IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY, PENNSYLVANIA

CIVIL DIVISION

:
:
Plaintiff	:
vs.	:	File No.
:
:	IN DIVORCE
Defendant	:

COMPLAINT IN DIVORCE

Under Section 3301(c) OR 3301 (d) OF THE DIVORCE CODE

AND NOW, this day of , 20 comes the Plaintiff , who files this Complaint in Divorce a statement of which is as follows:

1. The Plaintiff,	, is an adult individual residing at
(Name)
(Address)	(City)	(State/zip)	(County)
2. The Defendant	, is an adult individual residing at
(Name)
(Address)	(City)	(State/zip)	(County)
3. resided in the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint.

4. Plaintiff and Defendant were married on	in
(Date)
(City/State or Courtry)
5. There have been no prior actions for divorce or for annulment of the marriage between
the parties in this or any other jurisdiction. Except
6. Plaintiff avers that the Defendant is not a member of the armed services of the United States and so the protections afforded under the Service members Civil Relief Act are not applicable.
7. Plaintiff has been advised of the availability of marriage counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives whatever rights he/she may have to request marriage counseling.
8. Plaintiff avers that the marriage is irretrievably broken.

WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce upon the following grounds:

A. Plaintiff avers that the marriage between the parties is irretrievably broken and believes that the Defendant will consent to the entry of a divorce decree under 23 Pa.C.S.A. §3301(c), after at least ninety (90) days have passed from the date of service of the within Complaint.

B. Plaintiff avers that the marriage between the parties is irretrievably broken within the meaning of 23 Pa.C.S.A. §3301(d) of the Divorce Code, and the parties will have lived separate and apart for a period of at least two (2) years with the date of separation commencing prior to December 5, 2016, or one (1) year with the date of separation commencing on or after December 5, 2016 at the time of hearing of this matter and/or at the time that the Plaintiff will file an Affidavit under 23 Pa.C.S.A. §3301(d) of the Divorce Code.

Print Name:

Signature:
Address:

Phone:

Fax:

VERIFICATION

I verify that the statements made in this Pleading 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:
Plaintiff

(Rev. 12/17 Form 4)

3

DVCWB

IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY, PENNSYLVANIA

Rachel A Wotring

2023-01-18

Lehigh County