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Home My WebLink About00-01517 ~.,.:,.:.~+:,. ':'~<:'~+:<::'~+:"':'~.:<:::'~.;<::::'~<:X+:';:'::'~~':'X.:<:"~.:<: ,..~;.":""~+:,:::,~.:,,,,,,~,,,,:..,~.X,,~+:,,,',~+:,:::~r::<::+:<:::''''Kx.:;,~.,.;,;";~.x".,.;,,..x.;,;:.:.:.cK:::'~.:;:;:ll ~ i v ~ ;..~ ~ ~.~ ~ ;..~ ~ ~.;; ~ ~i ~., ~ ~.~ ~ '-,,> ""S * ~'s ~ ;..~ ~ ;..~ ~\ ts ~ i ".~ i's ~ ~fi ~ ".~ ~ ~.~ ~.~ ~ ;'0\ ~l , ,"- ~~ ~ i~; ~ N ~ ~ , ~ ~.~ ~ i'\ ~ ~ ~.~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. .uM.!\Rqi\ ,JE.!\N.?l'9TI?,., Plaintiff I II II No. ...fQQ.9.::J..?F ............ Versus ...R:J:c:HA,RD.1\IbE;r'LSl'9TIS,. , Defendant DECREE IN DIVORCE AlA AND NOW,..... .-;.;~. !?.......... ,~.~,"i~~ ord'er~d and decreed that. . ~~~:'.~. ?~~? . . . . .. . . . . . . . . . . .. .. . . . . . . . " plaintiff, and, .. .RIC~ ..AMEp .~~~ . .. .. . . .. .. . . .. . . .. . . . . . . .. . . . . . " 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 .......................................................................... , i'~ * I to." ~'s ~ i'~ ~ ~ ..0,; ~ ~ ~ .. I . - ~ ~-~--~~~~~~~~~~~~~~~ "n___.. Prothonotary '-" ~'- ~,~ " " , ~ v ~ ~." ~~ ::'::+-:':::",::'::.X'_:.::.:., :-:-::+;< '>:'€'..: ').:.+;. _ ....:,.;...- ,:'::.~',:. ',,"::+::'.: >.::.::~~ Attest: f}~ ,..-" , ~ f _~ .~ . " "--' ~.~ N ..,." ~os ~ ;'Os ~ ~ ~ ~o~ J ,"'. ~ ti l'.~ ~.s ~ ~,,; ~ i i 't.~ ~ i ~.~ ~ ~o~ I i ~~~ i ~.~ ~.~ ~ ,'" a ~ ~ ~.~ ~o~ ~ C~ w ~.~ ~ ',.", $. ~.~ i l'o~ t'" ~ ~ ~.~ i '.' ~.~ ~ ~ ~o! ~ ... J. ~ ~o~ ~ '.. ;i;. ... r.' .~ ~"oJ....'~ ~~ ..,~~.. '11:a-~ - ~ -.~" 1,_ .' ,.>-~ <-- -. =' -" " - "^-- . <" , I ., . t./s.6t} M-'L'&ff~~4 ~ ~ /s.-.t'Jtf ~~ ~~, ~,y- ~ , MARCIA JEAN SPOTTS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 1517 CIVIL TERM RICHARD ALLEN SPOTTS, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please 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 330 I (d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, return receipt requested on March 16, 2000. 3. Complete either Paragraph A or B. None. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: B. (1) Date of execution of the Plaintiffs affidavit required by Section 330 I (d) ofthe Divorce Code: March 31, 2000. (2) Date of service of the Plaintiff's affidavit upon the Defendant: April 4, 2000. 3. Related claims pending: None 4. Complete either (a) or (b). A. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Regular mail, May 1,2000. B. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary; Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary; ,~~ ...:;;-7.;~"':""~~-"''''-':'.'';~''- ':;J \ Telephone: (717) 243-7922 Richard Allen Spotts, Jr.. #DY0436 301 Morea Road Frackville P A 17932 ".',--, . , -~~._--_. ,-,,,,,,,,.,",,,;,-, ,''''''-, ,---,'- Kayer and Brown Attorneys At Law A Professional Corporation Liberty Loft 4 E. Liberty Avenue Carlisle, Pennsylvania 17013 e-mail: jkayer@epix.net May 1,2000 RE: Spotts vs. Spotts - In Divorce Dear Mr. Spotts: -~'-,',-'-"-""",,...~ ~ FAX: (717) 243-0946 Decree. Enclosed please find the Notice ofIntention to Request Entry of3301(d) Divorce Thank you for your attention to this matter. JJKlvj g cc: Marcia J. Spotts (w/enclos.) , - ~ Very truly yours, ~,:,::,. .' , vs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENN$YL VANIA : NO. 2000 - /6/7 : CIVIL ACTION - LAW CIVIL TERM MARCIA JEAN SPOTTS Petitioner RICHARD ALLEN SP011S, JR., Respondent : 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 armulment 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 grounds 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 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 TillS 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. Court Administrator - Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone (717) 240-6200 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire Attorney for Plaintiff Liberty Loft 4 East Liberty Avenue Carlisle, PA 17013 (717) 243-7922 \1I.P..,.,.,.. ~ vs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - /SI/ : CIVIL ACTION - LAW CIVIL TERM MARCIA JEAN SPOTTS Petitioner RICHARD ALLEN SPOnS, JR., Respondent : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) and 3301(d) OF THE DIVORCE CODE COMES NOW, Plaintiff Marcia 1. Spotts, by and through her attorney, James 1. Kayer, Esquire and avers as follows: COUNT I - DIVORCE I. Plaintiff is Marcia Jean Spotts, an adult individual, whose current address is: 229 Peach Glen Road, Gardners, Cumberland County, Pennsylvania, 17324. 