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HomeMy WebLinkAbout06-6669OW *% J1.60- ?Oarl Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA dA& vfl? Defendant • NO. 06- G (, t. / CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOUHAVE BEENSUED 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 -A 10% k(la La6/ Plaintiff v. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : No. 06-6t(, 9C1VIL TERM : IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is 1-15 A , f JAN LUCA S who currently resides at I ?`? ? s ??e, AJrY GA?.o?l? ?' • ? ,C'??t aS(s " , PA f 7Ui Cumberland County, Pennsylvania. 2. Defendant is wA GT E -- fe y ? who currently resides at I)r1?1(1c?1,)I/? 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on _ 10 ( J - S J at 5. The marriage is irretrievably broken, and the parties separated on KA /q (?_ 0 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in paragraph 2 above. ..^ ., *"S 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plaiv(iff, -Pro Se I, L I S r N LUCA S , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. 2_0 0 4> -- Date: Plai iff, Pro Se Assisted by: Jennifer L. Spears, Esquire Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, Pennsylvania 17013 (717) 243-3341 i , _? C ?? ?+ ..?'? T. 7 __> _ ? ? J. °" ?J `? :` -,. USA Joan l uccS Plaintiff V. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06- L L G 9 CIVIL TERM : DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Lisa J. Lucas , Plaintiff, to proceed in forma au eris. I, Jennifer L. Spears, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. ///4 'Je ifer L. Spears, Esquire A tomey for Plaintiff 10 E. High Street Carlisle, PA 17013 (717) 243-3341 ACA ?? ?,.s (" :`, ? _ _< ?) <?a ; +?i ' T? -r, `' a n_? ,?'? ,; _ - t..; . , y_ .. - _ ?. f "4.. _? _ oan , Plaintiff •/ V. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 06- 6 GQ CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on /D and cont inued to live separate and apart for a period of t2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. I, !?-?? 70A? t , verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. Date Vlailnfi, Se F:\FILES\DATAFILE\General\Cuc ent\5492.73 Created: 9/20/04 0:06PM Revised: ]111107 2:OOPM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff LISA JOAN LUCAS, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA WALTER RAY LUCAS, JR., Defendant NO. 06-6669 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the Divorce Complaint filed in this matter on November 20, 2006. MARTS EARDORFF WILLLAMS & OTTO By Jonnif L pears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: January 11, 2007 Attorneys for Plaintiff rs Un ' ' rv O > " c c r n LISA JOAN LUCAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-6669 CIVIL TERM WALTER RAY LUCAS, JR., CIVIL ACTION-LAW Defendant IN DIVORCE PRAECIPE FOR WITHDRAWAL OF COUNSEL AND APPEARANCE OF COUNSEL TO THE PROTHONOTARY: Please note my withdrawal as counsel for Lisa Joan Lucas, Plaintiff in the above matter. MARTSON LAW OFFICE Dated: Jas BY: Jennifer . Sp , E uire 10 Eas igh eet Carlisle, Pennsylvania 17013 (717) 243-3341 Kindly enter our appearance on behalf of Lisa Joan Lucas, Plaintiff in the above matter. Dated: 2 "2'9 ' " O'BRIEN, BARIC AND SCHERER BY: Michael A. Scherer, Esquire Pa I . D.: 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff mas.dirldomestic/lucas/withdraw-entry.pra (,j, >1 €o - LISA J. LUCAS, Plaintiff/Petitioner V. WALTER R. LUCAS, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 6669 CIVIL TERM CIVIL ACTION -LAW : IN DIVORCE PETITION FOR SPECIAL ORDER OF COURT 1. Petitioner is Lisa J. Lucas, represented by her attorneys, O'BRIEN, BARIC & SCHERER. 2. Respondent is Walter R. Lucas and to Petitioner's knowledge and belief, Respondent is unrepresented in this divorce matter. 3. Petitioner and Respondent were married in Eureka Springs, Arizona on October 19, 1999. 4. On March 11, 2004, the Parties separated when Respondent was sentenced to work release in Dauphin County, Pennsylvania. Thereafter, Petitioner neither saw nor heard from Respondent. 5. Petitioner filed for divorce from Respondent on November 11, 2006 in this County's Courthouse. Petitioner filed for divorce only; there are no economic claims. 6. According to Petitioner's knowledge, information and belief, Respondent was incarcerated in the Palm Beach County Detention Center on or about August 27, 2006. 7. Respondent's incarceration was confirmed by phone calls by Petitioner's counsel to the Palm Beach County Sheriff's Office and the Palm Beach County Detention Center. 