HomeMy WebLinkAbout02-1764OWEN D. HIGHAM,
Plaintiff
V.
LAURIE A. HIGHAM,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002- !'7~' t./ CIVIL TERM
CIVIL ACTION-LAW
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
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 Cumberland County Court House, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONy MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO
NOT HAVE AN ATTORNEY 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
OWEN D. HIGHAM, :
Plaintiff :
:
V. :
LAURIE A. HIGHAM, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2002- I~(_Ol{ CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(C) AND
3301(D) OF THE DIVORCE CODE
1. Plaintiff is Owen D. Higham, an adult individual who currently resides at 22
Courtland Road, Camp Hill, Cumberland County, Pennsylvania.
2. Defendant is Laurie A. Higham, an adult individual who currently resides at 13
Walnut Street, Shiremanstown, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on September 23, 1989, in Cumberland
County, Pennsylvania.
COUNT I - DIVORCE
5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above.
6. There have been no prior actions of divorce or for annulment between the parties
as to their current marriage.
7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States.
8. Plaintiff avers that the marriage between the parties is irretrievably broken.
9. The Plaintiff has been advised of the availability of counseling and that he may
have the right to request that the court require the parties to participate in counseling.
divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in
DATE:
COUNT II -EQUITABLE DISTRIBUTION
10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above.
11. The parties have acquired personal property, including automobiles, bank
accounts and other items of miscellaneous property during the course of their marriage, some of
which is marital property.
WHEREFORE, Plaintiffrespectfully requests this Honorable Court to enter a decree
which effects an equitable distribution of marital property.
Respectfully submitted,
O'BRIEN, BARIC & SCHE~I~
David A. Baric, Esquire
I.D. # 44853
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
dab.dir/domestic/higham/complaint, pld
VERIFICATION
I verify that the statements made in the foregoing 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.
bwen D.~ham
DATED: