot? t7Yas aYKenter ddmyaddreswov> ?No 3. flWWWIy" )a tkr~ Met t7 6mree Mal O F1 al -1 O Ragan Reoelpt for Men2mrdw 4. OirMlt"I' rs V6e 2. ArtlcleN4mber 7003 3110 0004 5775 4337 ffimnsfer from servloe MW P8 Form 3811, February 2064 Demeeso ANlae now" 1ae642444M Respectfully Submitted: Jan Adams, Esquire I . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?.? t ?-? ?, ?- c„ ' ra ; i _. . r ..? -r -in ?'? ? , .1 ~ ?' , . ? GWEN M. LUKENS, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 04 - 5000 Civil Term JASON E. LUKENS, ACTION IN DIVORCE Defendant ORDER AND NOW, this a 6 day of OPV-4? 2005, in consideration of the within Emergency Petition for Special Relief, a hearing will be held on the q A Day of F'tjolo ? , 2005, in Courtroom No. S of at d : 0do'clock P. M. at the Cumberland County Courthouse, Carlisle, Pennsylvania. 7 cc: 'Jane Adams, Esquire ason Lukens, Defendant J. 1 > o ? a? -c 5 SC :8 0Vll LZ V mfC St"Z cLid it 0 ;- GWEN M. LUKENS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 04 - 5000 Civil Term JASON E. LUKENS, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this February 1, 2005, I, Jane Adams, Esquire, hereby certify that on or about January 31, 2005, a certified true copy of the COURT ORDER Setting a Hearing regarding the Petition for Special Relief was served, via certified mail, return receipt requested, addressed to: Jason Lukens ¦ Complete ftm 1, 2, and 3. Also complete R.D.#4 Box 4419 item 4 M Restricted DOMY Is desired. ¦ Print your name and address on the revamp Duncannon, Pa. 17020 0 Att that thls raarrd to the card back of t the ? ' DEFENDANT or on the front N apace permits. 1. ArWe Addreseed to: 7ason Lukens R . D .#4 - sox 44tq Dvncarmcn, ?A m2o, X r 13 At D ix B. Racdvsd by (PrsrtedNrrrs) c. note of 0.1adeswyeddeweds)sarstronraeml4 urge itYEB, ~ dNpery addl?eee bdw. O No s. ttervbslype cerdssd Mdl 0 Opposes MIX D A is 1 d 0 R lam RaoeIli for Madrdss 14aw O yes 2. ArtlcleN=bw 7003 3110 0004 5775 4368 (dandM eae wrWwYy Ps Form 3911, Febnwy 2004 oaanw pear wroelpt mmmn4m4&UQ .... .__ ................: . Jafi Adants, Esquire T.D. No. 79465 64 outh Pitt Street arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ,._, ?,, - ;. ?=°; `?"? _? ..., ?-; ; :, ?, ., , - . ;{ _ .. '?-? _ - i.:, G1 GWEN M. LUKENS, Plaintiff vs. JASON E. LUKENS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 5000 Civil Term ACTION IN DIVORCE AMENDED AFFIDAVIT OF SERVICE AND NOW, this February 4, 2005, I, Jane Adams, Esquire, hereby certify that on or about January 25, 2005, a certified true copy of the PETITION FOR SPECIAL RELIEF was served, via certified mail, return receipt requested, addresscd to: Jason Lukens SEI DER7 ConIPLFT 1115 SECTI I R.D.#4 Box 4419 ? Duncannon, Pa. 17020 a G6taplat6 kbitis 1,p, dhd 9A J66 66htpl66 . item 4 k RbWLAed beiWary is damirad. A 8W idhlia , M Agerd DEFENDANT ¦ print your name dnd address oft the reyeras 13 Addresses so that we cdn Mum the card to you. 0 Attach this card to the beck of the mdllpiace, a. Rei:eWed hY (Rlnted Name) C. Date of Delivery or on the froht It apace permits, t. Article Addressed toi: D. Is ?dellvery addroas rai(erant ft a item 1? ? Yes . If M. War delivery addrgee below.- ? No ?itsehA Lu kens R- p 4 4 - V. 9 -. ox 44ta f? s tom 67yod Dor1cftntmt PA I'?e2b Acertified Maa 13 Express Mail ? Repisterad C1 Rehlm Receipt for March .,? EI lnsuted MeN :. 13L,o.D. s, AW6. ad Dallvety? (665 Fee) ? Yes 2 Ay"j W' !7?1i 1 je i 7003 3110 0004 5775 4337 ri a a eAhY A 1AW t ral) Hry, 0q" _ j , , I9b!rlj§tla FkW 11"pt 102595.02-M-15401 Ile ectfully S e 4u p._No. tr 65 64 outhPitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ,? ?-_? ..`` ? . GWEN M. LUKENS, Plaintiff V. JASON E. LUKENS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5000 CIVIL TERM ACTION IN DIVORCE ORDER OF COURT AND NOW, this 4th day of February, 2005, after hearing, Plaintiff's Petition For Special Relief is hereby ordered and directed as follows: 1. Plaintiff is given exclusive possession of the Toyota Tacoma pickup truck titled in the joint names of the parties. Provided, however, that the Plaintiff shall be responsible for timely paying all monthly payments and insurance premiums due in connection with said truck. 2. Husband is directed to take whatever steps are necessary so that the agreement of sale for the parties' marital home at 50 South 39th Street, Camp Hill, Cumberland County, Pennsylvania may be closed upon. If husband refuses to cooperate, wife shall have the authority to sign any documentation on his behalf pursuant to this Order. .dane Adams, Esquire Attorney for Plaintiff _.Zason Lukens R.D. #4, Box 4419 Duncannon, PA 17020 srs V? i_ V'' }1 i ?? :r ? ? _, ?', Curtis R. Long Prothonotary OfflCC Of the Protbonotarp Cumberranb Cnuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor O - s pn6 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 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) '7en_Ac'7'7