8. Respondent's incarceration was also confirmed by the Palm Beach County Sheriff s Office Booking Blotter, an on-line database that provides the public with access to prisoner records. 9. According to Petitioner's knowledge, information and belief, Respondent was released from the Palm Beach County Jail on March 1, 2007. The release and date were confirmed by a phone call by Petitioner's counsel to the Palm Beach County Sheriff s Office. 10. Petitioner and Petitioner's counsel have searched extensively for the current whereabouts of Respondent since being released from the Palm Beach County Jail in Florida.. 11. Petitioner's counsel has made numerous attempts to locate Respondent without success, including phone calls to the following offices: a. Palm Beach County District Attorney's Office; b. Palm Beach County Clerk's Office; c. Palm Beach County Sheriff's Office; d. Palm Beach County Detention Center; e. Palm Beach County Innate Records; and f. Palm Beach County Post Office. 12. Petitioner's counsel attempted to locate Respondent's parole officer; however, Petitioner's counsel was informed by the Palm Beach County Clerk's Office that Respondent does not have a parole officer and is no longer on probation. 13. Petitioner's counsel attempted for find a forwarding address for the Respondent from the United State Postal Office in Palm Beach County. All attempts made by the U.S. Postal Office were unsuccessful. 14. Petitioner has contacted Respondent's only living relative, Margaret Byrd, who resides at 7393 Kopp Road, Spring Grove, Pennsylvania 17362. Ms. Byrd's is the Respondent's sister and confirmed that she is Respondent's only living relative. Ms. Byrd's last contact with the Respondent was made over a year ago. She does not have any knowledge of Respondent's whereabouts. All of Respondent's family, including his mother and father, are deceased or their whereabouts are unknown to sister, Margaret Byrd. 15. To Petitioner's knowledge, information and belief, Respondent has never, at any O'BRIEN BARIC & SCHERER time, held or applied for a driver's license in Pennsylvania or elsewhere. WHEREFORE, Petitioner respectfully requests that this Honorable Court grant Petitioner's request for special relief regarding service in this matter and order Petitioner to effectuate service by publishing notice once in this county's Cumberland Law Journal as attached hereto and made part of and marked as Exhibit "A." Petitioner further requests that this Court relieve Petitioner of the duty to provide a Counter-Affidavit to Respondent as well as a Notice of Intention to Request Entry of Divorce Decree to Respondent. Respectfully submitted, Robert J Attorney for Petitioner Date: !r of July, 2007 I.D. 203418 19 West South Street Carlisle, Pennsylvania 17013 Phone: (717) 249-6873 LISA J. LUCAS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - 6669 CIVIL TERM WALTER R. LUCAS, CIVIL ACTION -LAW Defendant/Respondent IN DIVORCE VERIFICATION I, Lisa J. Lucas, verify that the statements made in the foregoing Petition for Special Order of Court are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities. Lisa J. Lucas i Date: ? of July, 2007 EXHIBIT "A" In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Term No. 06-6669 LISA J. LUCAS V. WALTER R. LUCAS IN DIVORCE TO: WALTER R. LUCAS YOU HAVE BEEN SUED IN COURT. The Plaintiff, Lisa J. Lucas, by her attorneys, O'BRIEN, BARIC & SCHERER, has filed a Divorce Complaint under §3301 (c) or (d) of the Divorce Code. If you wish to defend against this claim, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, this case may proceed without you and a divorce may be entered against you by the Court. You may lose property or other rights important to you. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION 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 (717) 249-3166 ?.? C ? ?-' ?._-> ? 'Tl _._? ? _ f.r_ `- T _ (.1? ^J -: ?,) t ? :;- -^") ? _1 . ?. F' i t l-'-? _- - s LISA J. LUCAS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF/PETITIONER CUMBERLAND COUNTY, PENNSYLVANIA V. WALTER R. LUCAS, DEFENDANT/RESPONDENT 06-6669 CIVIL TERM ORDER OF COURT AND NOW, this _ 2-7? day of July, 2007, IT IS ORDERED that petitioner may obtain service of this divorce complaint by publishing notice one time in the York County Legal Journal and a newspaper of general circulation in Palm Beach County, Florida, and by notification to defendant's sister Margaret Byrd of 7393 Kopp Road, Spring Grove, Pennsylvania. By the Edgar B. Bayley, J. Robert J. Dailey Esquire For Petitioner sal J ?-_ - .,y_, _..!, r ?? ?' j..? ` ?i "? i t. Et ?