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HomeMy WebLinkAbout96-04661 ***-*~*~~~****~~,,*.~*,~)**..*****-*~ ~ \ ~_._----------..-...--.-..-... ---- --...---...----._..~~... ,--...~.,--~..... ." -- ~ . .... ,. ... .,-.....-.. ,.._-~-'--------~-'" -.--- .~_. { ~ ,~j I~ ','\ /'.- I, PLEAS i~ I,.. I~ k 1',- I.., ~:: IN THE COURT OF COMMON ~ ~ OF CUMBERLAND COUNTY ~ I':I' STATE OF l~~': PENNA. ~ ~{ ~ ~ ~ ~ ~ ~ ~ Mark J. Swab Plaintiff ~(), 96-4661 "Civil Term V('!'.'l!.'; Gemma M. Swa b Defendant ~ ~ ~ ~ DECREE IN DIVORCE ~ ~ AND NOW, ",'D.C~4M~~ r, ,$""" 1996"", it is ordered and decreed that ,Mark, ,J:. ,Swab..........,..",....".."..,....., plaintiff, and, ...... .., Ge,mma, ,M.... Sw,a,b....." "" " .. ..,.. ' " ......., defendant, are divorced from the bonds of matrimony. .. ~ ~ ~ ~ ~ ~ The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ ~ ~ ~ . . . . , . . . . . . . , . , . . , . . . . , . , , . , . , , , . , . ~ ;t: ':+:' ':+:- -:..:- ':0-:- ':+> ,:.:- ':..:. ':~> ':+:. ':+:- ?- '" ~. fly The W~'~ Oir ~r . ,. AlIc!lt: .;' I / ~. J. /1b-"Jt"NC<' (~}a. 4 ~~Ar~/ V;;~/:'Yl r, x..!/~i {jj;;;:{ fI / JUthonolary ~ ~ ~ ~I ~; ~I ___M" ',:.:. .~:' .:t:. .:+:. .:+> .:+:. .: .' .::+:. ':+:. ':+:. -:+:. .:.:- ':+:- -:+> -:+:' ':+:. .:+:. ':+:' ':+:- -:+;. ~ I~ i'" \~ I':' '~ ~ ~ ~ ~ I':' I~ , ' i~ I~ .. I~ ~ ~ ~ ~ ~ ~ ~ :~ ~ ~ :~ :~ ',~ ~ ~ ~ . , ~ ,~ MARK ], SWAB, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, No, 96-4661 Civil Term GEMMA M, SWAB, Defendant CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 330 I (c) of the Divorce Code, 2, Date and manner of service of Complaint: August 24, 1996 by Certified mail, return receipt requested, 3, Date of execution of the Affidavit of Consent required by Section 330J(c) of the Divorce Code: by Plaintiff: November 25, 1996 by Defendant: November 25, 1996 4, Complete the appropriate paragraphs: (a) Related claims pending: There are no outstanding relatcd claims pending, (b) Claims withdrawn: There are no outstanding claims withdrawn, (c) Claims settled by agreement of the parties: There are no outstanding claims settled by agreement of the parties, Date: November 25, 1996 ~4 ~\ \=o:\-v---- Randall L. Hartman Attorney for the Plaintifi. MARK J, SWAB, Plaintiff . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY, PENNSYLVANIA : No, I C 'I (, I, I tu', I ;,., ,_ v, GEMMA M, SWAB, Defendant : CIVIL ACTION - LAW . IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF TilE DIVORCE CODE AND NOW, comes Plaintiff, Mark 1. Swab, by and through his attorney, Randall L. Hartman, \ Esquire, Randall L Hartman, PC, Lemoyne, Pennsylvania, and files the following: COUNT I DIVORCE PURSUANT TO SECTION 3301(c) OF TilE DIVORCE CODE I, Plaintiff is Mark 1. Swab, who currently resides at 79 Kensington Drive, Camp Hill, Cumberland County, Pennsylvania, 170 II. 2, Defendant is Gemma M, Swab, who currently resides at 66 Sherwood Circle, Enola, Cumberland County, Pennsylvania, 17025, 3, Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4, The plaintiff and defcndant wcre married on Novcmber 2,1985 in Fairview Township, York County, Pennsylvania, 5, No prior actions for divorce have bccn filcd, 6, Thc marriage is irrctricvably brokcn, 7, PlaintitThas been advised that counseling is available and that plaintitTmay have the right to request that the court require the parties to participate in counseling, 8. The causes of action and sections of the Divorce Code under which PlaintitT is proceeding are: a, Section 330t(c), The marriage of the parties is irretrievably broken, After ninety (90) days have elapsed from the date of the filing of this Complaint, plaintitTintends to file an Affidavit consenting to a divorce, PlaintitT believes that defendant may also file such an affidavit. WHEREFORE, PlaintitT respectfully requests the Court to enter a Decree of Divorce divorcing