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HomeMy WebLinkAbout00-02522 < . < . . . < < < . . < . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . < . . . . . . '. . , , .,. '" ..,-, . .. .. '" '" :F.'" . . < . < IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. AARON M. MUMMERT, Plaintiff NO. 2000-2522 CIVIL VERSUS AMY M. ENGLISH-MUMMERT, Defendant DECREE IN DIVORCE AND NOW, o~ ..,;r c.: ~~ I,M' 2000 , IT IS ORDERED AND 17 DECREED THAT AARON M. MUMMERT , PLAINTIFF, AND AMY M. ENGLISH-MUMMERT , DEFENDANT, ARE DIVORCED F'ROM 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 TH ATTEST: ~~ ROTHONOTARY . . '" '" '" :Ii '" '" :Ii . . . ,], .J..-l, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . -- - .. ,.,.....,-..... . ,.- .-.t. j[J.ltf.tJtJ W ~ ~$ 4-. ~ /t9/f'OJP! 6d. ~~ ;;t4~ ,~ """ ,_ ,_,' !h-~k -~.~"t._,_'r.~~ ~~1IIJIl ~I!_.~- c;I"I~ , ' I, _,~ 'j-; -:~! ,'- ~;-~'i< ,'1' Il;iY/)J .... . ....'~..'.i...............,c.\'...,.'..........'...........i....... ....,.................:.>.:..' ,- 'r;~ ,r:~ ~ cit .'.~ ~J?,'t.~ ....~ fn ~..~- -",' .-: ' .- " - I,' - - , (I... .~.........,'.'...'...,.........." ..... ..i.i...~'j..': .......... ~".."C(J~""--~:" , I, ' I ii Iilll! ] ~ LL' ~ L L ,.;:1, AARON 14. MUMMERT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 2522 CIVIL TERM AMY 14. ENGLISH-MUMMERT, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the 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: On April 25, 2000 by u.S. Mail, Restricted delivery. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, July 29, 2000; By Defendant, October 13, 2000. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in 5 3301(c) divorce was filed with the Prothonotary on August 28, 2000. Date Defendant's Waiver of Notice in 5 3301(c) divorce was filed with the Prothonotary on October 16, 2000. J'Iwm'W"'O. ~ Thomas D. Gould, Esquire Attorney For Plaintiff . .,........' '''"'''''___~liIii_~~:Iilm\_Oll_~~;-''!i<Jdma,~<\,~-~ . ~~ ..a Glr' ~~~ o C 7' -oC;; rn6--i ;~i;'.i ~~S~ r::CI )";:r :z:~~; ):.-1' c:~ L~ ::2 -- CJ C) C) (-, -, ,",..J 'T\ C"I :oc:~ T -~() ;~,!<jj t~~;.~ ~ ~S! -.... ~, ~ {::J ~~J , . AARON M. MUMMERT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -JS~:J.. CIVIL TERM AMY M. ENGLISH-MUMMERT, 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 ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 --' " , . I'~ ~"'" iml~ AARON M. MUMMERT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -;)SQ.2. CIVIL TERM AMY M. ENGLISH-MUMMERT, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Aaron M. Mummert who resides at 192 Klein Road, Chehalis, Washington 98532. 2. The Defendant is Amy M. English-Mummert who resides at 311 Somerset Drive, Shiremanstown, Cumberland County, Pennsylvania 17011. 3. The Defendant has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 18, 1999 in Stafford County, Virginia. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. I'. . " 1,.- Ie 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. -:a;..,44 l) huUt' Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 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. 4904, relating to unsworn falsification to authorities. Date: tJ<.../-/rf-OD /~- Mummert ~, ~ 'tl '~ ~ l!! ~ - ~ = " o 'tl .. li is. E o ,,, SENDER: I also wish to receive the follow- ing services (for an extra fee): Addressee 2.11 Restricted Delivery 4a. Article Number 3S.:l 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise lSl:Ce~lfied o Insured DeOD 7. Date ~! D,llv~ 7-,/{'-OD t a. Addressee's Address (Only if requested and m'fll'.>::J( f~e is paid) CI COhlplete items 1 and/or 2 for additional selVicas. Complete items 3, 4a, and 4b. EJ Print your nama and address on the reverse otthis form so that we can return this card jO you. o Attach this form 10 the front of the mailpiece, or on the back it space does not permit. o Write ~Retum Receipt Requested." on the mail piece below the article nulTlbElr. l:J The Return Receipt will show to whom the article was delivered and the dale delive(ed. 3. Article Addressed to: ,. Amy fYI. ~1\I~/,r~, ll'l"m....l'd 31l .sOA1(lrH.:t ~rl vt. Sh ,fe Wlell'/ s"l"tlWIl, PA' 7Q II ,; " '~ ~ Ul 1i ';; u .. '" " - = li "', DI, ~ '~ = ~r = , o ... ",,' " .. ~. 