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Home My WebLink About95-06211 ~ , " , ~: :.;. " . ~'.; .,-- . lUlGELA M. LAWRENCE IN THE COURT OF COMMON PLEAS OF Plaintiff THE 9TH JUDICIAL DISTRICT, PA. i' I' vs. CUMBERLAND COUNTY BRANCH i CIVIL ACTION - LAW \ I KENNETH L. LAWRENCE, SR. I Defendant NO. 95-6211 Civil Term ~OTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TO: KENNETH L. LAWRENCE, SR. 2440 LoW Ditch Road #4 Gettysburg, PA 17325 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-Affidavit to the plaintiff's Affidavit. Therefore, on or after December 18, 1995, the plaintiff can request the court to enter a final Decree in Divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter- Affidavit by the above date, the court can enter a final Decree in Divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH yOu MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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. pennsylvania Bar Association Lawyer Referral service Telephone: 1_800-692-7375 (PA ONLY) or 717-238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin Count is re law to complY with the Americans with Disab~lities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals havin business before the court, lease contact our office. All arran ements must be made at least 72 hours rior to an hear in or business before the court. You must attend the scheduled conference or hearing. _ A~til~i,A.::":"<.~ ,"~-L: ,'.--,- . MARTIN' GRAY, P.C. Date: JJ- :;17.Q5 ,j II'~ J:t - fl.i.I"-:"tv . c..A./ Kimberly S. Gfay I Attorney for~Plaintitf . \:lC "'- ... , ... ~ .- - ie -...~~:! u co.. eZu.. . ~...~ OS;j" ~lEa:= ,-'w"';C i6::c"'W I-:&~ ;:;5 e. ,~ \r, \r, . \6 '"i> t'\) ~ - ~ G \.;..0 c::t ,-n , .!j .' - r ~ .'- . . ~~ ATl'ORNEYll AT LAW - 10 ftAlI1tLlN MAIITIN. . 2".AIloll NIl. _ . W.,...... PA \7261 (7\1)762.\001 . PAX (7111762.515r - ~~'2 _ M..,. r- . ~ (;)0 ~@ . . . IUMIIULYI.GIlAY. ~. Nmh'Mal.S....' . ~.Mmll\ . Qll)J6HlOO . PAX (7I7l2601-7m vs. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT, PA. CUMBERLAND COUNTY BRANCH ANGELA M. LAWRENCE Plaintiff KENNETH L. LAWRENCE, SR. Defendant CIVIL ACTION - LAW NO. qj". &,;)// r; ql-~L_ ,j U~..- 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 in 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 at Cumberland County Courthouse, Carlisle, Pennsylvania 17013 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. Court Administrator Cumberland County Courthouse Carlisle, Pennsylvania 17013 Phone: 717/240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. MARTIN & GRAY, P.C. l . By ilH Attorne Kimberl S. Gray 38 N. Main st. Chambersburg, PA 17201 (717) 263-8500 \., ., '.., r> ~F" , . \ ~ : , - '~ '5, .~ T <,'i If you wish to deny any of the statements set forth in this atfidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE NOT:ICE 'l'0 THE DEFENnaNT 1. The parties to this action separated in , 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 th.. before a divorce is granted. I verifY that the statements made in this aftidavit are true and correct. I understand that false statements herein are aade subject to the penalties of 18 pa. C. S. 4904, relating to unsworn falsification to authorities. Date: .-10' JiLl- q n y..k'J~tLJ:}i. 't!ln"IAlillq t..; .~~ ANGELA M. LAWRENCE Plaintiff IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT, PA. CUMBERLAND COUNTY BRANCH vs. CIVIL ACTION - LAW KENNETH L. LAWRENCE, SR. Defendant ;;.~ . NO. ~ -~ 1 COMPLAINT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. at 271 County, Plaintiff is Angela M. Lawrence , a sui juris adult who resides Newville Road, Shippensburg, Southhampton Township, Cumberland Pennsylvania 17257, since September, 1993. ;1 .,t 2. resides County, Defendant is Kenneth L. Lawrence, Sr., a sui juris adult who at 2440 Low Ditch Road *4, Gettysburg, straban Township, Adams Pennsylvania, 17325, since October, 1994. ;, i 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 8, 1975, at Westminster, Carroll County, Maryland. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff requests the court to enter a Decree in Divorce. 8. The Plaintiff has counseling and the Plaintiff require the parties hereto to been advised has the right participate in of the availability of to request that the court counseling. .. .....11If _a_ _..J._ ......_~ .ftUI . ~Jk AT\llRNlml AT LAW ,,~..,....~....., .C~.'j,.,-'- ,. . VB. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT, PA. CUMBERLAND COUNTY BRANCH ANGELA M. LAWRENCE Plaintiff CIVIL ACTION - LAW KENNETH L. LAWRENCE, SR. Defendant NO. 95-6211 Civil Term AFFIDAVIT OF SRRVICE BY C~RTtFIED MAlL Kimberly s. Gray, deposes and says that on November 4, 199~, ahe served a true and correct copy of the complaint in Divorce and plaintitt's Aftidavit in the above captioned matter on the Defendant, Kenneth L. Lawrence, Sr., by mailing the same trom the Chaabersburg Post ottioe by certified Mail No. P591536698. The return receipt card showing the signature of Kenneth L. Lawrence, Sr., on November 4, 1995, is attached hereto and made a part hereof. I verify that the statements 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 talsification to authorities. MARTIN & GRAY, P.C. i -Y-2 ()j / 2 (l}hJ~, ~,-N K mberly s. tfray () Attorney for plaintiff 38 N. Main st. Chambersburg, PA 17201 717/263-8500