_ ?? _? cw.: (a,l LISA J. LUCAS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - 6669 CIVIL TERM WALTER R. LUCAS, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT UNDER 4 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on March 11, 2004 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 4. Because no appearance has been entered on Defendant's behalf and because the Defendant was unable to be located after diligent search, this Court required service by publication in an Order dated July 25, 2007. 5. As a result, Defendant was not served a counter-affidavit in this matter. I verify that the statements made in this affidavit 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: of 2007 L Lisa ///Lucas, Plaintiff LISA J. LUCAS, Plaintiff V. WALTER R. LUCAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006 - 6669 CIVIL TERM CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(d) 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 if I do not claim them before a divorce is granted. 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. 4. Because no appearance has been entered on Defendant's behalf and because the Defendant was unable to be located after diligent search, this Court required service by publication in an Order dated July 25, 2007. 5. As a result, notice upon Defendant is impossible and waiver of that notice is unnecessary. I verify that the statements made in this affidavit 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: of 2007 isa J. Lucas, Plaintiff ?? ?; t-??•s ' t i t. ?? ? "` 6 ?a`.i i ? ? 1:. . r ,, ??, t?:? ? " LISA J. LUCAS, Plaintiff V. WALTER R. LUCAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006 - 6669 CIVIL TERM : CIVIL ACTION -LAW : IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD TO: The Prothonotary of Cumberland County, Pennsylvania Please transmit the record, together with the following information, to the court for entry of a divorce decree. 1. Ground for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: By Order of Court dated July 25, 2007, the Honorable Edgar Bayley ordered service by publication. Said Order is attached hereto and marked as Exhibit "A." Service by publication in the York County Legal Journal was effectuated on September 27, 2007 and is attached hereto and marked as Exhibit "B." Service by publication in a newspaper of general circulation in Palm Beach County, Florida was effectuated on September 26, 2007 and is attached hereto and marked as Exhibit "C." Service upon Defendant's sister, Margaret Byrd was effectuated on September 28, 2007 and a signed Acceptance of Service form is attached hereto and marked as Exhibit "D." 3b(1). Date of execution of the affidavit required by § 3301(d) of the Divorce Code: October 29, 2007. 3b(2). Date of filing and service of the Plaintiffs affidavit upon the Defendant: Service not required per Order of Court dated July 25, 2007 and due to Plaintiffs inability, despite diligent search, to locate Defendant. 4. Related claims pending: None. 5. Neither the Notice of Intention nor the Waiver of Notice was filed by Defendant because he was, after a diligent search, unable to be located. Plaintiff filed her Waiver of Notice with the prothonotary on November 2007. -to , .A Date: day of November 2007 O'BRIEN, BARIC & SCHERER 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff EXHIBIT "A" LISA J. LUCAS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF/PETITIONER CUMBERLAND COUNTY, PENNSYLVANIA V. WALTER R. LUCAS, DEFENDANT/RESPONDENT 06-6669 CIVIL TERM ORDER OF COURT AND NOW, this _ day of July, 2007, IT IS ORDERED that petitioner may obtain service of this divorce complaint by publishing notice one time in the York County Legal Journal and a newspaper of general circulation in Palm Beach County, Florida, and by notification to defendant's sister Margaret Byrd of 7393 Kopp Road, Spring Grove, Pennsylvania. By the Couff Edgar B. Bayley, J. Robert J. Dailey, Esquire For Petitioner :sal F-7 150 0 07 LISA J. LUCAS, Plaintiff/Petitioner V. WALTER R. LUCAS, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 6669 CIVIL TERM : CIVIL ACTION -LAW : IN DIVORCE PETITION FOR SPECIAL ORDER OF COURT 1. Petitioner is Lisa J. Lucas, represented by her attorneys, O'BRIEN, BARIC & SCHERER. 2. Respondent is Walter R. Lucas and to Petitioner's knowledge and belief, Respondent is unrepresented in this divorce matter. 3. Petitioner and Respondent were married in Eureka Springs, Arizona on October 19, 1999. 4. On March 11, 2004, the Parties separated when Respondent was sentenced to work release in Dauphin County, Pennsylvania. Thereafter, Petitioner neither saw nor heard from Respondent. 