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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
PENNA.
Frederick L. Wright, III
No.
3597 Civil 2000
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VERSUS
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Marjorie A. Wril1:ht.
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AND NOW,
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DECREED THAT
Plaintiff
Defendant
DECREE IN
DIVORCE
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~ , IT IS ORDERED AND
Frederick L. Wright, III
, PLAINTIFF,
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AND
Marjorie 1\. Wright
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY,
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IHE 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;
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FREDERICK L. WRIGHT, III,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No, 00 - 3597 Civil Term
MARJORIE A. WRIGHT,
Defendant
: ACTION 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 ~3301(d) of the Divorce Code,
2. Date and manner of the service of the Complaint: Delivered by certified mail.
restricted delivery. return receipt requested. delivered on: June 15.2000.
3, Date of execution of the affidavit required by 93301(d) of the Divorce Code:
By Plaintiff: June 12.2000.
Date of filing and service ofthe plaintiffs affidavit required by 9330I(d) of the
Divorce Code on respondent:
Filed: June 14.2000.
Served on Defendant: June 15.2000.
4. Related claims pending: None.
5. Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached: July 10. 2000. via certified mail. restricted delivery to
Maijorie A. Wril!ht.
Dm. 7~!OD
'te.Q.
ane Adams, Esquire
LD, No, 79465
117 South Hanover St.
Carlisle, Pa, 17013
(717) 245-8508
Attorney for Plaintiff
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FREDERICK L. WRIGHT, III,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 00 - 3597 Civil Term
MARJORIE A. WRIGHT,
Defendant
: ACTION IN DIVORCE
NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE
TO:
Marjorie A. Wrie-ht
75 E. Rosebud Road
Myerstown, Pa. 17067
DATE:
July 7, 2000,
You have been sued in an action for divorce. You have failed to answer the Complaint or
file a Counter-Affidavit to the 330I(d) affidavit. Therefore, on or after July 27.2000
the Plaintiff 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 date above, 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 lose forever the right to
ask for economic relief, A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE
PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE.
Unless you ~ave 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
ask for economic relief, The filing of your 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,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pa. 17013
(717) 249-3166
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FREDERICK 1. WRIGHT, III,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
No. 00 - 3597 Civil Term
MARJORIE A. WRIGHT,
Defendant
ACTION IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 330Hd) ofthe DIVORCE CODE
1. Check either (a) or (b):
~(a) I do not oppose the entry ofa 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):
_(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees, and expenses if! do not claim them before a divorce is granted,
_(b) I wish 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
Prothonolliry in writing and serve them on the other party. If! 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 verilY 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, ~4904 relating to unsworn falsification to
authorities,
Date:
MaJjorie A. Wright, Defendant.
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim
for economic relief, you need not file the counter-affidavit.
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FREDERICK L. WRIGHT, III,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No, tnJ. 359.., ~ ~J.u-..
MARJORIE A. WRIGHT,
Defendant
: ACTION 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.
Where the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling, A list of marriage counselors is available at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pa. 17013
(717) 249-3166
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FREDERICK L. WRIGHT, m,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
; No. IY{)- ~1)91 Ce;;J Ie...--
MARJORIE A. WRIGHT,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Frederick L, Wright, III, an adult individual, who has resided at 1269
Boiling Springs Road, Boiling Springs, Pa, 17007, since December 1998.
2, Defendant is , Mllljorie A. Wright, an adult individual, who has resided at 75 E,
Rosebud Road, Myerstown, Pa. 17067, since 1997.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4, The Plaintiff and the Defendant were married on June 20, 1964 in McKean County,
Pennsylvania,
5, There have been no prior actions of divorce or for annulment between the parties,
6. 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,
7. Plaintiff and Defendant have had seven children together; however, only one child is
currently under the age of 18, namely, Eric Gibson Wright, date of birth 10/7/83.
8. Plaintiff and Defendant are both citizens of the United States of America,
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
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10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken,
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
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.
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Frederick Wright, III,. laintiff
Respectfully submitted,
Date: 06- 17.-tJo
~
ane Adams, Esquire
J.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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FREDERICK L. WRIGHT, III,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
; No, .,2000 - 3597 c (v,(
MARJORIE A. WRIGHT,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SEPARATION
1. The parties to this action separated in August 1988 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 my rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
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. ~4904 relating to unsworn
falsification to authorities.
