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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
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Lydia L. Adkins,
PENNA.
Plaintiff
No.
4739 Civil Tem
2000
VERSUS
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George R. Adkins, Jr.
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Defendant
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DECREE IN
DIVORCE
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AND NOW~
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DECREED THAT
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Lydia L. Adkins
, PLAINTIFF,
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AND
George R. Adkins, Jr.
, 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;
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LYDIA L. ADKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2000 - 4739 Civil Term
GEORGE R. ADKINS, Jr.,
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 ~330l(c) of the Divorce Code.
2. Date and manner of the service of the Complaint: Delivered by certified mail.
restricted deliveJY. return receipt requested. delivered on: July 7. 2000.
3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code:
By Plaintiff: October 6, 2000
By Defendant: October 10,2000.
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: October 16,2000.
Date: 10'/6 '00
Respectfully Submitted:
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e Adams, Esquire
J.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
LYDIA L. ADKINS,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No.02.CX:O-lf139 civil
: ACTION IN DIVORCE
GEORGE R. ADKINS, Jr.,
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 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 ofthe
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 FlLE 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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LYDIA L. ADKINS,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
; No. tTO- '-17:3 9~ T..LU--
GEORGE R. ADKINS, Jr.,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Lydia L. Adkins, an adult individual, who has resided at 113 Grouse Drive,
Harrisburg, Pa. 17110, since September 1999.
2. Defendant is George R. Adkins, Ir., an adult individual, who has resided at 216 Spring
Lane, Enola, Pa. 17025, since May 6,4000. .
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 July 2, 1989 in Montrose,
Susquehanna 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 no children together.
8. Plaintiff and Defendant are both citizens ofthe 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. 1 understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
J
Respectfully submitted,
Date: 7~~
e Adams, Esquire
J.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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LYDIA L. ADKINS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 2000 - 4739 Civil Term
GEORGE R. ADKINS, Jr.,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF THE
NOTICE TO DEFEND AND COMPLAINT
AND NOW, this July 11,2000, I, Jane Adams, Esquire, hereby certify that
on July 7, 2000, a true and correct copy ofthe NOTICE TO DEFEND AND COMPLAINT were
served, via certified mail, restricted delivery, return receipt requested, addressed to:
George Adkins, Jr.
216 Spring Lane
Enola, Pa. 17025
DEFENDANT
Respectfully Submitted:
ane Adams, Esquire
LD. No. 79465
117 South Hanover 8t.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FORPLAINTITF
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JE PS Form 3811, Pecemb r 1994
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Domestic Return Receipt
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L YOIA L. ADKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 2000 - 4739 Civil Term
GEORGE R. ADKINS, Jr.,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on July 3, 2000.
2. The marriage of 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 of divorce,
4. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or
expenses, if I do not claim them before a divorce is granted,
I understand that the statements made in this affidavit are true and correct. I also understand that false
statements therein are made subject to the penalties of 18 Pa,C,S. 4904, relating to unsworn falsification to
authorities.
Date:
~Ott :leoD
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WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER li33011cl OF THE DIVORCE CODE
1, I consent to 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 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 made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities,
Date: J ~ ~ -
lLJ 0 of- () () 0 0 Lydia
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LYDIA L. ADKINS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 2000 - 4739 Civil Term
GEORGE R. ADKINS, Jr.,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1, A complaint in divorce under section 3301(c) of the Divorce Code was filed on July 3, 2000,
2. The marriage of 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 of divorce.
4. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or
expenses, if I do not claim them before a divorce is granted,
I understand that the statements made in this affidavit are true and correct. I also understand that false
statements therein are made subject to the penalties of 18 Pa.C,S. 4904, relating to unsworn falsification to
authorities.
Date: 'P(/P/fJO
/,f;
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER lS33011cl OF THE DIVORCE CODE
1. I consent to 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 if I
do not claim them before a divorce is granted,
3. I understand that I will not be divorced ufltil 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. ~904 relating to unsworn falsification to authorities.
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c1eorg~lns, J~" Defen nt
Date: 10/ItJ(Od
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