The URL can be used to link to this page

Home My WebLink About94-02085 oJ '" -,:) c :J Q} If) ." j j J lr) Co a (Q 6; . ~ .... .... co .... yc>- .r.... , .<"'-'~ t:1,""l" .'O' _:..;r.......:. .,....Ol.,':!:- ~~ 1~"2'.: :;~., ~ (!'" \.I") - - ~ ~ ~~ ,.~ 1-, '""b- ~ C:i , ~ . . , . l~ Q I/) '\) ~ I . . rQ ~ ~ ~ - ~ ~ ..'.....i r . I' ',_-;'..~~~ ...., ~.... ~', (,: CB .. r . ~ - ... . . . ,,-, .. '. .. . ,....... "" LAURA L, LINDSEY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA NO, q 4 - ~ 0 85 C iv,' J Tt ( fY1 CIVIL ACTION - LAW VS, STEFAN LINDSEY, DEFENDANT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGIITS YOU IIA VE 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 entered against you by the Court, A judgment may also be entered against you tor any other claim or relief requested in these papers by the PlaintifT. 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 at the Cumberland County Courthouse, 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 SIIOlJLDTAKE TillS PAP":R TO YOUR LAWYER AT ONCE. IF YOU DO NOT IIA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE THE OFFICE SET FORTII BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL IIELP. COURT ADMINISTRATOR CUMBERLAND COlINTY COURTHOUSE CARUSLE, PA 17013 (717) 240-6200 . ,.. "" "'\ LAURA L, LINDSEY. PLAINTIFF IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA VS, : NO, qq, ~08S : CIVIL ACTION. LAW o~, I Tn tv) STEFAN LINDSEY, DEFENDANT : IN DIVORCE COMPLAINT IN DIVORCI: UNDER SI:CTION 330ltd OR SI:CTION 3301t1l) 0..' TilE DIVORCE CODE \, The PlaintifT, Laura L, Lindsey. is an adult individual who currently resides Ilt 409 C Beaver Avenue, Enola. Cumberland County. Pennsylvania 17025, 2 The Defendant. Stefan Lindsey, is an adult individual whose current address is 417 Antelope Court. Mechaniesburg. Cumberland County. Pennsylvania 17055, 3, PlaintifThas been a bona fide resident of the Commonwealth of Pennsylvania for at least sil( months immediately prior to the filing orthis Complaint. 4, The PlaintifTand the Defendant were married on February 17. 1990, in Cumberland County. Pennsylvania, 5, The parties separated on or about March 27,1993, 6, Neither party hns instituted nny prior action of divorce or annulment with regard to this marriage in this or any other jurisdiction, 7, There are two minor children by this marriage: Aiel( Jedidiah Lindsey. born May 2, 1988 and Ryan Matthew Lindsey. born August 29, 1990, 8, Neither the PlnintifTnor the Defendantnre members of the Armed Forces of the United States of America or any of its allies, 9, The marriage is irretrievably broken. ,.." "\ " 10. The PlaintilT avers that she has been advised of the availability of counseling and that she may have the right to requcstthatthe Court require the parties to participate in counseling, Wherefore, the PlaintilTrequests this I-Ionorable Court to enter a Decree of Divorce)n this mailer pursuant to 3301(c) or 3301(d) of the Divorce Code, ii.) i1YL) I\nnond, Esquire Allo D Number 64177 2800 Market Street Camp HiII.I)A 17011 (717)730-9394 DA"9tJ ;(rJ , 1994 - ._.~.~.,~..._.. ,~.. ...~ ., ,. VERIFICATION I, Laum L, Lindsey, state that I am the PlaintilTin the above-captioned case and that the facts set forth in the above Complaint in Divorce are true and correct to the best of my knowledge. infonnation and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa, C, S, 4904, ~~~, ~Vfl~ Laura L. Lindsey Date: 4/4-/Qq. '" ~- , u_>,. f'..,"~-"",,- ..........<.._N.- LAURA L. LINDSEY, PlaiOlilT : IN TilE COURT OF COMMON Pl.EAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs, : NO, 94-2085 CIVIL TERM : CIVIL ACTION - LAW STEFAN LINDSEY. Defendant : IN DIVORCE NOTICE TO TilE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must tile a counter-affidavit within twenty (20) days aller this affidavit has been served on you or the statements will be admitted, PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF TilE DIVORCE CODE \ ) l{'), ( h.; llqq:.;> I. The parties to this action separated on or about August 1,5; 1985, and have continued to live sepamte 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 gmnted, I verilY 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, Section 4904 relating to unsworn falsilication to authorities, . Date: '5 J 4-1 qS I I '. .. . '. LAURA L. LINDSEY, PLAINTIFF IN TilE COURT OF COMMON PLEAS : OFCUMIJERLANDCOUNTY, PENNSYLVANIA VS, NO, 94-2085 CIVIL TERM : CIVIL ACTION - LAW STEFAN LINDSEY, DEFENDANT : IN DIVORCE nEFENDANT'S COlINTER-A.....IDA VIT tiNDER SECTION JJOHdl Oil TIm I)IVORCI~ conE I. Check either (a) or (h): _ (a) I do not oppose the entry ofa divorce decree, _ (h) I oppose the entry of a divorce decree hecause (Check (i), (ii) or hoth): _ (i) The parties in this aclion have not lived separate and apart for a period of at least two years, _ (ii) The marriage is not irretrievahly broken, 2, (Check either (a) or(h)): _ (a) I do not wish to make any claims lilr economic relie!: I understand that I may lose rights concerning alimony, division of property, lawyer's fees or eKpenses il'l do not claim them before a divorce is grunted, _ (b) I wish to claim economic relief which may include alimony. division of property, lawyer's fees or expenses or other important righls, I verify that the statements made in this counter-affidavit are true and correct. I understand thatlillse statemenls herein are made suhjecllo the penalties of 18 Pa. C, S, Section 4904 relating to unsworn falsification to authorities, Date: Stelim Lindsey NOTICE: If you do not wish toollllose the entry of II divorce decree and you do not wish to make any eluim for economic relief, you need not file this counter-affidavit. ... ~... . CERTIFICATE OF SERVICE AND NOW, this ItJ'Tt. day of ~ ' 1995, I, Keith 8, DeAnnond, Esquire, hereby do certifY that I have served a copy of the foregoing on this date by depositing a copy of the same by Certified Mail and 1st Class United States Mail, postage prepaid in Camp Hill, Pennsylvania, Addressed to: Mr, Stefan Lindsey 44172 Antelope Court, #118 Mechanicsburg, PA 17055 L~~,/ - -