The URL can be used to link to this page

Home My WebLink About00-00778 '.'" ,-,:,<, ' -,',,~ --'':,;,,;-;-::,"--:'.,;~_ "-c;'__"-'~':, ~"~-r~:,::;::-:,;;..,~ "~, ~;:' JESSE DEAN EASH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW CAROLYN lONE EASH Defendant NO.;loao- r7f CIVIL TERM CIVIL ACTION - IN DIVORCE 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. If the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3l66 ~~ Marlin R. McCaleb Attorney for Plaintiff LAW OFFICES MARLIN R. McCALEB ,", , r- '- ,',,-. .~, .'-. ~;.' ~.' , ,-,,,,' "~".--' '-'0" ;-'-~--".', ;~-'.;" ~ ':' AS. -1:;2;!;;:~'; JESSE DEAN EASH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. CIVIL TERM CAROLYN lONE BASH, Defendant CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is JESSE DEAN EASH, who currently resides at 288 Stumpstown Road (Monroe Township), Mechanicsburg, Cumberland County, pennsylvania 17055, since on or about November 30, 1993. 2. Defendant is CAROLYN lONE EASH, who currently resides at 1 South Chestnut Street, Borough of Dillsburg, York County, Pennsylvania 17019, since on or about December 20, 1999. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 22, 1992, in Lower Allen Township, Cumberland County, pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court LAW OFFICES MARLIN A. McCALEB -2- nCC' ,.~,. .c", ',", ~-" '.'-,--",,;,,; j~';;-',,'-=--'::;,,; .'" ,-,..,_, .;.","~O r;<ij",,,,,,,,.,, _,'>' :--~:,::~:::>,'I~i,':.';~ """~' ..,h-,' ";j require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of l8 Pa. C.S., Section 4904, relating to unsworn falsification to authorities. Date~_ ( , 2000 ~~ Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 69l-7770 FAX: (717) 69l-7772 Attorney for Plaintiff LAW OFFICES MARLIN R. McCALEB -3- " H,~--" " "~.-,,-.,,,--"~'""';' ;,o:i:-,_" '-, ,,;_,'~' ;~ _, '., --.';~"", <i.''<;' " '",i ,C,~,_",'-' ,-. '" ", ~L'-\,i ";' ~,h' ,- ,-_ ~ ., ;,::;,;:'J;-.)..-:-.:,;';,,~,'; "i JESSE DEAN EASH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. CIVIL TERM CAROLYN lONE EACH, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Jesse Dean Eash, being duly sworn according to law, deposes and says: l. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of l8 Pa. C.S., Section 4904, relating to unsworn falsification to authorities. Date:~, 1/ , 2000 LAW OFFICES MARLIN R. McCALEB 0 "-< ozO OH :>' t'J HOH c::Z ~ (I) ",. '" :s: 0 (I) H H tJj8 ~ t-' t'J t-' t-' t'J::r1 m ~ 0 Kl ~t'J n 0 Z tJ :>' ~ t-' :r :s: t'J 0 0 ~O l> '0 H ~ 8 8 ZO z n N" t-' 0 Z H H tJc:: - ~ ~ Z 0 0 ~ V> III l> ~ \J rrI Z H t'J <: t'J Z Z 08 JJ' ;PO" r Z Ul '" 0 Cl 0 11l tt1 ~ ~ ~l t'J . (I) I I C::O . . -I tJl ~ ::r1 Z":! \Jill s: 111 0 111 0 l> :D " H tJ(I) '0- HOt-' 8 z x _ Cl " Z ro ::r1 I--' ZH~ KlO Z f\.l Z 1TI f n "'- PI <::!: - 0 tIl W VI II m -< 0 -I 11 V> tJ ro f-'. tJH 'O~ r ~ r H ::l ::l HI:'" ~ m l> '" P, rt '" t'J0 z m n - ~ '" 0 PI f-'. 08 ZZ l> ~ ::l '" ~t'J Z :;j 0 rt '" 0::0 (1)'0 0 t'J t'J:S: Kll:'" V> 1:"'t'J V> "'''' "'(I) Z. HO p":! -I::i. ~ ~ ~ ~ (') Co ',,-) h ~ C C::J '1"1 < ."f'l . uFT~' fTi ~ 8 ~ ~~, UJ ~ ...... "';:i ;T~ €J - .--'-' ).3 ~ 1 , (:::t y (~,\ JU ~ ~c; )::-:1> T. Q..- ~ ~"~..' ~;?0 - 5;; (:1 C i5i"!1 2:: "" ~ :< ',"", 2: r..:> ~, -< ~ ~ '0 > ~_ __,' ,-"" ,--,"", '- ,y"-,;',',-""-"",,,,--','';.-,,'','''' ,~,-~ ~"" ",.---", I~~,"'c'-"'r',: -""j JESSE DEAN EASH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000 - 778 CIVIL TERM CAROLYN lONE EASH, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF SERVICE MARLIN R. McCALEB, Esquire, certifies and says: that he is the attorney for Jesse Dean Eash, the Plaintiff in the above-captioned action; that on behalf of said Plaintiff, he did file Plaintiff's Complaint in Divorce in the Office of the Prothonotary of Cumberland County, Pennsylvania, on February 10, 2000; that pursuant to Rule No. 1930.4(c) of the Pennsylvania Rules of Civil Procedure, he did serve said Complaint upon Carolyn lone Eash, the Defendant herein, by depositing a true and attested copy of said Complaint, properly endorsed with Notice to Defend and Claim Rights, in the mail in the post office at Mechanicsburg, Cumberland County, Pennsylvania, on February 11, 2000, properly addressed to the said Defendant at her place of residence at One South Chestnut Street, Dillsburg, PA 17019, with proper postage attached, certified United States mail (Receipt No. P 977 270 309, return receipt requested, restricted delivery); that thereafter he did receive a return receipt card bearing the signature of Carolyn Eash, Defendant herein, and indicating receipt of said copy of LAW OFFICES MARLIN R. McCALEB the Complaint on February 12, 2000; that the said certified , LAW OFFICES MARLIN A. McCALEB ~ ^<'. ....J ".' "',.P.. -_","" ;;"",,,", "'--', "I',~,--'~'" _';;;" ~ "" mail receipt and return receipt card are attached hereto and made a part hereof, marked Exhibit "A". 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., Section 4904, relating to unsworn falsification. Date: February ~~ , 2000 Marlin R. McCaleb -2- ",--" TO: P "17 7i!70 309 Carolyn lone Eash One South Chestnut St. Dillsburg, PA 17019 SENDER: REFERENCE: ""~'-:'~~"F PS FORM 3800 SEPTEMBER 1995 ,,",\ago RETURN RECEIPT SERVICE RelurnRecelptFee Certified Fee Restricted Delivery Total Postage and Fees US Postal Service Receipt for Certified Mail ! No Insumnce CoveI8g8 Provided i Do not use for Intematlonal MiIII Hi .andenter nemeandaddresson~ereverse. q 1. ~~m'"'i"'P\W~No/,p~~fo'~''I'8~'1'"ll~~ i2a R6tumrei:eiplWASpaId'lo'Ottim,cil'lnaiiilig. o 2b. Relum'receipt showing addressee's addmss WAS paid for al lima ofmaJlh1g. 3. AIIIcIeAddressedTo: CIH<o<.'y-.; -qdKh'} EAS4J OlJe S' ('1-I~STP<lt Sr DIL.LS~<lJi-c. PA 170/9 1(~>r'('/C Ifr;P ~;,;.",,,",-_.'- LAW OFFICES MARLIN R. McCALEB EXHIBIT "A" , . . ' 0 "-< OZOOH ~ to HOHCZ ::0 (I) <:. <::.: 0 (I) H HtJjf-3 ;:: t" to t""'t"too:: '" ~ ~ >< o ::oto n OJ Z 0 :O<O""t" ~ ~ OJ to 000""0 Z N" H H "" "3 "3 Z 0 n - " 0 0 Z HI HOC '" '" ~ ~ Z 0 0 ::0 m c" '" z to to Z-.JZO>3 ~ ~ r OJ' ~ H "" -.J 0 P P '" '" ~ m ~ f-3 to ~ (I) I CO I CO " m ;:: '" 0 "" Ul 0:: ZOJ '" 0 ~ " " 0 0(1) . '0' HOt"f-3 z X _ n " Z N Z '" f n OJ CD 0:: f-' ZH",,><O '" '" '" " '" m' Il> <: :;;:, 0 ~ 0 ~ " '" (I) CD 1-" OH ~ " r ~ '" ~ to ::l ::J Ht" '0 Z "l '" ::0 p.. rt <: ':':10 ~ <: Il> 1-'- 0f-3 ZZ ~ H ::J m ::0 to Z 0 rt m 0::0 (1)'0 0 to to:': ><t" '" '" t"to <::0< :0<(1) Z HO :0< OJ () c ~ffi C.) ,':;- :~; ~ ':-::J C::J -'1 ;Tl :::.;:,l f'\.j f'~ <'. ,1.:>-. :'.i: - .. ..,.- 5 .,