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Home My WebLink About05-6002 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUBEN LEMUS, v. Defendant CIVIL ACTION - LAW NO. OS - va:>.;.! CIVIL TERM IN DIVORCE SUSAN LEMUS, You haye been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION 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, P A 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA RUBEN LEMUS, v. Defendant CIVIL ACTION - LAW NO. 05 - (~00.2../ CIVIL TERM IN DIVORCE SUSAN LEMUS, COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Ruben Lemus, an adult indiyidual, who resides at 2470 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Susan Lemus, an adult individual, who resides at 2470 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 13, 1996 in Allentown, Lehigh County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiffrequests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE II/t(D~ Mark F. Bayley, Es . 155 S. Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court J.D. # 87663 Attorney for Plaintiff Date: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA RUBEN LEMUS, v. Defendant CIVIL ACTION - LAW NO. 05 - CIVIL TERM IN DIVORCE SUSAN LEMUS, 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. Date: /I~ c i - 0 S-- ~~ Ruben Lemus, Plaintiff ~ - ..>,.J Q ~. .L' -'\ ;>-:> :..,...l - - ~ ""'" "". _. ......s> C> v, " --0 :s:.- '(jJ ? -...;: ~ l--:I S_-, r' g ....' ~ C;.-::r c...., -:;::~ C,\ ~ -::? \--'\'1 r....' - ~~'" " . ~'," .- - . , ::,~ :~ h -"') .-- <,' ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUBEN LEMUS, v. Defendant CIVIL ACTION - LAW NO. 05 - 6002 CIVIL TERM IN DIVORCE SUE LEMUS, You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations ayailable to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA RUBEN LEMUS, v. Defendant CIVIL ACTION - LAW NO. 05 - 6002 CIVIL TERM IN DIVORCE SUE LEMUS, AMENDED COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Ruben Lemus, an adult individual, who resides at 2470 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Sue Lemus, an adult individual, who resides at 2470 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately preyious to filing of this Complaint. 4. Plaintiff and Defendant were married on September 13, 1995 in Allentown, Lehigh County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE D", I/~ ~ ( Il /1 ( k'; B.~,,!J-- 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court J.D. # 87663 Attorney for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COI1NTY , PENNSYLVANIA RUBEN LEMUS, v. Defendant CIVIL ACTION - LAW NO. 05 - 6002 CIVIL TERM IN DIVORCE SUE LEMUS. VERIFICATION I yerify 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. S4904, relating to unsworn falsification to authorities. Date: l{ ---- 70 ~ 0) ~~ Ruben Lemus. Plaintiff '" c..) (,) ,.~ -il "_d _I (,,) p.,) RUBEN LEMUS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Defendant CIVIL ACTION - LAW NO. 05 - 6002 CIVIL TERM IN DIVORCE SUE LEMUS, ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Sue Lemus, in the above-captioned action and I certify that I am authorized to do so. ~1,9. - I D. -O~) Date BY: J ) AU ,(=/.. JUY\)J.f\ Sue Lemus, Defendant C~ (:.:: .--' ...."~"::> c;=-"J. c::i-' ..,.. ~~, ~, N <>) c> :~ (:) -n ,-,\ ~:c -\1 fnr::: ~,~~(i.: .';~), 1,':...) -Q " ;:5/..', ?;~ ~j'1'1 ~.~ E:. :::< - .. .-;..- UJ RUBEN LEMUS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. SUE LEMUS, DEFENDANT CIVIL ACTION - LAW NO. 05-6002 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Diyorce under S330I(c) of the Diyorce Code was filed on November 21, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. g4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ::.:.]1- 0 J - 0 ~ Date ~~~) Ruben Lemus r--' <~.~) ('~:-:) c:... -r. "2];; t"--' vJ ~.-:.::, C) -n ,_1 ~~1~;J. .0"' ~.d '._ , , , \~,; - ..... w - ----- RUBEN LEMUS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. SUE LEMUS, DEFENDANT CIVIL ACTION - LAW NO. 05-6002 CIVIL IN DIVORCE WAIVER OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER & 330I(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a diyorce is grantl~d. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 2 S - 0") - 00 Date fjl;c-~ Ruben Lemus ~:; ~~ '31, -. ;,~-... :';0 ,,1 vO -- Ar;:,.-- "p .--------- RUBEN LEMUS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. SUE LEMUS, DEFENDANT CIVIL ACTION - LAW NO. 05-6002 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Diyorce under 9330I(c) of the Diyorce Code was filed on Noyember 21, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing ofthe Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. 3- ~~-Oc." Date .~ML~ Sue Lemus o c t") ;;;.1 ,,- - ~:~;;. :;'j ('.) t.;:! - .~ .. ".'." ...c - RUBEN LEMUS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. SUE LEMUS, DEFENDANT CIVIL ACTION - LAW NO. 05-6002 CIVIL IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, diyision of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be diyorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. g4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. <3-~ ;<.3~ OlD Date ct A L ~)'V-.A8-. SueLemus (") c " ,..0 '~~'~ (:.."" C') ..., -~. ~..--,~ -'.',';" ;';(,j ['oJ 0' t,J.') - RUBEN LEMUS, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. SUE LEMUS, DEFENDANT CIVIL ACTION - LAW NO. 05-6002 CIVIL IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to th(, Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under 9 3301(c) of the Divorce Code. 2. Date and manner of service of the Amended Complaint: December 1. 2005 and was served on Defendant by First Class Mail and Acceptance of Service was signed on December 12, 2005 (copy attached). 3. Date of execution of the affidayit of consent required by 9 3301 (c) or The Divorce Code: by the Plaintiff March 23, 2006; by the Defendant March 23,2006. 4. Related claims pending: None 5. (b) Date Plaintiffs Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: on March 23, 2006; Date Defendant's Waiyer of Notice in 9330I(c) Divorce was filed with the Prothonotary: on March 23, 2006; a copy of which is attached. Date: March 23, 2006 IRWI~ & ~AYL~? By ~~ ~ Mark F. Bayley, Esquire 64 South Pitt Street 717) 241-6070 Supreme Court LD. # 87663 Attorney for Plaintiff ('~} --if -"'" .--/ :!;::~n -.,,-1,:';f. . :;;"':] ,--- i'') C" C') w ~~~~~~~~~~~~~~~~~~~~~~~~~~+~+~+~~~~~~~++~~~+~~+~~+~++~++~+~+~~++~+~+~+~+~+~++~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + ~~+~~~~~~+~+~~+~+~+~++++~~++~++~+~+~+~++~+~+~~++~+++++++++++++++++++~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +~+++~~++ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Ruben Lemus Plaintiff VERSUS ~llP T.pmllo:::. npfpnn~nt- AND NOW, DECREED THAT AND . PENNA. NO. 6002 2005 DECREE IN DIVORCE c:J;- 3:4t1,.~ . JOO~. IT IS ORDERED AND f'It~ ).,31 Ruben Lemus , PLAINTIFF, SHe Lemns , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT Wono / ATTEST: ROTHONOTARY J. *;7 /p:'i/ 0/71, 90 -}:C' . f:' fr;t;f? fr f- /~ /dP? ../0/ /j02L'. L . ~ ...' . ".. ..~ ,.. . . ---------