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HomeMy WebLinkAbout97-01094 ****'~~**~**'~'~***'~*~"~~*'*:*******'~ ~I-~~--~~-"'----~-'----~~-~-'-~-'---'-'" ...----.~-...-..,~.~-.-.--.-"----... "~. -" ...,---,...._--......,_._--"~-',~ ~II ~ -"1, ~ '.' ~ '.' 8 ~ ~ ~ <:" ~ ~) "'1 ~I .. IN THE COURT OF COMMON PLEAS $ OF CUMBERLAND STATE OF ~, PENNA. COUNTY ~ '.' ~~ ~ ~ KRISTEN S. CHISOOIM, ~ i\: o. 97-1094 (lJ ~ ~\ V('I',';II:; ~ JA\1I:S J. CHISIDIM, ~ '.' s ~ ~ DECREE IN DIVORCE ~ ':' ~ ~ ~ AND NOW, . . ' . , . , , . . 7X~~,~ , ' , /O~, , '. 19 .~r. ' '. it is ordered and decreed that.., ,~i.l;t;~ ,S., ,Chi!inolm, . " . , .., , , . , , .. . . . . .. ,.. " plaintiff, anai,. .Jumes, .J. . Chisholm, .' , .. , . ,. " , " , .' ,. . . , . , . ,. .. . ... ". 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; , , .. ' ,f10IJ,( ~ ~ <:" ......... ,........... ............... "M /-jJt Allo',l. Ukv~HC( E' tJ,~. ~1tP~~~/ .' ),' ^,/ J. Z {/ / ~::-~;c I'/t',' k'. >>E~ .i.J.'~~ , f/ '/ ProlllOnolan- ~ . i ~l ~I ~;..;. .~:. .~;. .:+:. .:.:. ~ ~.~..~..~.~.~~..~..~.~"~~.-~.~..*~.~..~.~.~.~-~.*~,.~ 8 ~ ~ '.' ~ ~ '.' ~ ,;, ~ ~ ~ ~ '.' ~ ~ ~ ~ ~ i, ~ ~ <:" I~ .. ),:. ',", I' I~ I: i~ i~ /',' I.;., I~ ~ ~ I~ (-.- I.., ;~ ::~ I. ~ ~ '~ '~ :~ :~ ~ ~: :~ ~~ ,.:I' e " e': , , , , ", " , ( 0 " , ~~: -' , r ..... I , . L : ,j " L;. I. . ~ , r.:' . , G ['- () rr- I ~ !i. Ii " " Ii !i KRISTEN S. CHISHOLM, Ii Plaintiff i' :i il ii ii ) ) ) ) ) ) ) I ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ;1 V5. CIVIL ACTION - LAW ,I " il ;i NO. 97- /0<('/ CIVIL TERM IN DIVORCE II JAMES J. CHISHOLM, :1 Defendant 'I ! " , " NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the 'foregoing 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 in 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 in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House Carlisle, Pennsylvania 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. Court Administrator, Fourth Floor Cumberland County Court House Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 KRISTEN S. CHISHOLM, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA Ii ) vs. ) CIVIL ACTION - LAW ) ) NO. 97- /(f(~1 CIVIL TERM JAMES J. CHISHOLM, ) Defendant ) IN DIVORCE !i 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 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. Failure to do so will constitute a waiver of your right to request counseling. , KRISTEN S. CHISHOLM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JAMES J. CHISHOLM, Defendant NO. 97- IOrl CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, KRISTEN S. CHISHOLM, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is KRISTEN S. CHISHOLM, an adult individual who currently resides in Cumberland County, Pennsylvania. 2. The Defendant is JAMES J. CHISHOLM, an adult individual who currently resides , at 340 Lawlor Terrace, Stratford, Connecticut, 06497. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania " for at least six months immediately previous to the filing of this Complaint. i: 4. The Plaintiff and Defendant were married on 7 April 1995 in Orlando, Florida. 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 may have the right to request that the Court require the parties to participate in counseling. 8. The Plaintiff requests this Court to enter a Decree of Divorce. 3 t r , , i :I r . -- -~ .. .- , c. . .' U:1. _:: ('I-_ I;:":. , (.:, ,- r'- .:"': L. , C '. ';j . ':"1. ,- '-' I' 1- '- a" ) -- ~ .. ~~ ,': .. '" , , .. IU:', ("; ( ,. r:" '. " 1'"". '.',1 L:,. I ~_.ll C , . ,~ . " -- ,..;. " r- U L' C. KRISTEN S. CHISHOLM, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION. LAW ) ) NO. 97- 1094 CIVIL TERM JAMES J. CHISHOLM, ) Defendant ) IN DIVORCE AFFIDA VIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 3 March 1997 and was served upon the Defendant on or about II March 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage cowlselofs and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 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. 17 Novanber 1997 DATE ~(11Uol ~ (lJtudi&-tr,.... J ES J. CHI OLM \ ,- - :-- ~ C'", , '" (~! L , , ,. i.~: .~ .. . t. " "". r. I ; '0 'oO ,. , ,. Co ,. ,- , (.) ,,;" CJ , KRISTEN S. CHISHOLM, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) ) NO. 97-1094 CIVIL TERM JAMES J. CHISHOLM, ) Defendant ) IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entty 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 arc made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn tillsificatioll to authorities. 17 Nov~r 1997 DATE (1,111"" ~ (Ift;g ;"/2,,, ESJ.C OLM . >- ..:I' '- r; c': I , .' u:t ('I . . ft. t,_ ( r: , '--1 " I L. C j I ~ J I he. L l' .:1 c; tj' u