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Home My WebLink About07-1064KIMBERLY SABOL, Plaintiff VS. THOMAS SABOL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- d G `? CIVIL ACTION - LAW : 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 will proceed without you and a decree in divorce or annulment may 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 or 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 in the Office of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 32 S. Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 i KIMBERLY SABOL, Plaintiff V. THOMAS SABOL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- /0 (-Y CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Kimberly Sabol, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following: 1. Plaintiff is Kimberly Sabol, an adult individual, currently residing at 187 Faith Circle, Carlisle, Cumberland County, Pennsylvania 17013 since January, 2000. 2. Defendant is Thomas Sabol, an adult individual, currently residing at 187 Faith Circle, Carlisle, Cumberland. County, Pennsylvania 17013 since January, 2000. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on March 31, 1990, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. Y 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, acq line M. Verney, Esquire Supreme Ct. ID. 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing divorce complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. J 4:at Kimberly S o Plaintiff C7 ^' r? p -v i -*? 7 f rTZ -1 I -: co m t -7 rTl ? V; ,r i 10 c ocJ ?i CS C KIMBERLY SABOL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.2007- /0& y CIVIL ACTION - LAW THOMAS SABOL, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce in the above captioned matter pursuant to Pennsylvania Rule of Civil Procedure, Rule 1930.4(d). Date: 3. p 7 De end t JS? rc, 4 C:i((L Covj,'S?v- PA 1-70k3 Address ? ? G' -rt c? ? .--a -t ? y ,? ?? r ??; -n,- _,,, r -, ?= __-?. ?'`, s?' ? * ? ? v ?? ., y ? KIMBERLY SABOL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. 2007-1064 CIVIL ACTION - LAW THOMAS SABOL, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 27, 2007. 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. Date: 5- ca KrP-I!aintiff ? ? Q C-n KIMBERLY SABOL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-1064 CIVIL ACTION - LAW THOMAS SABOL, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. 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 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. section 4904 relating to unsworn falsification to authorities. Date: 0 7615 - 'j C Ky ca t-.. cp% t? IN THE COURT OF COMMON PLEAS OF KIMBERLY SABOL, ;CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO• 2007-1064 CIVIL ACTION -LAW THOMAS SABOL, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT int in Divorce under Section 3301 (c) of the Divorce Code was 1, A Compla filed on February 271. 2007. ' of plaintiff and Defendant is irretrievably broken and ninety 2. The marriage (90) days have elapsed from the date of filing and service of the Complaint. ent of a final decree of divorce after service of notice of 3. I consent to the ry intention to request entry of the decree. the statements made in this Affidavit are true and correct. I I verify that understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904, relating to unworn falsification to authorities. efendant Date: i 1 -3 -'z+ Thomas abol, D CA.) ; rT'l KIMBERLY SABOL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-1064 CIVIL ACTION - LAW THOMAS SABOL, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. 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 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. section 4904 relating to unsworn falsification to authorities. Date: a - Thoma Sab , Defendant ?„ J ??r.a ??'yI ° r? ??? '"r, T. ?i? ?`'? ? ?"h ?? \,?"' ?.. f? 'S 1 - - ?'a KIMBERLY SABOL, Plaintiff V. THOMAS SABOL, Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1064 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c), 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Acceptance of Service, made on March 6, 2007. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by sec. 3301 (c ) of the Divorce Code: by plaintiff October 25, 2007; by defendant December 3, 2007. (b) (1) Date of execution of the affidavit required by sec. 3301 (d) of the Divorce Code: ; (2) Date of filing and service of the plaintiff's affidavit upon the defendant 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to file Praecipe to transmit record, a copy of which is attached (b) Date plaintiff's Waiver of Notice in sec. 3301 (c) Divorce was filed with the Prothonotary: October 26, 2007. Date defendant's Waiver of Notice in sec. 3301 (c) Divorce was filed with the Prothonotary: December3, 2007. ? I v `V Atto y for Plaintiff Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 r-; ? ?? '?? - -' +?- ' x •• • f . E ..,j ?\ r ?" ..r.?F `.Iw?n ?"ya, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Kimberly Sabol Plaintiff Thomas Sabol VERSUS NO. 2007-1064 Defendant DECREE IN DIVORCE AND NOW, A a -2---7 , IT IS ORDERED AND DECREED THAT AND Thomas Sabol ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,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. BY THE COURT: PROTHONOTARY Kimberly Sabol l t: