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Home My WebLink About96-05744 "'.1 ., , ..~ ~ ~ *t - .~ t. '-',-. I , I I ( I ,J ,n'l) d.f. (1)/7 ",:.J, ~ ",4 1.7'....:. oJ '.:>/''1') '*tti.. ~.....~~ it ?'~' w · . ' . , . . JOlt R. CHABB, . IN ~HB COUR~ OF COMMON PLBAB PLAIN~I" . CUMBBRLAND COUNTY, PBNNSYLVANIA . v. . NO. 96 - 5744 CIVIL TBRM . BBTH B. CHASB, . IN DIVORCE DBFENDANT . PRAECIPE TO TRANSMIT RECORD To the prothonotary. Transmit the record, together with the fOllowing information, to the Court for the entry of a divorce decree: 1. Ground for divorce I irretrievable breakdown under Seotion 3301(0) of the Divoroe Code. 2. Date and manner of service of the complaint I October 21, 1996, by Certified U.S. Mail, Reetricted Delivery. 3. Date of execution of the affidavit of consent required by section 3301(0) of the Divorce Code: By Plaintiff, January 22, 19971 By Defendant, January 25, 1997. ..... 4. Related claime pending: None 5. Date and manner of service of ths notice of intention to file praecipe to tranemit record, Waiver signed by Plaintiff on January 22, 1997. Signed by Defendant on January 25, 1997. .." ' Michael S. Travis Attorney for Plaintiff :1- ... e-l r:: fe r~ ~~. .. '-')H~ - h.,j: ... 0-....:.. 11'\ ;.l... d. a. I;"j li'l" ,.;., ,'1:1 -i;} fill '\,; - 'II H re ILL L,.; ',' i~. '~.. l}, ,.. (3 LJ 1;' . . NOTICE TO DBFEND AND CLAIM RIGHTS JOEl R. CHASE, I IN THE COURT OF COMMON PLEAS PLAINTIFF I CUMBERLAND COUNTY, PENNSYLVANIA I NO. 96 - ~/7LlL/ CIVIL TERM v. I I BETH E. CHASE, I IN DIVORCE DEFENDANT I IOU HAVE BEEN SUED IN COURT. If you wish to defend against the olaims set forth in the following pages, you must take prompt aotion. 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 ohildren. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, cumberland County Courthouse, Hanover and High streets, Carlisle, pennsylvania. 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. Cumberland County Court Administrator cumberland County courthouse Fourth Floor Hanover and High streets carlisle, PA 17013 (717) 697-0371 Ext 6200 " JOB! R. CHASB, I IN THB COURT OF COMMON PLEAS PLAINTIFF I CUMBERLAND COUNTY,PBNNSYLVANIA I NO. 96 - 'I /'/'/ V. I CIVIL TBRM I BETH B. CHASE, I IN DIVORCE DBFBNDANT I COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THB DIVORCE CODE IN DIVORCE 1. The plaintiff is Joey R. Chase who resides at 5210 Simpson Ferry Road, Mschanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Beth E. Chase whose last know address was 5120 Simpson Ferry Road, Mechanicsburg, cumberland County, pennsylvania 17055, 3. The Plaintiff and Defendant have been bona fide residents of the conunonwealth of Pennsylvania for at least six months inunediately prior to the filing of this Complaint. 4. The Plaintiff and Dsfendant were married on June 4, 1993, in Cumberland County, pennsylvania. 5. There have been no prior actions of divorce or annulmsnt bstween the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. \::'.."'-~.;..> -...._- .' ~ Michael S. Travis Attorney for Plaintiff 1.0. # 77399 Law Office of Thomas Gould 2 East Main strest Bhiremanstown, PA 17011 (717) 731-1461 Falt 761-1974 .......-.-- I verify that the statements made in this Complaint are true and correct. I understand that false statements hsrein are made SUbject to the penalties of 18 Pa. C.B. 4904, relating to unsworn falsification to authorities. Datel /oltYltf ( -;0~~ oey Chase a I' . . , , JOEY R, CHASB, I IN THB COURT OF COMMON PLIAS PLAINTIFF I CUMBBRLAND COUNTY, PBNNSYLVANIA I v. I NO. 96 - 57U CIVIL TBRM I BETH B. CHASB, I IN DIVORCE DBFENDANT I CERTIFICATE OF SERVICE II Michael S. Travis, attorney for Plaintiff, in the ~bove captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. P 430 556 B30, restricted delivery, return receipt requested, by dspositing the same in the United States mail on October 1B, 1996, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to ths Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was received by the Defendant on ootober 21, 1996. \, .-- -.;c' ,....-:.,- ./' Michael S. Travis ID , 77399 Law office of Thomas Gould 2 East Main Street Bhiremanstown, PA 17011 (717) 731-1461 '- -. '.-. fl' (>'; '.. r.r. .. '14 ~r' - ~ ~~r f' .- ":-:~ .... ,I U_ ;:J 1 0:'1 :15 @r: .. !.:i;.; ...i [f! lj~ {j,t '"L " '-'1 I- a t) ~ " ,.