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HomeMy WebLinkAbout00-00835 - .~ . . . .. . . . . "" ~, > ... .. Of. Of.:ti0f. Of. 0f.0f. :ti . .. .. :ti :ti:ti;liOf. . . IN THE COURT OF COMMON PLEAS . . . . . OF CUMBERLAND COUNTY STATE OF . . JAN L. WARNER. . . Pl"i"tiff . . VERSUS . BARRY L. PARSON, . . Defendant . . . . . . . AND NOW, . . . DECREED THAT . AND PENNA. NO. 2000-895 Civil Iv . . . . . . . . t ..v1J( fA : , 4, IT IS ORDERED AND ; . . . . . DECREE IN DIVORCE . WARNER , PLAINTIFF, BARRY L. PARSON , 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; . . . . . . . . . . . . . fJ()1Jr: ~ ~ . ~. ~ OTHONOTARY . . . :ti :ti :ti"':ti:ti :ti "'''' T. T. ;Ii;li T. T. T. T. T. ;Ii T."'T. . . . . . . '" "':ti"':ti :ti :ti "':ti :ti J. , c ~~ ;liT. ;t'", . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . d, 'f?! d' .()/ .>' '--' '-'"'"''' - . ,~ . .;. ':J- "'il' thf,~~, $,~~~ ~ ~~?t~?t ~ ""..~!!i ~~" ~ ",,"~~lI1nl!l_l!l!j, _ ~=" . - JAN L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARRY L. PARSON, Defendant NO. 2000-835 IN DIVORCE CIVIL PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: 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 3301(c) 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: February 19,2000 by restricted, certified mail, return receipt requested 3. Date of execution ofthe affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff January 22, 2001; by Defendant January 22,2001. 4. Related claims pending: None 5. Date Plaintiffs Waiver of Notice in !l3301(c) Divorce was filed with the Prothonotary: 1,/1./ ;'Cfi / I ( Date Defendant's Waiver of Notice in !l3301(c) Divorce was filed with the Prothonotary: :llz/zcaf , ; FdJ'. Date: l,.......n~r~, 2001 By: ~_""IIl;I1i"","_olliliI;Ij'''-'''''''1IlI!IilI1i ~JolIO!~I{l",,,,,'.J'iil;l:lM-~~ ""~~~lOlI'''' ~.~ . - .c,; "'I 0 0 C) c: w'l' g ...., -oCC ,." mrn co 1~l Z:U Zl); I ';:'~8 ~:;.: N ' , ,',."'-, kC "::.::1 '~I f~2~ ~o -,,' 0 )>c c:/'T: -.j Z "'- =< 0 :1J ~~ . ~-' -~,' ), -,"" - '~)~ C'''''' ',_ JAN 1. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Defendant CIVIL ACTION - LAW ;;"000 - 8'35 NO. CIVIL TerM IN DIVORCE v. BARRY L. PARSON, NOTICE 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. 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 the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 .~ ." JAN L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW BARRY L. PARSON, Defendant NO. CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE \ c I. Plaintiff is Jan L. Warner, who currently resides at 49 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania, since November 4, 1999. 2. Defendant is Barry L. Parson, who currently resides at 130 Crain Drive, Carlisle, Cumberland County, Pennsylvania, since 1994. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on November 4, 1994, in Hagerstown, Washington County, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 require the parties to participate in counseling. jJ " " 8. Plaintiff requests the Court to enter a Decree of Divorce. ANDREWS & JOHNSON 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 18 Pa.e.S. S 4904, relating to unsworn falsification to authorities. Date: l- /0 . 00 ~AA--- c7' W~ J . Warner, PlamtJff > Z dl>\:l q~~~~ ... ~ (,n Q ~ -....:JtIl..........< ~--z N!06\JtyjOO ~~~~! .........."'~O N""-J......... <>>S"'r-<:;t <>>@>Z ~:ECIl o Z (") a '~:1 c CJ ? ?-:: ..,., ~ -.. r"~ j"1"1 75 rl-lr:", "~"1 ~~~ co 1---- fI::. ~ cg "I1"!-, - '-;::--:1 011 ; ~~ f,,~") -0 ~L: -0 --"- , Gj ...... 0'1 g) ?~~ :J!: - :-::J ()J u :",:,':-) llJ (fl )>~ (-,-; ~' ~ ! '-- .. 5~ ()J 0 -i7 2-= => ::;:I :;.J ~, -< j. , "0 lli!;lt.";l;.i ... " JANL. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARRY L. PARSON, Defendant NO. 2000-835 IN DIVORCE CIVIL AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code was filed on February 11,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 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 Pac C.S. S 4904, relating to unsworn falsification to authorities. Date: {J /- ;p. - oj II$<-' r/ W~ fl Jan L. Warner, Plaintiff ~~.~,.. "' "1!liIIl!II 'ftllI.;i.~J>.. = """"~ .".,.".~ !