2. Defendant is Richard Allen Spotts, Jr., an adult individual, whose address is: #DY0436, 301 Morea Road, Frackville, P A 17032 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 13, 1994 Clark County, Nevada. 5. There have been no prior actions of divorce filed in this matter. 6. Plaintiff or Defendant is not a member of the United States Armed Forces. 7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) and Section 3301(d) of the Divorce Code. 8. 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. ^:':"~~p;II,~,... I' ~- i' "" - WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, ,./ Date: March I,) ,2000 , - ,~ .'- ,. ,,- -r VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 P A. C.S. S 4904, relating to unsworn falsification to authorities. Date: ~ eA J ,2000 IY:)/J /(~~~ -9p%t15i ;-1'" , "'"""'I ... .. MARCIA JEAN SPOTTS Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : NO. 2000 - 1517 CIVIL TERM : CIVIL ACTION - LAW RICHARD ALLEN SPOTTS, JR, Respondent : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about August 25, 1997 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 4. No prior actions of divorce have been filed with the Court. I verifY that the statements made in this affidavit are true and correct. I understand the false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 6-3/-60 ftiI&~~ MAR A JEAN SPO S ~ , . I". , , MARCIA JEAN SPOTTS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : CIVIL ACTION - LAW :NO.2000-1517 CIVILTERM RICHARD ALLEN SPOTTS, Defendant : IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF 3301 (D) DIVORCE DECREE TO: Richard Allen Spotts #DY0436 301 Morea Road Frackville P A 17932 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after May 22, 2000, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter- affidavit which you may file with the prothonotary of the court was received by you on April 4, 2000. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to as for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. Court Administrator - Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone (717) 240-6200 il'-:' ''" ,~~ "" ,'''" ~ , ... ~ aComplete items 1 and/or 2 for addW_ _. I aI80 wish \0 receive 1M II aComplete h.ms 3,.... and 4b. following services (for l/tJ,', 1.:~!Print~3;~~addl'8B8onth.l'8vera.Ofthi8form80thatW8canretumth18 extra fee): ~.-~. B !I! a~lonntothefrontolthemallpleco,oronthe_nsP8C8_not 1.0 Addressee's Address ';: ! permit., .. .. aWrile'R_Iil~,ll,. , . on the maiplece below'" antda numllar. 2. lJlo.n...lill'ted Delivery 41 ~ a1lleRab\ln'Rec8lplWlII'_ Whom aJtId.wa.d......dandthedele 15- c dallv8red,":' Consutt postmaster for fee. : 3. Article AlIdressedld. . eNumber 3SS Cilo3 ! 1M eh1i(O Qtkr\~1rs, 4fJ.Service ~ 'i ':! ~ D~O <f 310 [J Registered ~ . '!. ':2 ~ q ElJFSS Mell red ';,1 f-?2;,!!\O\(J1.C\ D 1tI,".l-~!Bllllf'rM.I<hIRise [J COD ~ ~~('uLJ(Qd t~, n'13~ 7.~ ~11very i ... w-( Ii S \.'3"'&- 0 0"'-. ~ :~ f.>.v4\...\\V'~.eL .e.1.,<b--' 102"ca.Q119 DciJlne&litAetom eceipt , ," ~ ., "~:_""_"_. J~IJl!l.~ _ ~~~i\lII'~""~F1'''~~~HmRm!~~IJII"""!,,,,,"",",,,_, ':_~""'"'r"-' .,.,. ~ MARCIA JEAN SPOTTS Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : NO. 2000 - 1517 CIVIL TERM : CIVIL ACTION - LAW RICHARD ALLEN SPOTTS, JR., Respondent : IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for plaintiff, MARCIA JEAN SPOTTS, and that he did serve a true and correct copy of the Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, RICHARD ALLEN SPOTTS, JR., on March 16, 2000. The receipt form is attached hereto. J ~(lm to and subscribed before me thid3 day of M , ~ .;', ------(- , \'fl<J.:.-e (Vl~ ~tIO~C NOTARIAL SEAL DENISE PINAMONTI, Notary Public .Carlisl.. Borough, Cumberland Co u.. ., ,.~. -;.;:. unly . , . . -