HomeMy WebLinkAbout14-4072 T IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW _Z
DOUGLAS R. LAWVER, JR. -
Plaintiff Case No.
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KELLY A. LAWVER,
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NOTICE TO DEFEND AND CLAIM RIGHTS cCD
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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
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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.
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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
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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``� , `(,
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vs.
KELLY A. LAWVER, Action in Divorce
Defendant
ACCEPTANCE OF SERVICE
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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