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Home My WebLink About00-01971 - ,J..C." )::C~:, .:.~:+::( '}:e~,': :;~::<<{>::.::( ~;!::.::{'::.:C~::::::"::C";~:::~:+::.~::XC~;:'~;.::C.:,: ,;~::.::~:' ',';::+::.':\.::.::.': :':,;::c.{ "';>>Zo:":~":+::( ::~::c;( ::.~:::C';,-::K~::~::C,)3tf;~:->>>~f::~~::.};i:,,~~~;::;~:C~:,}::C~;:i~t::(!::.:~K;:!l1 ~ ~--- a ~.~ ~.~ jI;"S ~ ~.~ ~ ;..~ ~ I I I j I i I , , i I I I I I I I I :-<~-"~""-"\ ~ D E C R EEl N ".p, 2. l..9 foM. ~ DIVORCE ~ -:Jc~ I 1" " .I'f7) ~ . . . . ~ . . . . . . . . . . ,Jt'f!I. .'. ~., it is ordered and $ ,', ~ ~ :;'::+::":::::'::+:';:::'::+::', '::0::.::..:':::.::.::.,:' ::;.::.::.: 0,:::.::,..::,::,,::,,::::,:::.:0. ".-::.::.;' IN THE COURT OF COMMON PLEAS ;..; ~ OF CUMBERLAND COUNTY ~'S ~ i.~ ~ ::.,i ~ ~.~ ~.S ~ STATE OF PENNA. ~'S ~ .mmm I II II No. JQ.q9.::J.9.7.1 .................. ~.; ~ ~ ~.~ ;...; ~ ~ ;.~ ~ ERICA L. HENDERSON ,..u_.. un _.... __u... _upo u.. .oau_ __ n..2 . .... .Plaint.iff......... Versus EDWARD C. HENDERSON ..___........__...._u....o.__u...____.u.__._..,_ .. ...m..... uu..[)~f~I1d<lI1t.. ~.~ ~ ~~i ~ ~.~ ~.~ ~ ~ ~.~ ~.~ ~ . ~.~ .;'. f.'~ ~ ;"S ~ .'. ~.~ ~ ~.; ~ " ~, ~.~ ~ AND NOW,.. . .. decreed that .ERI.GA. .HENDERSON..........................., plaintiff, and. . . EP.l~~~P. (~'. . HE.N~~~?~l'! . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " defendant, are divorced from the bonds of matrimony. ",,< ~ ~.~ ~ !.~ ~ ~.~ ~ h ~ ~ 8 ""; ~.; * .", 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; ........................fJwe..................................... , umf"i: ;..; ~ a ~.~ ki ~ j iii B~- ;.::(>3E-,. ':;." "rO:<<..~ ':">>::~'" ::.:<<~::. ':.::+::':,. -::+:<<!.:: -:..>>::~~:: ';:.:::+:::< );~::: "..::+::.;~: :::.:::c.:~. :';.:::+:>..: ':":::+::!'" -~"::+::'..: "":::+::'" "'.:::+::"':' .:::+::'" '::+::'" Prothonotary - ~-?'i"Y"~,n:." " ..'f <>..,<",,~:~- I~" . ^-- i~ ~ >'. ~ i ~.~ ~.~ * ~.~ ~ ;".; ~.~ ~ ~ ~ ~.~ * ;..~ I ~~~ ~ ~ j ><, ; ~.~ ~ l~ ~.;; N' I $', ~.~ ~ ~'" ~ '"..' ~ ~.~ ~.~ ~ ~.; ~ ~ ~ y ~ ~.~ ~ ~.~ ~ ~.~ ~.~ ~ ~ ~.~ ~ '.' ~ ~l ~ '.' ,. lii'""'....:...L.~.-...l,~~._....-.,~..~~"""""""'"'~~i11 . -,..~ ..._~.~.,~_" ~- .~~~_...- '~"'-._"~.~~ , '.,. .::IIllIIIIlIi1~ ", .~ <">,..: "'I;"; ~~.. '-,.-...... - . . 6'-3/-t!JcJ {}vi e'~ /J'~.tl/ :?b 4/:"'~ S':'?/.CJe:7 ~~~ ~~ ,~L,,=,,_,.~~ _. ".., ,'Oh~' , . t ERICA L. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 1971 CIVIL TERM EDWARD C. HENDERSON, 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 3301 (d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, return receipt requested on April 7,2000 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: None. B. (I) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: March 27, 2000. (2) Date of service of the Plaintiffs and Defendant's Counter Affidavit upon the Defendant: April7, 2000. 3. Related claims pending: None 4. Complete either (a) or (b). A. Date and manner of service ofthe notice of intention to file praecipe to transmit record, a copy of which is attached: April 7, 2000, Acceptance of Service by the Defendant. 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; - ~ 0 ~ ___ m,_, ,v_ ,- ~ < ~,'- ',::<-'~: :;:,,!:.:.:;}?~~~t'2:.:t:"! ';-1":~::e~:~1c~::::\~j:r[:f~~.:~~1J?8~:~' '~ " ,~ I , ','-. ""." ., .~ . i . ERICA L. