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HomeMy WebLinkAbout00-01093 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;li:.l''f'+ . '" ~ ~'" + ~ :t + . '" + +. 'f.: :1::+ +++ + +;Ii + + '+' 'f- . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. WTT.T.TIlM r nVIl"RMIlT\T No. ::>000 1 OCr:! I'l,,-il1tH<'" VERSUS DEEDE LYNN DYARMlIN , Defendant DECREE IN DIVORCE ~V\ ~ AND NOW, IT IS ORDERED AND WILLIAM c. DYARMlIN DECREED THAT , PLAINTIFF, DEEDE LYNN DYARMlIN , DEFENDANT, AND 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; Nnn~A ---~ ... \- . J. . "':.; + 'I' '+' '" :i''t':f.+ :t;++ + +'1''1' '+' + +:f. + . . '" '" + + :1::1':t Of' .. . + + + + 'I' '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;to'" +:1; cr/;;s /DO - . - ''''....'~ .' ~l . "" ~.., <:..~ C~, Cb/~,Y3,;{.l~~~ Ml.y OII;:..LJ_ A.:::o/.I'C't:-m~i{c0...-Io ~ U~'1 I " . ~=,. WILLIAM C. DYARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1093 CIVIL TERM DEEDE LYNN DY ARMAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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 S 3301(c) 1]91(<1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on Mach 1,2000 by certified, restricted delivery, return-receipt requested mail that was signed for by the Defendant. 3. (Complete either paragraph (a), Dr (b).) (a) Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the Plaintiff: September 7, 2000; by the Defendant: September 7,2000. (b) (1) Date of execution of the Plaintiffs Affidavit required by S 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: none 5. (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by S 3301(c) of the Divorce Code: by the Plaintiff: September 7, 2000; by the Defendant: September 7, 2000. Date: September 13, 2000 ~j]; homas S. Diehl, Esquire Attorney for Plaintiff , . . C) = s;;;; c <:::> 5.., (f) --, uG:l rr1 11.~~_: n"1f~': v , :z: ._.. --;:1:T1 ZC GO ",-jO ~~2: i:1Q ~c. -0 (:'~~ ;-~ ~-. == ~C:; N :~_rrl >c: '-' :z ,....." ~ :::! '''' l... \ WIllIAM C. DY ARMAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- ICJ9..3 CIVIL TERM DEEDE LYNN DYARMAN, Defendant : C~ ACTION - LAW : 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIl'v1 FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU 1M Y LOSE THE RIGHT TO CLAIl'v1 ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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, Pennsylvania ]7013 (717) 249-3166 .. .... , WILLIAM C. DYARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00- /6 '1.3 CIV1L TERM DEEDE LYNN DY ARMAN, Defendant : ClYa ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, William C. Dyarman, through his attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, William C. Dyarman, is an adult individual who currently resides at 28 Big Spring Terrace, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Deede Lynn Dyarman, is an adult individual who currently resides at 8 Cedar Street, Newville, Cumberland County, Pennsylvania 17241. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 18, 1986 In Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. -. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, William C. Dyarman, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. g3301(c) or g3301(d) of the Divorce Code. Respectfully submitted, Date:_M J~OJ omas S. Die Attorney for the Plaintiff 401 East LDuther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX , VERIFICATION 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.C.S. S4904, relating to unsworn falsification to authorities. itl~ 1:., }"~A)wN'"' WILLIAM C. D ~,PlamtIff ,- '.. \\lLLIAM C. DY ARMA.N, Plaintiff : IN THE COURT OF COi';fMON PLEAS OF : Cl.TMBERLA1~D COUNTY, PENNS\'LVA..l\,'lA. v. : NO. 00-1093 CIVIL TERM DEEDE LYNN DY ARMAN, Defendant : CIV1L ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT ......... 1. A complaint In divorce under g3301(c) of t..lte Divorce Code was filed on Februa.ry 28: 2000. 2. The marriage of the Plaintiff and Defendant is i.."Tetriev~ibly broken and ninety (90) days have elapsed from the date of filing and service oflhe Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intemion to request ent!y of the Decree. I v€.l"i'rj (,'tat the statements made in t!us a..'TIdavit are true and COlTect. I \IDderstand that i~i!se sraten1t:,uts h~rein are made subject to the pe'nalties of 18 Pa.C.S. S 4909 ~'e]ai.iIlg 10 unS"VOrti f2.1sificatioc. i.o u-i,yt~~()rities. Date: _~..