102595-99.a-0223 Domestic Return Receipt -,-,' , ,,~- ~~,j ". doL I, i~~ ~ 'I "i I AARON M. MUMMERT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 2522 CIVIL TERM AMY M. ENGLISH-MUMMERT, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on April 24, 2000, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on April 25, 2000. ~iWD. ~ Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 . ' . ~~.. L.i.rIlMi-...... .~.""'""'ihIliM1lil\'.lO!i!J~,.,_~~M1l<'<~. ~~,~" < IiI' _JilL' _II - ~ " ~ 0 C} ~:! C Ci g "D> -oa:, -~.- mer: 7J '\ Z:T- ;'.) '--:2:~ -'C;- ~,:-~~:, CO , [~-) yG -- :;.?~ '-i~f~ ~o ::Ib - -" - >"c '~ z ~" ::2 N ~ N Ilii -..I; ,. I€l:i AARON M. MUMMERT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 2522 CIVIL TE:RM AMY M. ENGLISH-MUMMERT, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 24, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42 (e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 6'1- ;:q-oo ~~~ Aaron M. Mummert -' (") co LJ C 0 "l'l $: ;0- -oc.rJ ,- :: ~' j mf"r: ?5 'j z:::n , 1',,) " ;r",; ~?; CO ::~~r2 ~o "'" _:g~l. :PC ~~~~ 20 :Pc: ,~ -" ~ "> N :0 w -<; ;',>, I I, I' "E.~ '" "',W~ ' , -1'1 AARON M. MUMMERT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV>>lIA v. NO. 2000 - 2522 CIVIL TERM AMY M. ENGLISH-MUMMERT, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301/0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: ()'7-;J, '7-DD /-~ Aaron M. Mummert :'J,' "-'-- ^ .Mtin If , ......lm~~~.--<t..'i;>-'ilIiJi;i,:l'i~ (") c :s: -vc:' mn.~ z:rJ zr' ~~:: '-0 ~ 28 Pc :z; =< C) o "'" s""') f",,", ,.0 ';-1'1 .~c' ~;~~ -":.,- ~''1 ::::;,;C) C:5,Tl .'-1 "h, =0 -< ~.> -r."" "" (D , .-', . ~.1J AARON M. MUMMERT, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 7..5'Z..""Z- : NO. 2000-_ CIVIL TERM AMY M. ENGLISH-MUMMERT, Defendant : IN DIVORCE WAIVER OF NOTICE OF COUNSELING I, AMY M. ENGLISH-MUMMERT, Defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. No. 4904 relating to unsworn falsification to authorities. Dated: J b - J '3 ~A-tJ Jk;c:r .-"'"~' illL ~', ,~ ~' ~ ~,'~~ ~oo'-IWill,,,,,,,,:,- . '. () C <~ -U~, rnn---=\ Z:I1 zC ~"';:-, ,<i':.', ;;0 '-C ):> c: 3. c: => C7) ~-l v" '.,--", c~;~\ ~j~~) , ' ,:-~)?:-1 ?';,rn ~~ -~ ""<'"'" <:::" =<: ;~ CJ , , .'~ ~o - '" . ,f . AARON M. MUMMERT, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : -z.z-- : NO. 2000- ')...5" CIVIL TERM AMY M. ENGLISH-MUMMERT, Defendant : IN DIVORCE AFFIDA VIT OF CONSENT L 23,2000. A Complaint In Divorce under Section 330l(c) of the Divorce Code was filed on May 2. The marriage of 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 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: IO-13~G0 ~!.~~T'''''''''' ",---,..- . .., ...~~....~'...iu.<II.....""-'.......... ' ' "............~~"'.,""""'~"~ ".~ (") 0 (~~J C C,.) ,-'j'.] ?;:, 0 -~,.__. cJ mrTi -\ ;2 .L'-:r,: >--; Z,C :':-~;, SQ;,,~~--,-, 0;> ~~~ ??, r:~E -0 ~ ~'\~5 ;g z:c; -.,r- ''0.'-.-' bt-, :=~:,in )>r Z S! -' :x:) -< (;:) --<.:. IJ . AARON M. MUMMERT, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 5"Z.<]... : NO. 2000-~ CIVIL TERM AMY M. ENGLISH-MUMMERT, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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 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 Pa. C.s. Section 4904 relating to unsworn falsification to authorities. Date: 0 - I "3 - ~O ~1IiiIlIliMiIJ~_~~!llll--'~- """'-"'~ . ~~ ..- .J ,I " II 11 ;] i'l " 1'1 I~ I' ~ () 0 () C 0 "n <-: :;:) -0(:(, " rn,,-, ...... :z~:<:'~ :z:c- C"\ ~d; eEl --0 - :s::C) ......,.. ~C) [~5. pro- ~ -1 Z 'J~'" -' ::p -<; (::,) -c