Form 4

Fill in form
If you are E-fling at the Lehigh County Courthouse PRINT ONE (1) COPY.
If you are E-filing from your personal computer. Digitally sign and print to pdf. DO NOT efile any
document with the blue instuctional text.

IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY, PENNSYLVANIA

CIVIL DIVISION
Enter Name :
:

Enter Address, City, State and Zip

Plaintiff :
vs. : File No.
Enter Name
:
: IN DIVORCE
Enter Address, City, State and Zip Defendant :

COMPLAINT IN DIVORCE
UNDER SECTION 3301(c)(1) 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

Use drop down menu 3. Plaintiff and Defendant have resided in the Commonwealth of

Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint.

1
DVCWB
 4. Plaintiff and Defendant were married on ____________________ in
(date)

________________________________________________________________.
(city/state or country)

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.

2
 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)(1),

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
 Form 3

IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY, PENNSYLVANIA

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

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 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.



127,&(2)$9$,/$%,/,7<2)&2816(/,1*
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:

CLERK OF JUDICIAL RECORDS, CIVIL DIVISION

LEHIGH COUNTY COURTHOUSE
FIRST FLOOR, ROOM 122
455 W HAMILTON STREET
ALLENTOWN, PENNSYLVANIA 18101-1614
 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.

LEHIGH COUNTY BAR ASSOCIATION

LAWYER REFERRAL SERVICE
1114 W WALNUT ST ALLENTOWN PA 18102
PHONE: 610-433-7094

AMERICANS WITH DISABILITIES ACT OF 1990

The Court of Common Pleas of Lehigh 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 the Court Administrator’s Office at (610) 782-3014. All arrangement must be
made a least 72 hours prior to any hearing or business before the Court. You must attend the
scheduled conference or hearing

(REV. 7/08) Pa R.C.P. § 1920.71

Form 3