-,,-. . O!loml>lot.":""I1l4'or'Iof___., I 8110 wtBl1 10 receive 111, oC<lmi>lot."omo a, .., ond 4b, following ..rvIce, (for an .Print VOlINmelndlddl'lllonlht flVIfII 01 lhit Iorm 10 thai Mtan 'etumlNs eXlra '88): I told '0 rou, oAllodl "",,00. lolho Iron! ollho II1Illptto, 01 on lho batl d "'0.. doe. not 1. lJ Addraw~ ~.!!l" O~ROIum R<<>>ipI Roqwlllll'"" tho II1Illpioco bolo"", o~ido __ ~.a1i~I'rtctt<fDtlIWfyr, f 11llt "urnRecelpt Mllhowlo whomlhllrtldlwlI dab'lId andlhtdlll I doIlv Ill, Conlull pollma.' r ,~ .. 3. I. Add.....d to: 4e, Article umber I ) 7'J " ~~C~ J'j'<::l b, Sarv\ce ype j o Reglllered .J;I-ctrtlnad 3 0 Ellpr... Mall 0 Ineurad r (J'fl.'um Atallpt IS IJ COO .Ill 7, Date 0 0.11 ~ l II reqtJ8llad I, Ii : I " :; Beth E. Cha:le MAZZITT' & SULLIVAN 1305 Middletown Rd, Ste HUmrnelBto~n, fA 17036 :1 .. . " . \. . , " . \ UNITED STATES POSTAL SEAVICR' -~"'\ ! , l'1rat,C1a.. Mall.. Poltaga & Faa. Paid USPS PI"",l No. Q.IO . Print your name, address, end ZIP Code In this box. Michael S. Travis Law Off. Thomas Gould 2 E, Main street Shiremanstown, PA 17011 " ) .. " ,. .. JOB! R. CHASB, I IN THB COURT OF COMMON PLEAS PLAINTIFF I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 96 - 5744 CIVIL TERM I BETH B. CHASB, I IN DIVORCB DBFENDANT I AFFIDAVIT OF CONSBNT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on october 18, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of 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. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimonYI 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. " DATED I /h.,.)q7 I ' /"" Q J~Y R. Chase -" r ( ir. - (,' ." co: ~ " .. "~'.~ Nf' - .'~J -~ .;"~ -~ :] ", o. .t- ( "... ..I ~'l ':1;) ~r:J Ji' - :t..,; [j- t (i, ')(0 . , tJu: I 1',:' ~ . , I,. ,.... :J u 0" U I i I I . .' .. .. I . . - . JOEY R. CHASE, I IN THB COURT or CONNON PLlAS PLAINTIFr I CUMBBRLAND COUHTI,PENHSYLVARIA I v. I NO. 96 - 5744 CIVIL TIRM I BETH E. CHASB, I IN DIVORCB DEFBNDART I WAIVER OF NOTICE or INTENTION TO REOUBST INTRY or A DIVORCE DBCREE UNDBR SBCTION 3301/c\ OF THE DIVORCB CODB 1. I consent to the entry of a final decres without notice. 2. I understand that I may lose rights concerning alimonr' division of property I lawyer's fees or expenses if I do not cla m 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 subject to the penalties of 18 Pat C.S. Section 4904 relating to unsworn falsification to authorities. DATED I IA~./'97 ( ( ~ (' / Joe . Chi.. ----. .. ~ _. f"~ cr; .. ")..- IuD - , J;~'l a'" :c: j". 'L , . t~ j-'I Q,. :'2 ~t ' ' 0:1 ,ilJ . t ~ 11,: ' ."1"':,,, a', ~ "ll! -L~' i r:: " ...;~ II ,... J U l1' U . ~ ~ . . . . . JOIY R. CHASI, I IN THB COURT OF COMMON PLEAD PLAINTIFF I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 96 - 5744 CIVIL !rBRM I BBTH B. CHASB, I IN DIVORCB DBFBNDAN!r I AFFIDAVIT OF CONSBNT 1. A Complaint in Divorce under Section 3301 (0) of the Divorce Code was filed on October 18, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of 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. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. 4. I underetand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses, if I do not claim them before a divoroe is granted. I verify that the statements made in thie Affidavit are true and oorreot. I understand that false statements herein are subjeot to the penalties of 18 Pa. C.B. Section 4904 relating to unsworn falsification to authorities. \ DATED I I' d\~-; "- (I") J2(LI" (' e u. ' ,~ ' V\ ( __,a ',\ Blth E. Cbaae ( , _-i{ I' ~ - f: C': '... ~, i.~ ~f .. - '1''1 - I ~i. 11: ""!'o I' !;!J '- ," ~I I if) ]', Ii ;ffi J ~ G'l. '.' r4. .. .J II, r; :.1 () l) ~ .. . . .. . ~. .. . ~ . JOEY R. CHASE, I IN THI COURT OF COMMON PLEAD PLAINTIFF I CUMBERLAND COURTY,PEHHSILVANIA I v. I NO. 96 - 5744 CIVIL '.rERM I BETH E. CHASE, I IN DIVORCE DEFENDANT I HAI\~R OF NOTICE OF INTENTION TO REOUED'.r EN'.rRI OF A DIVORCE DECREE UNDER SECTION 3301'0\ OF THE DIVORCE CODE 1. I oonsent to the entry of a final deoree without notioe. 2. I division of them before understand that I may lose rights conoerning alimonr' property, lawyer's fees or expenses if I do not ola m a divoroe is granted. 3. I understand that I will not be divoroed until a divoroe decree is entered by the court and that a oopy 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 oorreot. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. DATED I {/(:25 /C)1 f I 861&\ [ ~fut() Betb E. Cball '\ () " I i I I I I ... N .~ f:r: "'fl' C'; . ~, .. rZS ~~ - L .~ . fe 1::1' .- ~'. t... j:~ , a:J iil ' , l ~". -.')i,; ~!!- ~ :~ r: " . l:J ., r- :; t;, U " . . .' \, Ii~_