5. Petitioner filed for divorce from Respondent on November 11, 2006 in this County's Courthouse. Petitioner filed for divorce only; there are no economic claims. 6. According to Petitioner's knowledge, information and belief, Respondent was incarcerated in the Palm Beach County Detention Center on or about August 27, 2006. 7. Respondent's incarceration was confirmed by phone calls by Petitioner's counsel to the Palm Beach County Sheriff s Office and the Palm Beach County Detention Center. 8. Respondent's incarceration was also confirmed by the Palm Beach County Sheriff s Office Booking Blotter, an on-line database that provides the public with access to prisoner records. 9. According to Petitioner's knowledge, information and belief, Respondent was released from the Palm Beach County Jail on March 1, 2007. The release and date were confirmed by a phone call by Petitioner's counsel to the Palm Beach County Sheriffs Office. 10. Petitioner and Petitioner's counsel have searched extensively for the current whereabouts of Respondent since being released from the Palm Beach County Jail in Florida.. 11. Petitioner's counsel has made numerous attempts to locate Respondent without success, including phone calls to the following offices: a. Palm Beach County District Attorney's Office; b. Palm Beach County Clerk's Office; C. Palm Beach County Sheriff's Office; d. Palm Beach County Detention Center; e. Palm Beach County Inmate Records; and f. Palm Beach County Post Office. 12. Petitioner's counsel attempted to locate Respondent's parole officer; however, Petitioner's counsel was informed by the Palm Beach County Clerk's Office that Respondent does not have a parole officer and is no longer on probation. 13. Petitioner's counsel attempted for find a forwarding address for the Respondent from the United State Postal Office in Palm Beach County. All attempts made by the U.S. Postal Office were unsuccessful. 14. Petitioner has contacted Respondent's only living relative, Margaret Byrd, who resides at 7393 Kopp Road, Spring Grove, Pennsylvania 17362. Ms. Byrd's is the Respondent's sister and confirmed that she is Respondent's only living relative. Ms. Byrd's last contact with the Respondent was made over a year ago. She does not have any knowledge of Respondent's whereabouts. All of Respondent's family, including his mother and father, are deceased or their whereabouts are unknown to sister, Margaret Byrd. 15. To Petitioner's knowledge, information and belief, Respondent has never, at any time, held or applied for a driver's license in Pennsylvania or elsewhere. WHEREFORE, Petitioner respectfully requests that this Honorable Court grant Petitioner's request for special relief regarding service in this matter and order Petitioner to effectuate service by publishing notice once in this county's Cumberland Law Journal as attached hereto and made part of and marked as Exhibit "A." Petitioner further requests that this Court relieve Petitioner of the duty to provide a Counter-Affidavit to Respondent as well as a Notice of Intention to Request Entry of Divorce Decree to Respondent. Respectfully submitted, Robert J. Dailey, Esq? I.D. 203418 19 West South Street Carlisle, Pennsylvania 17013 Phone: (717) 249-6873 Attorney for Petitioner Date: of July, 2007 O'BRIEN BARIC & SCHERER In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Term No. 06-6669 LISA J. LUCAS V. WALTER R. LUCAS IN DIVORCE TO: WALTER R. LUCAS YOU HAVE BEEN SUED IN COURT. The Plaintiff, Lisa J. Lucas, by her attorneys, O'BRIEN, BARIC & SCHERER, has filed a Divorce Complaint under §3301 (c) or (d) of the Divorce Code. If you wish to defend against this claim, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, this case may proceed without you and a divorce may be entered against you by the Court. You may lose property or other rights important to you. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION 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 (717) 249-3166 EXHIBIT "B" proof of publicattoll of Legal Advertisement in Porhlegat Recorb YORK LEGAL RECORD is the name of a legal newspaper as designated by the Act of Assembly approved April 24, 1931, P.L. 67, established on March 4, 1880, and issued continuously during a period of at least 6 months prior to the date hereof, owned and published by the York County Bar Association, a corporation, having its place of business at 137 East Market Street, in the City of York, Pennsylvania. The printed copy of the advertisement hereto attached is a true copy, exactly as printed and published, of an advertisement printed in the regular