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HomeMy WebLinkAbout06-6457JAMES R. LEWIS, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 66- (o ys?7 CIVIL TERM DENISE E. LEWIS, Defendant 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 (717) 249-3166 SNELBAKER & BRENNEMAN, P.C. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. By: ' Attorneys for Plaintiff JAMES R. LEWIS, JR., Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 66- WS7 CIVIL TERM DENISE E. LEWIS, Defendant CIVIL ACTION -LAW IN DIVORCE COMPLAINT COUNT I - DIVORCE 1. Plaintiff James R. Lewis, Jr. is an adult individual residing at 213 Railroad Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Denise E. Lewis is an adult individual residing at 213 Railroad Avenue, I Mechanicsburg, Cumberland County, Pennsylvania. 3. Both 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 lawfully joined in marriage on September 27, 1980 in Cumberland County, Pennsylvania. 5. The prior action in divorce initiated by Plaintiff and docketed to number 2001-0358, Cumberland County was purged due to inactivity. 6. Neither party is a member of the armed forces of the United States of America. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to-request that the Court require the parties to participate in counseling. LAW OFFICES 9. The Plaintiff requests this Court to enter to enter a decree of divorce. SNELBAKER & BRENNEMAN, P.C. WHEREFORE, Plaintiff James R. Lewis, Jr. requests this Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. COUNT I1- EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9, inclusive, of this Complaint are incorporated by reference herein. 11. The Plaintiff and Defendant have legally and beneficially acquired various property and assets since the date of their marriage on September 27, 1980. 12. The Plaintiff and Defendant have not agreed as to any equitable distribution of the marital property and assets. WHEREFORE, Plaintiff James R. Lewis, Jr. requests this Court to order equitable distributirn of the parties' marital property. WHEREFORE, the Plaintiff requests this Court to: (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony; (b) order equitable distribution of marital property; and (c) order such other relief as this Court deems just and reasonable. SNELBAKER & BRENNEMAN, P.C. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. By: Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Date: November 6, 2006 Attorneys for Plaintiff James R. Lewis, Jr. -2- 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. Section 4904 relating to unsworn falsification to authorities. s R. Le r. Date: November 6, 2006 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. JAMES R. LEWIS, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 CIVIL TERM DENISE E. LEWIS, Defendant CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT JAMES R. LEWIS, JR., being duly sworn according to law, deposes and says: I . 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. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate 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. § 4904 relating to unsworn falsification to authorities. James R. Le s, Jr. (Plaintiff) November 6, 2006 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. \ h ` o ? am Q O C C7 r?.? -rt Owl 1.0 Curtis R. Long Prothonotary Office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor OL -1, L1.5 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