HomeMy WebLinkAbout97-00426
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JILL A. EMERSON,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 97-426 CIVIL TERM
SCOT D. EMERSON,
Defendant
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 Section 3301 (cl.
2. Date and manner of service of the Complaint: Acceotance of Service filed bv Defendant's
counsel indicatino service on or about 31 Januarv 1997 fAcceotance filed on 3 Februarv 19971.
3. Complete either Paragraph la) or (bl:
(al Date of execution of the Affidavit of Consent required by Section 3301 (cl of the Divorce
Code: by Plaintiff: 14 Julv 1997 by Defendant: 23 June 1997
Ibl (1) Date of execution of the Affidavit required by Section 3301(dl of the Divorce
Code: 121 Date of filing and service of the Plaintiff's Affidavit upon the
Respondent:
4. Related claims pending: None
5. Complete either (a) or (bl:
(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 Section 33011c) Divorce was filed with the
Prothonotary: Dated 14 Julv 1997. filed contemooraneouslv herewith. Date Defendant's Waiver of
Notice in Section 3301(cl Divorce was filed with the Prothonotary: dated 23 June 1997. filed 3 Julv
I .lll..91.
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Date: J C\ ;1:.).f /?H
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BY~'__~\Jn
S _ I L. Andes
Attorney for Plaintiff
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JILL A. EMERSON,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 97-'f:l(" CIVIL TERM
SCOT D. EMERSON,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list. All necessary arrangements and the cost of counseling sessions are to be borne by you
1: and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failurtl to do so will constitute a
waiver of your right to request counseling.
2
JILL A. EMERSON, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
:1 I
vs. ) CIVIL ACTION - LAW
)
) NO. 9?-Ii.:l." CIVIL TERM
SCOT D. EMERSON, )
Defendant ) IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, JILL A. EMERSON. by her attorney,
Samuel L. Andes. and makes the following Complaint in Divorce:
,I
1. The Plaintiff is JILL A. EMERSON, an adult individual who currently resides at 1101
Linham Court, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is SCOT D. EMERSON, an adult individual who currently resides at
278 Lake Meade Drive, East 8erlin, Pennsylvania, 17316.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 20 October 1979 in Marysville,
:: Pennsylvania.
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5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
I: may have the right to request that the Court require the parties to participate in counseling,
,
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3
JILL A. EMERSON,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
SCOT D. EMERSON,
Defendant
NO. 97-426 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I hareby accept service of the Complaint in Divorce filed in the above-captioned
action on behalf of the Defendant on or about 31 January 1997.
) . J- f 1
James . Miller
Atto ey for Defendant
Locust Street, Suite 100
Harrisburg, PA 17101
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JLIl 22 '97 21:.15
Dill A. Emeroan, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF~erlarq;OUNTY.
) PENNSYLVANIA
)
vs, ) CIVIL ACTION. LA W
)
Scot D. Elner800 , ) NO. 97-426 Civil Tenn
)
Defendant ) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE OF-CREE UNDER SECTION 3301(j:l OF THE DIVORCE CODE
1. I consent to the entl)' of a final decree in divorce without notice.
2. I undersland that I may lose rights concerning alimony. division of property. lawyer's fees. or
expenses if! 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 fikd with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. ) undersland that false
statements herein are made subject to the penalties of I g Pa. e.S. Section 4904 relating to unsworn
falsification to authorities.
D8te/?/:7.3/C; 1
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Scot D. Dnerson
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JILL A. EMERSON, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. } CIVIL ACTION - LAW
)
) NO. 97-426 CIVIL TERM
SCOT D. EMERSON, )
Defendant ) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. ) consent to thc cntry 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! do not claim thl'm before a divorce is granted,
3. I understand th1tl 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 veritY that the sl'llements made in this Affidavit are true and correct, I understand that false
statements herein are m'I" subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn
falsification to authoritk'~,
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Dated:
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