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HomeMy WebLinkAbout07-0555 LORI A. STEVENS, Plaintiff V. MARK E. STEVENS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION-FAMILY DIVISION NO. 6 7 - (5 s5 5 cI ?; ? fi r.. 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 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 at Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: 717-249-3166 1 AMERICANS WITH DISABILITIES ACT OF 1990 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. LORI A. STEVENS, Plaintiff V. MARK E. STEVENS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION-FAMILY DIVISION NO. 6'7 - 0 X 55 I +ej ,. IN DIVORCE COMPLAINT IN DIVORCE UNDER 43301(c) OF THE DIVORCE CODE 1. The Plaintiff is Lori A. Stevens, who currently resides at 3532 Countryside Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Mark E. Stevens, whose mailing address is 340 East Penn Drive, #105, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 29, 2004, in Philadelphia, Pennsylvania. 5. There have been no prior actions of divorce or for annulment of marriage between the parties hereto in this or in any other jurisdiction. COUNT I - DIVORCE 6. Paragraphs 1 through 5 above are incorporated herein by reference as if textually set forth at length. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of counseling and is aware that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. cam' 0 - S&V-? Lori A. Stevens, Plaintiff 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. Section 4904 relating to unsworn falsification to authorities. Date: 1i1 16? ?Lori A. Stevens V =f t 7 C C, t rT? {; LORI A. STEVENS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - FAMILY DIVISION V. IN DIVORCE MARK E. STEVENS, Defendant NO. 07-0555 CIVIL TERM AFFIDAVIT OF SERVICE LORI A. STEVENS, Plaintiff, being duly sworn according to law, deposes and says that she mailed a true and correct copy of the Complaint in the above-captioned action to the Defendant, Mark E. Stevens, by United States Certified Mail, No. 7006 2150 0003 8540, on January 29, 2007, return receipt requested, and said return receipt is attached hereto and made a part hereof. Lori A. Stevens Swornxo and subscribed before me this ac-)- day of :Tt TJ7p 72007, Notary bl My Com. Exp. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shelley D. Pinckney, Notary Public Camp Hil &ma, Cumberland County MY Commission Expiage November 1, 2006 Member Pennsylvania Association Or Notaries 1 I i raYi°?e" 0 Complete items 1, 2. and 3. Akbo rwnipises " ttem 4 If RWUiated DOWNY Is dom. ¦ Print your name and,*kt-M OP<" M01" 30 ftQt tae can r*jm tfis card to YOU. ¦ Attach this card to the back of the MOP110". or on the front If space permits. 1. Article Addieseed to: -E, S-s SHO ? 016t 1 P,4 1-70 i_ 0 Agent S. R.a.w.d by (A- C. Date of DWWY D. h deMatY addnMS hem" 'W yes If YES, craw delvery O ND &'j" Type oaroa.d Mw o erne. bAd p PACIetered 13 Return Roos" for Merdwmdho 0 Insured Mail 0 C.O.D. 4. Restricted D91lvery4 (Exba Fee) Yes (0$'3 a- 2. Article Number 7006 215 0 0003 8540D (Transfer from Wmce kbeD Domestic Return Receipt 102595.02-M-1540 PS Form 3811, Febnjary 2004 C 1-nr?; t,,,... 1f? un Sr i LORI A. STEVENS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA CIVIL ACTION - FAMILY DIVISION V. IN DIVORCE MARK E. STEVENS, Defendant NO. 07-0555 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on January 29, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. §4904 relating to unsworn falsification to authorities. Date: -H I Lori A. Stevens C-) i Co ` ? fit rv ? C-n 3' ? C N a n,y -? W or LORI A. STEVENS, Plaintiff V. MARK E. STEVENS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - FAMILY DIVISION IN DIVORCE NO. 07-0555 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND $3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 unworn falsification to authorities. Date: 12-010-7 _ xoe?-?(2- D Lori A. Stevens O - G n rn e t m w 1 LORI A. STEVENS, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA CIVIL ACTION - FAMILY DIVISION V. IN DIVORCE MARK E. STEVENS, Defendant NO. 07-0555 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on January 29, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. §4904 relating to unswom falsification to authorities. Date: 6i e. 'A?? E. Stevens rv O R N f LORI A. STEVENS, Plaintiff V. MARK E. STEVENS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - FAMILY DIVISION IN DIVORCE : NO. 07-0555 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 63301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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: 4#10W ^ Z D d M?rk't Stevens tr, ".. , a A LORI A. STEVENS, Plaintiff V. MARK E. STEVENS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - FAMILY DIVISION IN DIVORCE NO. 07-0555 CIVIL TERM 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(c) of the Divorce Code. 2. Date and manner of service of the complaint: By United States Certified Mail No. 7006 2150 0003 8540, on January 29, 2007, return receipt requested, which receipt was attached to an Affidavit of Service filed in the Office of the Prothonotary in and for Cumberland County, to the above-captioned action. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff on June 20, 2007; by Defendant on June 20, 2007. Date of filing and service of the Plaintiff's affidavit upon the Defendant: June 20, 2007 (service date) and June 22, 2007 (date of mailing via U. S. first-class mail to the Prothonotary for filing). 4. Related claims pending: none. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: June 22, 2007 (date of mailing to Prothonotary by U.S. first-class mail for filing). 6. Date Defendant's Waiver of Notice was filed with the Prothonotary: June 21, 2007 (date of mailing to Prothonotary by U.S. first-class mail for filing). & Q. S(?e? Lori A. Stevens, Plaintiff VERIFICATION I verify that the statements made in the within document are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. st&?7?- Date: daue 6, A. Stevens Lori C R q v C?Cti ? ? -0 rn r'rt C . wti ,r. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LORI A. STEVENS Plaintiff NO. - 07-Qd5-CIVI1,ffERM VERSUS MARK E. STEVENS DECREE IN DIVORCE AND NOW, J 7 IT IS ORDERED AND am- w DECREED THAT LORI A. STEVENS , PLAINTIFF, AND MARK E. STEVENS ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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 Ll -Z -Z 4 a