\. 'l~oo () ~~_k1L~~__. . W1LLIAM C. DY1\.lu'1.A..."-i. J:'Jamtlff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF "', mVORCE DECREE UNDER ~3301(c) OF THE. mVOHCE CODE 1. I: cansen:, to the entry of a Final Decree i11 D.i vorce "'.;f:1out :lonce. 2. r understand that I rnay lose rights cow;ernlng alirnon)'" division of prc.perty, ia'N"':/er~~ f~es or t;xpenses if 1 do not claim them before ~ cli'/t}:'(;e is granted. 3. r llllders;and that I will not be divorced until a Divorce De.;rce is entered by ,h(: Court amI a copy of the Decree will be sent. to me immediately after it is filed with the P.fothonot;:-~rj'" . I vedry t~ldt the statem.ents made in t.~is affidavit are true and correct. I ll...rJ.derstfU1d that ff1~~{:- ~h\r.e:rnc:nt$ h~rein are made subject to th(;~ per:aitie~ of 18 P2~..C.S. ~ 4909 relating to unsv./orn ~h.~si,{icu.titH1 !:..1 au.th.::rities. Da!c:.~~,--~.U;..QC>____ ~.LJd~_._.____ WILLIAM C. DY ARMAN, Piainriff . o c;;;; v~F:: n~lr.(\ Z::;:: Z,- ~~t !2G J;;c . ,'~> )>~ ~ "'", Cl o r./' rr. v , CO ~ ,--, -n ~;-<.D :.~if1 ~~ _._~ l n '-' ~ ...,..,; ~ -~ U1 N WILLiAM C. DY ARMAN, Plaintiff : IN THE COURT OF COM:M:ON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANiA v. : NO. 00-1093 CIVIL TERM DEEDE LYNN DY ARMAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under g3301(c) of the Divorce Code was filed on February 28,2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 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 Fa. C.S. g 4909 relating to unsworn falsification to authorities. '}-7-tJcJ lJ~04 ~ DEEDE L. DY , Defendant Date: 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 Final Decree in Divorce without notice. ? I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. [ 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. S 4909 relating to unsworn falsification to authorities. Date: Q---1-oo N, Defendant o G: "t.7"> r;iF"'. :?;::J~) <f~ C?,,"c. ;=:$-2 ~t'.:.. :s iG;;O P(;=:l ;;?: =< c_':;. C:> '/.) :-'1 --0 I <:0 .~ ~_*t -"'I -.....E; '-' --0 :::!<:: .':j~d ~ft~' ,:::; ~ -OJ -<: 1":i' (.0 ~~...}, ""'-; ... , * WILLIAM C. DY ARMAN, Plaintiff : IN THE COURT OF COJ\1}.llON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1093 CIVIL TERM DEEDE LYNN DY ARMAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 3m day of March 2000, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, William C. Dyarman, and states that he personally mailed a certified copy of a Complaint in Divorce to the Defendant, Deede L. Dyarman, at 8 Cedar Street, Newville, Pennsylvania by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on March 1,2000. Respectfully su mitted, }LJ[j) 'Thomas S. Diehl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 240-0893 - FAX ~....." ~.... ~ Z 339 067 256 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse Sent to DEEDE L. DYlIRMAN Streel & Number 8 CEDAR "TKliliT Post OHice, State, & ZIP Code Postage $ .55 1.40 Certified Fee Spedal Delivery Fee '" '" '" Restricted Delivery F~e 2.75 .~ Return Receipt Sh~1ng Who <( Date, & Addressee"siAd ess o " o TOTAL Postage & F es ex> , C? Postmark or Dale "'- E \"\ <5 ',\, ~ " (/) ...,> a. .~.:::-:: " ,., 'a; SENDER: 1:l . Complete items 1 and/or 2 lor additional seNices. ou; . Complete items 3. 4a, and 4b. Q) . Print your name and address on the reverse of this form so that we can relurn this ~ card to you. Q) . Atlach this form to the front of tha mailplece, or on the back If space does not e permil " - Q) . Write 'Return Receipt Requested" on the mai~lece b~w the article number. :5 . ~~ffv~~~~ Receipt will show to whom the article was ellvered and the date '.' ,i :' ~ I also wish to receive the following services (for an extra fee): 1 . 0 Addressee's Address 2}[X] Restricted Delivery Consult postmaster for fee. 4a. Article Number Z 339 067 256 4b. Service Type o Registered o Express- Mail o Return Receipt for Merchandise, 7. Date of Delivery -c:/d 8. Addressee's Address (Only if requested and fee is paid) g 3. Article Addressed to: ." " ;;; Q. E o u CJl CJl w a: Cl Cl .. z a: DEEDE L. DYARMI\N 8 CEDAR STREET NEWVILLE, PA 17241 Je~\'er W addressee onlll -'; ~ t I i'- , , I"~"~. 'iI ,\ , .. u .~ " CJl Q. " u " a: <: ;; ;;; xx Certified a: o Insured -~ DeOD ~ - .E ~ o ,., '" <: '" -" I- < " ..,': 102595.98.6-022' Domestic Return Receipt