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Home My WebLink About05-6245VICTORIA L. COLYOTT-LAUER, Plaintiff VS. DENNIS J. LAUER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 2005- 6d YS CIVIL TERM IN DIVORCE 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 will proceed without you and a decree in divorce or annulment may 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 or 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 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 S. Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 VICTORIA L. COLYOTT-LAUER,: Plaintiff V. DENNIS J. LAUER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005- &2 Y5' CIVIL IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Victoria L. Colyott-Lauer, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following: Plaintiff is Victoria L. Colyott-Lauer, an adult individual, currently residing at 1230 Timber View Drive, Mechancisburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Dennis J. Lauer, an adult individual, currently residing at 488 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on December 23, 1980 in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, cqu ne A Verney, Esquire Supreme Ct. ID. 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing divorce complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. ..,tee I ar?? Date Vti,-- Victoria L. Colyol?tt-Lauer, Plaintiff \'`1 ,, _? ? '? ?a ? ' c ? , ? ? ? ?? --e? ? ? .. _ _ _: } ?° VICTORIA L. COLYOTT-LAUER: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2005-6245 CIVIL ACTION - LAW DENNIS J. LAUER, Defendant IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa RCP 1930.4 (c) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS I, Jacqueline M. Verney, Esquire, being duly sworn according to law, deposes and says that she is the attorney for plaintiff, Victoria L. Colyott-:Lauer, and that she did serve a true and correct copy of the divorce Complaint that was filed in the above matter, by U.S. mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the defendant, Dennis J. Lauer, on December 8, 2005. The receipt form is attached hereto as EXHIBIT "A". l,Jacq ine M. Vemey, Esquire #2 67 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff Sworn to and subscribed before me this day of bL-Ek yy k1J CJ 12005. i ktkt- Notary Public G C?pyMpion Bou t 9, ? A. 0 bent B. Recelved by (Printed Name) C. Date of Delivery D. Is dIm from Item 17 0 Yes If Yer deliverya '^Fe'I°uva°L7'-Mo 0?-81!005 3. ServIce Tye /L / •/`GS n u?6r D? 0?enfned Mail 13 Express Mail ? Registered ? Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 7U SJ 4. Restricted Delivery? (Etta Fee) Yes z.M 7003 1010 0001 1198 2752 ansfer ft m s erNCe label) (Ilensl PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addre59ed to: ? ?N s ? GA-u E,e Z/$? S I on/? ? t-?15 ?- C>a-r EXHIBIT "A" r, C, c Curtis R. Long Prothonotary ®ffire of the i9rotbonotarp Cumberfantl Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor S - L24CIVIL 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 RCP230.2 BY THE COURT, CURTIS R. LONG .PROTHONOTARY /1 _ I`1 _-_?6-'_-- n-"---- /?__1T_1. T_ _---'?-'--''' 1'7^In - I^.."'.\ .1... i. - ? - - . - w... ,-