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 1971 CIVIL TERM EDWARD C. HENDERSON, Defendant : IN DIVORCE . ACCEPTANCE OF SERVICE I, Edward C. Henderson, hereby accept service this 7th, day of April, 2000 of the Notice ofIntention in the above captioned matter. a?:VC~ ~!i Edward C. Henderson ~- " ".-, ~, ERICA 1. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 1911 CIVIL TERM EDWARD C. HENDERSON, Defendant : 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 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 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 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 " . ~- , I ..r" ERICA L. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - /f71 CIVIL TERM EDWARD C. HENDERSON, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE COMES NOW, Plaintiff Erica L. Henderson, through her attorney, James J. Kayer, Esquire and avers as follows: COUNT I - DIVORCE 1. Plaintiff is Erica L. Henderson, an adult individual, whose current address is: 1328 Pine Road, #4, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Edward C. Henderson, an adult individual, whose address is: POBox 84, Loysville Perry, County, Pennsylvania, 17047. 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 June 15, 1968, Hershey, Pa. 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(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. ~m_] , ",1 ,"',- . WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Date: ~ ! Z1! DO wrl!i'l . " .. 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: .:s - d 7- ,2000 ~b-f fA , ,X /~ ~A1J1;(./ ,"~ ~ " ERICA L. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - /1.}7{ CIVIL TERM : IN DIVORCE EDWARD C. HENDERSON, Defendant 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 October, 1978 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. 6 . . AjA, _ A.kd~ ERICA HENDERSON Date: 3 - d 7 ~,.J 000 'J? ~ - ~. ERICA L. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - l'tl l CIVIL TERM EDWARD C. HENDERSON, Defendant : IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either ( a) or (b): @I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i),(ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ffiU do not wish to make any claims for economic relief. I understand that I may lose ri~~oncerning alimony, division or property, lawyer's fees or expenses if! do not claim them before a divorce is granted. (b) lwish to claim economic relief, which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verifY that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsification :a::~hO;: 7- c/ Cl ~ eJi1# - ! EDWARD C. HENDERSON NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not fIle this counter-affidavit. '~!il!',. _ 0 ,_,_,~,'" . ERICA L. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 -1971 CIVIL TERM EDWARD C. HENDERSON, Defendant : IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF 3301 CD) DIVORCE DECREE TO: Edward C. Henderson POBox84 Loysville, P A 17047 You have been sued in an action for divorce. On or after April 28, 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 by the above date, the court can enter a final decree in divorce. 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 :'1 , ~ ERICA L. HENDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 1971 CIVIL TERM EDWARD C. HENDERSON, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Edward C. Henderson, hereby accept service this 7th, day of April, 2000 of the Notice of Intention in the above captioned matter. ~~!i Edward C. Henderson , " ,,- ", < , -,-,. " -,