issue of said York Legal Record published on the date following SEPTEMBER 27, 2007 Krystal Zeigler Agent of the York County Bar Association designated and authorized to verify Proofs of Publication of advertisements and notices published in the York Legal Record. Commonwealth of Pennsylvania County of York I Ss.: Before me, LUCINDA J. VAN LAEYS, duly commissioned and residing in said County, personally came Krystal Zeigler who being by me duly sworn, deposes and says that she is a designated and duly authorized agent of the York County Bar Association to verify proofs of publication of advertisements and notices published in York Legal Record, for and on behalf of said Association, and has personal knowledge of the publication of the advertisement or notice mentioned in the foregoing statement on the day or days above stated and that the allegations in said statement relative to the York Legal Record are true according to the best of her knowledge, information and belief, and that she is not interested, directly or indirectly, in the subject matter mentioned in said advertisement or notice. Sworn and subscribed ? L ? ?( /! /?W? Before me this 5t" day of OCTOBER 2007 EALTH CEA ENN VAN), t Notarial Seal v Lucinda J. Van Laeys, Notary Public City of York, York County Comm! 2006 Received of CUMBERLA D CO , enns ania Associatlon of Notaries SIXTY AND 00/100 Dollars in payment of the charge for the publication of the above-mentioned advertisement and the expense of the above affidavit. Advertisement 64.35 YORK COUNTY BAR ASSOCIATION ACTION IN DIVORCE LISA J. LUCAS vs WALTER R. LUCAS No. 06-6669 TO: WALTER R. LUCAS YOU HAVE BEEN SUED IN COURT. The Plaintiff, Lisa J. Lucas, by her attorneys, O'Brien, Baric & Scherer, has filed a Divorce Complaint under Sec. 3301 (c) or (d) of the Divorce Code. If you wish to defend against this claim, you must enter a written appearance per- sonally or by attorney and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, this case may proceed without you and a divorce may be entered against you by the Court. You may lose property or other rights important to you. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFOR- MATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION 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 (717) 249-3166 9-27-1t $64.35 EXKIBIT 44cl? THE PALM BEACH POST Published Daily and Sunday West Palm Beach, Palm Beach County, Florida PROOF OF PUBLICATION STATE OF FLORIDA COUNTY OF PALM BEACH Before the undersigned authority personally appeared Marc Kramer, who on oath says that he is Inside Sales Supervisor of The Palm Beach Post, a daily and Sunday newspaper, published at West Palm Beach in Palm Beach County, Florida; that the attached copy of advertising for a Notice in the matter of #06-6669 was published in said newspaper in the issues of September 26. 2007. Affiant further says that the said The Post is a newspaper published at West Palm Beach, in said Palm Beach County, Florida, and that the said newspaper has heretofore been continuously published in said Palm Beach County, Florida, daily and Sunday and has been entered as second class mail matter at the post office in West Palm Beach, in said Palm Beach County, Florida, for a period of one year next preceding the first publication of the attached copy of advertisement; and affiant further says that she/he has neither paid nor promised any person, firm or corporation any discount rebate, commission or refund for the purpose of securing this advertisement for publication in the said newspaper. Sworn to and subscribed before 26' day of Se e be D 2007 Personally known XXX or Produced Identification Type of Identification Produced i?.?pRV p Karen N1, Minton 9 :1,Q: Expures. h4Y. 15, 2008 •: Bonded Thra Attaatic Bonding Co., Inc. EXHIBIT "D" LISA J. LUCAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-6669 CIVIL TERM WALTER R. LUCAS, Defendant ACCEPTANCE OF SERVICE A Ln? AND NOW, this A day of 2007, I, Margaret Byrd, hereby accept service of the Petition For Special Order of Court in the above cause pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a copy of said Petition. arguret 8lyd t_. _ ?....... , _ _ _? ? , f -- ?_ ?.,'. s' =J _ -^C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Anon& PENNA. LISA J. LUCAS, PLAINTIFF VERSUS WALTER R. LUCAS, DEFENDANT No. 2006-6669 CIVIL DECREE IN DIVORCE AND NOW, tc-'k - "l-' IT IS ORDERED AND DECREED THAT LISA J. LUCAS AND WALTER R. LUCAS ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, ,DEFENDANT, PROTHONOTARY THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE. ,ww -p- ^? ?-w -4) 3?