Date: tJ" -;;l -1flJ
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Frederick L. Wright,
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FREDERICK 1. WRIGHT, III,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
vs,
: No. 00 - 3597 Civil Term
MARJORIE A. WRIGHT,
Defendant
: ACTION IN DNORCE
AFFIDAVIT OF SERVICE
AND NOW, this June 20, 2000, I, Jane Adams, Esquire, hereby certify that
on June 15, 2000, a true and correct copy of the NOTICE TO DEFEND, COMPLAINT and
AFFIDAVIT OF SEPARATION were served, via certified mail, restricted delivery, return
receipt requested, addressed to:
Marjorie Wright
75 E. Rosebud Road
Myerstown, Pa. 17067
Respectfully Submitted:
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U~, No. 79465
117 South Hanover St,
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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FREDERICK 1. WRIGHT, Ill,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: No. 00 - 3597 Civil Term
MARJORIE A WRIGHT,
Defendant
: ACTION IN DIVORCE
NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE
TO:
Marjorie A. Wright
75 E. Rosebud Road
Myerstown, Pa, 17067
DATE:
July 7, 2000,
You have been sued in an action for divorce. You have failed to answer the Complaint or
file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after July 27. 2000
the Plaintiff 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 date above, 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 lose forever the right to
ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE
PROTHONOTARY OF THE COURT IS ATTACHED TO TillS NOTICE.
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
ask for economic relief. The filing of your counter-affidavit alone does not protect your
economic claims.
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,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pa, 17013
(717) 249-3166
....
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FREDERICK L. WRIGHT, III,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
No, 00 - 3597 Civil Term
MARJORIE A. WRIGHT,
Defendant
ACTION IN DIVORCE
COUNTER.AFFlDA VIT UNDER SECTION 330Hdl oUbe DIVORCE CODE
L Check either (a) or (b):
_(a) I do not oppose the entry ofa divorce decree.
_(b) I oppose the entry ofa 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):
_(a) I do not wish to make any claims for economic relief, I understand that I may lose rights concerning
alimony, division of property, lawyer's fees, and expenses if! do not claim them before a divorce is granted.
_(b) I wish 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) ahove, I must also file all of my economic claims with the
Prothonotary in writing and serve them on the other party, If! 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. ~4904 relating to unsworn falsification to
authorities.
Date:
Marjorie A, Wright, Defendant.
NOTICE: If you do not wish to oppose the entry ofa divorce decree and you do not wish to make a claim
for economic relief, you need not file the counter-affidavit.
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FREDERICK L. WRIGHT, III,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
vs,
: No, 00 - 3597 Civil Term
MARJORIE A. WRIGHT,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF THE
NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE
and COUNTER-AFFIDAVIT
AND NOW, this July 31, 2000, I, Jane Adams, Esquire, hereby certify that
on July 10, 2000, a true and correct copy of the NOTICE OF INTENT TO REQUEST ENTRY
OF DIVORCE DECREE and COUNTER-AFFIDAVIT were served, via certified mail,
restricted delivery, return receipt requested, addressed to:
Marjorie A. Wright
75 E. Rosebud Rd,
Myerstown, Pa. 17067
DEFENDANT
Respectfully Submitted:
J e Adams, Esquire
.D, No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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FREDERICK 1. WRIGHT, III,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
No, 00 - 3597 Civil Term
MARJORIE A. WRIGHT,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF NON-MILITARY SERVICE
Plaintiff, FREDERICK 1. WRIGHT, III, deposes and says that he is the Plaintiff in the
above-captioned matter; that he personally knows that MARJORIE A. WRIGHT, Defendant, is
over the age of 18 years; and that she currently lives in Myerstown, Pennsylvania,
Plaintiff further avers that Defendant is not in the Military Service or in any branch of the
Armed Forces of the United States or its Allies or otherwise within the provisions ofthe
Soldier's and Sailor's Civil Relief Act of Congress of 1940 and its Amendment.
Plaintiff verifies that the statements made in this Complaint are true and correct. Plaintiff
understands that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904
relating to unsworn falsification to authorities.
Date: 0 '7- ').. 9- (;'0
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Frederick 1. Wright, III
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