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NOTICE TO DEFEND
AND CLAIM RIGHTS
IN THE COURT OF COMMON PLEAS OF
LEBANON COUNTY,
PENNSYLVANIA
CIVIL ACTION - FAMILY DIVISION
IN DIVORCE
NO. 2018-20932
ANGELYZ FRANQUI-PAGAN,
Plaintiff vs.
KEVIN FIGUEROA,
Defendant
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 the 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 400 South 8th Street, Municipal Building, Room #104, Lebanon, PA 17042.
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, 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.
MID-PENN LEGAL SERVICES
1150 CHESTNUT STREET, SUITE 1
LEBANON, PA 17042
717-274-2834
COMPLAINT IN DIVORCE
IN THE COURT OF COMMON PLEAS OF
LEBANON COUNTY,
PENNSYLVANIA
CIVIL ACTION - FAMILY DIVISION
IN DIVORCE
NO. 2018-20932
ANGELYZ FRANQUI-PAGAN,
Plaintiff vs.
KEVIN FIGUEROA,
Defendant
AND NOW, comes the Plaintiff, Angelyz Franqui-Pagan, by and through her attorneys, FEATHER AND FEATHER, P. C. and makes the following averments:
1. Plaintiff is Angelyz Franqui-Pagan, who currently resides at 1940 Church Street, Lebanon, Pennsylvania 17046
2. Defendant is Kevin Figueroa who currently resides at 11406 Bridge Pine Drive, Riverview, Florida 33569.
3. The Plaintiff has been a bona fide resident of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married May 27, 2017 in Lebanon, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
COUNT I - DIVORCE
6. Paragraphs 1 through 5 above are incorporated herein by reference as if textually set forth at length.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised of the availability of counseling and is aware that she may have the right to request the Court to require the parties to participate in counseling.
WHEREFORE, the Plaintiff prays this Honorable Court to enter a decree in divorce.
FEATHER AND FEATHER,
P.C.
CHARLES A. RITCHIE, JR., ESQ.
I.D. #47461
22 West Main Street
Annville, PA 17003
(717) 867-1200
Attorneys for Plaintiff
March 12, 2021 21-00733H