>Oii!l4 ~ ., '-.' ,,~ ~, j .~" ^ .~"~'" .. . () c: :-os: mCD ZQ, :;?''-' (f'j c- r:s;'^ Iio 2'0 ~("'-) c" ~ ~ '::::. ." o - ,~ ---) ,., ;::j CO I /'.c, -' . .'. r~,:__-:: ,-j" ;_! c-i ) j~ ~!~) tJ~ C:5rn -; :1:::. ':;'::;1 '"< -u ::n: - \'" ~~ tIEJ:~,. r - JAN L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARRY L. PARSON, Defendant NO. 2000-835 IN DIVORCE CIVIL WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a [mal decree of divorce without notice. 2. 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. 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 Pac C.S. ~4904, relating to unsworn falsification to authorities. Date: / - ,,).2 - 0 I ()~ I1z/AA~ J~L. Warner, Plaintiff U~_~Jil1Jj!_~u,"_lliI.m~~~Mil!ilw.",.~..._.'J~"~-~, ~ l"'ir~ ~.~<~ ... , () C _3': ut:o 92r~ :z: 3:, enS:: rs ~~:; ,,0 ~() ""0 ..PC 2' :':;! Q '\D o ..." f7l co , 1'., c;- -q :jl "" _I;~ ~~\ ..J i_~5f:;? ::;! :0 -< ;; - .. ,'. " -" A fi JAN 1. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARRY 1. PARSON, Defendant NO. 2000-835 IN DIVORCE CIVIL AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code was filed on February 11,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 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 Pac C.S. ~ 4904, relating to unsworn falsification to authorities. Date: /-::n -";}. (J()J ~I.~ Barry 1. Parson, Defendant ~1"""''''.'''"'1itiiillllllll "'lIIill"-"""~- lWi-'- l''''''''~~'''~~'''"~-~ ." ~ ~~ ..'"~ ~" t'v'- t (') c::> "~ ., c: ~ - ..." :s.. -,--I -oCC r:; 'i':J mm co Z:.'C,\ ,- Zr I '.1; (j).d::: f') , CJ -<.:-.:... ~;d, ;<'C:) <:; ~O ~ ~O Pc: Z .0 j;! =< ::0 \.0 -< . ~ ,-.J . ~ t, " " . JAN L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARRY L. PARSON, Defendant NO. 2000-835 IN DIVORCE CIVIL WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE 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! 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 Pac C.S. S4904, relating to unsworn falsification to authorities. Date: 1-22-;)oa1 ~j,f ~ Barry L. arson, Defendant ~~......_" ~ ,~.....""..~< ~ """'"~ ~'" ''''''''''~''_f"1lil1''''' " 2 s:- -0'(." m' :z::[J] -;.-'-".; <.C' U)~.;: ;::;" ",0 :&=c 5€c5 c:: ;z :< - ~.. :::> to - - -', c;, - ~~~ .." '" Co I f\) ,_.',-r; '- -I) -"". _-!c~ ;~1'!t1 s.j'-'~; C3.h~ :::::--! :D -< - . ~...... ~ .-1.............. "~"~!![1 " 1 .! JAN 1. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARRY 1. PARSON, Defendant NO. 2000-835 IN DIVORCE CIVIL AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 23rd day of February, 2000, I, Ronald E. Johnson, Esquire, attorney for Jan L. Warner, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter, upon the Defendant at his residence at 130 Crain Drive, Carlisle, PA 17013, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on February 19, 2000, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON Sworn and subscribed to before me this c;;L3 day of~bll:.Y~'f ,2000. ~~ , oaryPu ic NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 26, 2003 Member, Pennsylv~nla Association of Notaries o Complele llems 1 andJor 2 for additional services. Complete item!?, 3, 4~, and 4b. CI Print your naml:! and address on the reverse of this form so that we can retum this card to you. CJ Attach this form to the front of the mail piece, or on the back if space does not permil. o Write "Return Receipt Requested' on the mailpiece below the article number. C The Return Receipt will show to whom the article was delivered and the date delivered. . Article Addressed to: ~".1- Pt!tr60f'l \60 c;rA i.., Dr. v{... ~ ~,...\\Sk (PA (10\3 .. GI- " 'ijj GI l!! GI ~ " = SE,NDER: e o " J!! " .<,0. E o <> 5. Received By: (Print Name) ~ " o >- .!!! PS Fonn 3811, December 1994 4a. Article Number :z. 33? 4b. Service Type D Registered D Express Mail Retum Receipt for Merchandise [J", J I also wish to receive the follow'"'), ing services (for an extra fee): 1. D Addr ress Restricted Delivery )!(certified D Insured OeOD 1~~()V 8. Addressee's Address (Only if requested and fee is paid) 102595-99-8-0223 Exhibit A Domestic Return Receipt ~"he =~ 'l cD <>. '1: GI In a .~ <> GI 0: e ~ 'ii 0: '" c 'ijj " .2 " o >- '" Iii .c >-