PlaintitT and Defendant. Respectfully submitted: ~~~ Randall L. Hartman, Esq, Randall L. Hartman, PC 438 Market Street Lemoyne, P A 17043 (717) 761-8490 I.D, No. 68732 CERTIFICATE OF SERVICE I, Randall L. Hartman, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, return receipt, upon the following, on the date indicated below: Gemma M, Swab 66 Sherwood Circle Enola, P A 17025 Date ~ ,w \"-tl(P /Z,~~\ L~- MARIO, SWAB, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, No, 96-4661 Civil Term GEMMA M. SWAB, Defendant CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Randall L Hartman, the undersigned, hereby certify that I have served a original copy of the Divorce Complaint, by certified mail, return receipt, upon the following, on the date indicated below: <;; SENDER: " .Completeitoms1 andlor2lor.dditional saNieet 0; 'Complete items 3, 48, and 4b. ' ~ 'Print your name and address on the reverse oflhis form 80 thai we can rel"m 'h' ii card to you. .. IS > .Attac~ this form 10 lhelronl 01 the mailpiece or on the back ita,.", do. I f permit. ' a no lIP :~~R8tum Re~eip' ~equ6SI&d' on the mailpiece below the arliclo number ~ deliv8:d~ ReceIpt Will show 10 whom the article was delivered and the dal~ o 'll ... il. ~ 3. Article Addressed to: ~ e. "^ IV\. G..- ~ v.),~ I.:, W~ Sh~r<-voo", EtJo \~ f{\ , I also wish to receive the following services (for an extra fee): 1. 0 Addressee's Address B ~ 2. 0 Restricted Delivery ~ Consult postmaster for fee. 46. Article Number Q...\.rc..\~ 17DZ.~ it ~ II: 4b, Service Type ~ O ... Registered B Certified a: o Express Mail 0 Insured ~ o Return Receipt for Merchandise 0 COD ~ 7. Date of Del~ oS .k" / i. .1/ P (fl [ 8. Address~e's Address (Only If requested .lIC and fee IS paid) :; .c t- 'Z- '2. 2..0 s,,,-.i.lP Domestic Return Receipt Date: November 25. 1996 . ~~k\\.~ Randall L. Hartman, pc. AllOrney At Law Counsel for PlaintifY 438 Market Street 1',0, Box 33 Lemoyne, I' A 17043 7171761.8490 1..!.1 (;; u__. I.'. (L (.I U! L~_ '.. ~ ,. ~~:; [i: L'., (/i C~ :..- '-- , MARK J, SWAB, Plaintiff :IN THE COURT OF COMMON PLEAS :CUM13ERLAND COUNTY, PENNSYLVANIA v, :No, 96-4661 Civil Term GEMMAM. SWAB, Defendant :CIVIL ACTION-LAW :IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) and 3301(d) of the Divorce Code was filed on June 30, 1994, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree, 4, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if[ do not claim them before a divorce is granted, I verifY 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,~~ 4904 relating to unsworn falsification to authorities, Date \\ ~q~ {\\ C\\~(\ o,~>J~iY' Mark 1. Swab \ MARK J SWAB, Plaintiff :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA v, :No, 96-4661 Civil Term GEMMAM, SWAB, Defendant :CIVIL ACTION-LAW :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~~ 3301(c) OF TilE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice, 2, 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 granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verifY 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,~~ 4904 relating to unsworn falsification to authorities. Date t( ~(q(, J- , '" C,,; I IUI' f~~ 1.,'._: l/t C': "". '" ,;. " 1..J t.. MARK 1. SWAB, Plaintiff :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Date II ) J-sI1f.-, I .~ v, :No 96-4661 Civil Term GEMMA M, SWAB, Defendant :CIVIL ACTION-LAW :IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) and 3301(d) of the Divorce Code was filed on June 30, 1994, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3, I consent to the entry ofa final decree of divorce after service of notice of intention to request entry of the decree, 4, 1 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 granted, I verify 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, ~~4904 relating to unsworn falsification to authorities, "