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HomeMy WebLinkAbout14-4072 T IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW _Z DOUGLAS R. LAWVER, JR. - Plaintiff Case No. C") CD VS. � c a MU) KELLY A. LAWVER, Action in Divorce M C= a Defendant r– — _­3 C,-; �> — o —I CD 7—,_ NOTICE TO DEFEND AND CLAIM RIGHTS cCD ,r T; mss_ 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 at the Adams County Courthouse, Gettysburg, Pennsylvania. 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. COURT ADMINISTRATOR Adams County Courthouse Gettysburg, Pennsylvania 17325 (717) 337-9846 ENTWISTLE & BE By: k I Hea h r Entwistle Roberts, Esquire Q � pdIt1� Attorney for Plaintiff 7 �� 3084a 3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW DOUGLAS R. LAWVER, JR. Plaintiff Case No. VS. KELLY A. LAWVER, Action in Divorce Defendant COMPLAINT IN DIVORCE 1. Plaintiff is DOUGLAS R. LAWVER, JR, whose current address is 1079 Ridge Road, Gettysburg, Adams County, Pennsylvania 17325. 2. Defendant is KELLY A. LAWVER, whose current address is 962 Long Lane, Gettysburg, Adams County, Pennsylvania 17325. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 13, 2001, in Ocean City, Maryland. 5. There have been no prior actions in divorce or for annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. v 7. Plaintiff avers that he has been advised of the availability of counseling and he is aware that he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests that a Decree of Divorce be granted. Respectfully submitted, ENTWISTLE & ROBERTS By: ather Entwistle Roberts, Esquire Attorney for Plaintiff 37 West Middle Street Gettysburg, PA 17325 (717) 334-6761 (717) 334-7447 hroberts@entwistleroberts.net Supreme Court I.D. No. 209230 r VERIFICATION STATEMENT I verify that the statements made in the foregoing document is true and correct to the best of my personal 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. Date: DOUGLA9 R. LAMER, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW DOUGLAS R. LAWVER, JR. Plaintiff Case No. i``� , `(, `-t"" `�v� a vs. KELLY A. LAWVER, Action in Divorce Defendant ACCEPTANCE OF SERVICE OC inr I, Christina M. Simpson, attorney for Defendant, Kelly A. Lawyer, in the above -captioned action, do acknowledge that I have received a true and attested copy of the Complaint in Divorce and Notice to Defend and Claim Rights filed July 11, 2014, in the above -captioned matter. I certify that I am authorized to accept service on behalf of the Defendant, Kelly A. Lawyer. Date: 7 - zq / K" Christina M. Simpson, Esquire Attorney for Defendant