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Home My WebLink About00-01422 , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF HELEN C. WARD Plaintiff VERSUS DUDLEY F. WARD Defendant AND NOW, September PENNA. No. 2000 - 1422 CIVIL DECREE IN DIVORCE z 'I" ,2002 ,IT IS ORDERED AND DECREED THAT Helen C. Ward , PLAINTIFF, AND Dudley F. Ward , 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; None. , -,- " By THE COURT: .f ,/1~ ~~ PROTHONOTARY , , , , ~_. - -. '''1 " - ~--- '-"f- , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , . . . , , , , . , , , , , , , , , , , . , , , . , , , , , . , , . J. , , , , , , , , , . , . , , , ,,' ~, ~1B1_1~"'""'.'--' i' I""lil!illllllill!i-'~ _il"~~~~IiiL,~ L -1 --~_.,- t[. .;J.t/'tJ ;) tJ -,;)l{-Od I --. - ,--~ Iiii&'. -~~~ ~ .1Ii1li!.1_~ . ,-, i ':.l<i< j.' ~". !\...~. _,I w-~ ~ Wa7f t1~ 7Z~~~ Z4~ " , HELEN C. WARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000 - 1422 CIVIL TERM DUDLEY F. WARD, 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 Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: The Defendant signed an Acceptance of Service form on March 13, 2002. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on September 10, 2002; and Defendant on August 15, 2002 . B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce Code: None, Respectfully submitted, .~ \ .. Robert L. O'Brien, Esquire ,'-- ~ <" , ,'~ '" -.^'- ,Jr' , 11IIII ~~~.~ ____,11]1....., ,~_.,...."., - -."",,-~" ~'". I~' ',.."~ , 0 '_J ;::; C r....) " S. U') -eG' ;-., fT1P1 -0 2:::;:, ~~?i -' r;::c.: ~l:' );:;:C\ :x ~;Cl r;:- J:'c: --, ~ ::> ;c~ JJ -< <::> -< 1llJIII. ,:_,m~,Mflj~i1~n'lf'~t.-'l-'ll~~~~~lJlliI, '"~"~...".,.... "'I.~ . HELENC. WARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND-COUNTY. PENNSYLVANIA v. NO. 2000- /</;;2,;). CIVIL ACTION-LAW IN DIVORCE CIVIL TERM DUDLEY F. WARD, Defendant 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 c10 so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. Ajudgment may also be entered.against-you-foI- 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. Alist of marriage-counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM,FORALIMONY,.MARlTAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DNORCE OR ANNULMENT IS GRANTED, YOU MA-\' LOSE TlffiRIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFEORD-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 Clldisle, PA- 17013 Telephone: (117}249:-3166 ;\ ~, -, ~ ^.," , . , ~".- ", ~t_~,~& . ".- ~. .",~,",'" ~-- '. ,.- . 'J ,'- . ..' "'" - '. v. INTHE COUR:r OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- /,-1 :2 07- CIVIL TERM HELEN C. WARD, Plaintiff' DUDLEY F. WARD, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301(C) AND 33:0l(P)OFTImDIVORf:R CODE 1. Plaintiff'is Helen C. Ward, an adult individual who currently resides at 645 North Middle Road,. Newville, Cumberland County, Pennsylvania. 2. Defendant is Dudley F. Ward, an adult individual who currently resides at 645 North Middle Road, Newville, Cumberland-County, Pennsylvania. 3. Plaintiff' and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous-to- the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 27, 1969, in Baltimore, Maryland. coumI,-DI~CE 5. Plaintiff hereby incorporateshyrpfprpn('e paragraphs 1 through 4 above. 6. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 7. Neither Plaintiff'nor Defendant is inthe Armed Forces of the United States. 8. Plaintiff avers, that the marriage between the parties is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. .~ml~ 'III!! 11 ~ WHEREFORE, Plaintiffrespectfull~requests-this-Honorable Court to enter a decree in divorce. COUNT Il-EQUll'ABLEDIS'IJUBUTION 10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above. 11. The parties have ac<!, jiredpersonal pwperty, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiffrespect:fully requests-this-Honorable Court to enter a decree which effects an equitable distribution of marital property. Respectfully submitted, ;;;:;;Ci: David: A. Baric, Esquire LD. if44853 11 West-South Street Carlisle, Pennsylvania 17013 (1'17).249-6873 Date: 7/11 n:; Attorney for Plaintiff, Helen C. Ward dab.dir/domestic/wardlcomplaint.pld - """"'- ""'",1, '-'-,-l-''''''-C -, - -, . "_", "=M'- "" .0-- -., ,__,__" -, c.'" ~,,- '_c-,- .'., ",'.'. n ~ VERlFlC..Al'ION , ,i 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 of18 Pa.. C.S. ~ 4904, relating to unsworn falsification to authorities. I , I' "i :i! ~.e'.~~ Helen C. Ward Date: 3- II ~ 1 tJ1; '~19V " """1 ,-,.". v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-1422 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE HELEN C. WARD, Plaintiff DUDLEYF. WARD, Defendant ACCEPTANCE OF SERVICE I, Dudley F. Ward, Defendant in the above-captioned matter acknowledge that I accepted service of the Complaint In Divorce on or about March 13, 2000, pursuant to Pennsylvania Rule Of Civil Procedure, Rule 1930.4 (d). ~,~~ >"'-,,'''''--- J ~,e .~o" I \"- M/_!IlI:lM. "'9'~"",,___, ~h _mTi -J' ~,;- ' ,,, "--nil{'" 'J-,-';,,~'l_,,'''''~;'~~_ .I*_l'[ji~~'il () (.::; C 1'0 ~ S Cj) -u ~1: '" rn -0 Z .J_ zro ~~~~: -~.---; ~<\....: -Tl )>c.:: Z() w Pc::: Z -:.n =< , 0 .4t,:Qj1 I1Ii~flN-MM-.o1' _ ~-~~ ""','OTf~ I , , v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- tV;),'). CIVIL TERM HELEN C. WARD, Plaintiff II DUDLEY F. WARD, I Derendant I, CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 10,2000, 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 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. 5. 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. ' 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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 to authorities, " Date: ~ II, tPtJZ- :d~ /!, J1/~ Helen C. Ward !<~'" ^ ~.~ 'II!!II ~. 1-- ., IRN!I_~ n - ~~...,..,,!-~- .- .~ ~",-",-.' 8 ;;:~, "'1:,.." ItI,QJ -.:;.-/,1 ~:t'"",' ~ r CI5> ~i~~~ ~' C;:C') :J;:C5 C" ;e:' -; -< h :.0 '-.1 ".~r."~""o" --,--"",-~ ~ ''''''"'-'[fi'c Litl o f\) CI} f71 -0 o -'1 - C ~~j h:r:JJ r-- ,Ol"n JQ -:~J ,.!" -~:j~ '~5:k .>"0 C'5l"'1j ,..., 1; -<: "-, .:'.:ll.-""' ::!t S? . . $~1~10_"_~~,"""'i$l!.ilI:!~!~~~ II " I ,I I HELEN C. WARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1422 CIVIL TERM DUDLEYF. WARD, Defendant CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on March 10, 2000. 2. Defendant acknowledges receipt and accepts service of the Complaint on 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a [mal decree in divorce without notice. 5. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 6. 1 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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 to authorities. Date: A\')L1, \5. Z-w2- ~~f~ Dudley F. Ward I', " ! !fl.. ~ -rm- " ~ .'"1 ',r "'!"", lJA.~~IJII!I_ ". .'<: ...~ .", -~ '"'-,"'~' ".. - '.''-- - I"v'h--' ,. - '--t 0 0 0 C N " ? (l) uro ...---\ l'Tl ~i :JJ nlm " 2::;::1 f- "'-I:.:" "TJrn ~~;-_: <::) ':"0 ,.-'ti;;;l :;2(:, <", ':0 :~~~ ~0 ?;c'i ~. c,,<(') )>c:- ::::> r5fn z ,.... =< "'" ?i5 .,..J -<; f'1!1\!IHftiI,_ I'~"-:~~ "',.,.-.....-