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HomeMy WebLinkAbout06-3675d Barbara'. Supreme 549 Brid New Cui (717)77 JEAN 1 nple-Sullivan, Esquire urt#32317 Street erland, PA 17070 LY'1EK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o(o - J&Z 3D E. LYTER, Defendant CIVIL ACTION - LAW IN DIVORCE &-? (.,`? NOTICE TO DEFEND AND CLAIM RIGHTS OU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth in the f llowing pages, you must take prompt action. You are warned that if you fail to do so the case in y 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, in luding custody and visitation of your children. en the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you in request marriage counseling. A list of marriage counselors is available in the Domestic Relatio s Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAW R'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU NIAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT AVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFIC SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Barbara E Supreme 549 Bridl New Cun nple-Sullivan, Esquire iurt #32317 Street ;rland, PA 17070 JEAN L. LYTER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. ao -jima RICH E. LYTER, : CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE Plaintiff is Jean L. Lyter, an adult individual residing at 331 Fourth Street, New Cumberland County, Pennsylvania 17070. Defendant is Richard E. Lyter, an adult individual residing at 331 Fourth Street, New Cumberland County, Pennsylvania 17070. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of for at least six (6) months prior to filing this complaint. The Plaintiff and Defendant were married on October 25, 1958 in Cumberland Pennsylvania. There are no minor children born of this marriage. There have been no prior actions for divorce or annulment between the parties. Neither Plaintiff nor Defendant is in the military or naval service ofthe United States or its aljies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 ankl its amendments. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT The averments in paragraphs 1 through 8, inclusive, of Plaintiffs Complaint are herein by reference thereto. 0. The marriage is irretrievably broken and no possibility of reconciliation exists. Plaintiff requests entry of a divorce decree in her favor in accordance with § 3301 the Pennsylvania Divorce Code. 1. The averments in paragraphs 1 through 10, inclusive of Plaintiffs Complaint are herein by reference thereto. 2 Plaintiff is the innocent and injured party, and Defendant has offered such indignities to the p4rson of the Plaintiff and has been mentally cruel to her so as to make her life burdensome and he? condition intolerable, in violation of the marriage vows and of the laws of the Plaintiff requests this Court to enter a decree in divorce in accordance with the Divorce Code. COUNT II EQUITABLE DISTRIBUTION herein 11 The averments in paragraphs 1 through 12 of Plaintiffs Complaint are incorporated reference thereto. 4. The Plaintiff requests the Court to equitably divide, distribute or assign the marital between the parties in such proportion as the Court deems just after consideration of all factors. Plaintiff requests this Court to equitably divide said property in accordance with Sgction 401(d) of the Pennsylvania Divorce Code. COUNT III SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY 15. The averments in paragraphs 1 through 14, inclusive, of Plaintiffs Complaint are herein by reference thereto. 3 Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. COUNT IV ATTORNEY'S FEES AND COSTS 7. The averments in paragraphs 1 through 16, inclusive, of Plaintiffs Complaint are herein by reference thereto. 8. Plaintiff is unable to sustain herself during the course of this litigation and has Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and attorney's fees for said counsel, and the necessary and reasonable costs and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and expenses. WHEREFORE, Plaintiff, Jean L. Lyter, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Awarding Plaintiff support, alimony and alimony pendente lite; C. Awarding Plaintiff counsel fees, costs and expenses; D. Equitably distributing the marital property; and 4 Awarding other relief as the Court deems just and reasonable. Dated: _, 2006 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sullivan, Esquire Supreme ourt ourt #32317 549 Bride Street New C berland, PA 17070 JEAN 1. LYTER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. o6 - 3675 Ou;-f T.U.-.. RD E. LYTER, : CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT REGARDING COUNSELING I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors in the Domestic Office, which list is available to me upon request. Being so advised, I do not require that the Court require that my spouse and I in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A 4904 relating to unsworn falsification to authorities. JEf4N L. LYTER a Barbara umple-Sullivan, Esquire Supreme ourt #32317 549 Brid a Street New C berland, PA 17070 (717)77 -1445 JEAN . LYTER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. RD E. LYTER, : CIVIL ACTION -LAW Defendant : IN DIVORCE VERIFICATION Jean L. Lyter, hereby certify that the facts set forth in the foregoing COMPLAINT IN are true and correct to the best of my knowledge, information and belief. I understand that ant false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to uns*orn falsification to authorities. 2006 a® - z.t AN L. LYTER CJ ?? ? ? c Q c ? ?> -? .p .,J C _ ? i -n pp ?, ?' W ? r --, ??? cn r„? ? .? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEAN L. LYTER, : IN THE COURT OF COMMON PLEAS Plaintiff V. RICHARD E. LYTER, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3675 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7003 0500 0001 6561 3054, Return Receipt Requested, on the above-named Defendant, Richard E. Lyter, on June 29, 2006 at Defendant's last known address: 331 Fourth Street, New Cumberland, PA 17070. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: July 11, 2006 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff -T, Ut:RTIFIED I MAIL R ECEIPT L, C3 (DOMeStiC Mail Only , No Insuranc e COverage Provided) I r apt Ln `D Postage 1 $ &n (z o CertifiedFee f2.40 r 070 JGy v z O C3 ReWm Reciapt Fee (Endorsement Required) $1.85 arl, CI ?• \ ere b O li ! D R t i t p e very Fee es r c ed (EndommereRequired) $3.70 f), - 0-0999 C3 Total Postage & Fees $ $8.58 06/2812006 m -? M Sent To -- .Plf........... aPOBax Ab. -31.----Wur?t?:,_rs,e.------ ---- - ---- - - PA ¦. Cereph% Neste 1, 2, and.3.. Also complete IMn 4 N PAWkftd Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. I Apach this cad to the back of the mallpkce, or on the front R apace permits 1. Ardole Addressed ft 3 31 ??? C.k?orlo,PAk TzAb A. Agem B. Rabelved by (Printed NYlrt* I C. Date of Delmy D. kt d*MY address dRerem from earn 17 0 Yes If YES, amen delivery address bsbw: 0 No 3. Service Type 13 Ceraeed Mall 13 Bwm Mall 13 Rsalntered 13 Retum Recelptfor Merdwrawe O kqumd Mal 13 C.O.D. .' 2. MoBN10t'0ef 7003 0500 0001 6561 3054 monfor apm "I mw PB Form 3811, Febnery 2004 oanweao Roar Race" 1009e542-WISO EXHIBIT "A" USP$ - Track & Confirm a _ e Track & Confirm Search Results Label/Receipt Number: 7003 0500 0001 5561 3054 Status: Delivered Your item was delivered at 8:52 am on June 29, 2006 in NEW CUMBERLAND, PA 17070. Additlp/a! @eeeNSS Rarase ea Y/11??4'0iY Nsmr?a Notification Options; Page 1 of 1 Home I Help Track& Confirm Enter Label/Receipt Number. Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Go s) ® POSTAL INSPECTORS site map contact us government services jobs National & Premier Accounts Preservinq the Trust Copyright ©1999.2004 USPS. All Rights Reserved. Terms of Use Privacy Policy http://trkcnfrm 1-smi.usps.com/PTSinternetWeb/interLabelinquiry.do 7/6/2006 n w c- ,? - C ? _ ; r N 'v 3 N J N V Curtis R. Long Prothonotary office of the Protbonotarp Cumberiaub QCountp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ?DL '3L / CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573