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Home My WebLink About05-0159KEITH JACOBS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : · V. : CIVIL ACTION - LAW : MONICA LYNN JACOBS : 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 wamed 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 of 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. 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 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 or (717) 249-3166 KEITH JACOBS, Plaintiff MONICA LYNN JACOBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT DIVORCE UNDER SECTION 3301(c) and (d) OF THE DIVORCE CODE AND NOW COMES Plaintiff, Keith Jacobs, by his attorney, Jay R. Braderman, Esquire, and respectfully represents as follows: 1. Plaintiff, Keith Jacobs, is an adult individual residing at 885 Acre Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant, Monica Lynn Jacobs, is an adult individual residing at 885 Acre Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 2, 1992 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no children bom of this marriage. 6. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). After ninety (90) The marriage of the parties is irretrievably broken. days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301 (d). The marriage of the parties is irretrievably broken. The date of separation was on or about December 1, 2004. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a Decree in Divorce from the bonds of matrimony. COUNT I EQUITABLE DISTRIBUTION UNDER SECTION 3502 OF THE DIVORCE CODE 9. Paragraphs 1 through 8 of this Complaint are incorporated herein by reference as though set forth in full. 10. Plaintiff and Defendant have acquired property, both real and personal during their marriage from October 2, 1992 to date. 11. 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. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order of equitable distribution of marital property and marital debts. Date: /1~/8/)~/~ Respectfully Submitted, 126 ~ocust Street P. (J. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney For Plaintiff KEITH JACOBS Vo Plaintiff MONICA LYNN JACOBS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - LAW : : IN DIVORCE : : AFFIDAVIT KEITH JACOBS, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that the Court maintains a list of marriage counselors in the I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4909 relating to unsworn falsification to authorities. VERIFICATION Upon my personal knowledge or information and belief, I hereby verify that the facts averred in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein made are subject to the criminal penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. I verify that I have reviewed this form with my client and to the best of my knowledge the allegations herein are true and correct. Date: ~~7 ~quire /1/26 Locust Street 'P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attomey For Plaintiff KEITH JACOBS, Plaintiff v. MONICA LYNN JACOBS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-159 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE Please mark the within divorce case as terminated, settled and withdrawn. Date: -4- ~\ \06 n~d (~. ~o-~~c~ i\ ~an, Esquire IrD; Id. No. 07047 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney for Plaintiff, Keith Jacobs --q Pi C...) I -",-' !>.)