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Home My WebLink About02-5893SCOTT DEAVEN, Plaintiff JODY DEAVEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O&- j-gqS 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 may proceed without you and a decree of divome 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 Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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, Pennsylvania 17013 Telephone(717) 249-3166 SCOTT DEAVEN, Plaintiff JODY DEAVEN, Defendant 17013. 2. PA 17013. 3. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~.~ CWIL ACTION- LAW IN DiVORCE COMPLAINT Plaintiff is Scott Deaven, who currently resides at 224 Meals Drive, Carlisle, PA Defendant is Jody Deaven, who currently resides at 109 Woodlawn Lane, Carlisle, 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. The Plaintiff and Defendant were man'ied on September 6, 1997, in Carlisle, Pennsylvania. 5. 6. 7. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 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. 8. Plaintiff requests the Court to enter a decree of divorce. MARTSON DEARDORFF WILLIAMS & OTTO Thomas J. W ms, Esquire I. D. Number'q 7512 Ten East High Street Carlisle, PA 17013 Attorneys for Plaintiff Date: December 10, 2002 VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Scott Deaven 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. Defendant No. 0Z-3 CIVIL ACTION - LAW IN DIVORCE CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the ~ in the above captioned Divorce Action, hereby elects to retake and hereafter use her previous name of '~kl R. ~t'a'~ This election is made )ursuant to the provisions of 54 P.S. 704. I ' - - Si~uJ~e (married name) (?°nn~r name) Commonwealth of Pennsylvania: County of Cumberland : ss: Onthe /b~dayof '~~~f , 2002, before a Notary Public. Personally appeared-4. ,,~Ck~\i ~, L-P-_JtDCh known to me to be the person [ - whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. -I CLAUDIA A. I~r~jj~lj~41:lY PUBLIC J Carlisle Bom, Cu'mberland County ,I My Commission Expires April 4, 2005 F:~FILESkDATAFILE\G-endoc,cur\9813 -3 .affl/cny Created: 12/31/02 08:10:22 AM Revised: 12/31/02 08:17:23 AM 9813.3 SCOTT DEAVEN, Plaintiff V. JODY DEAVEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5893 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) · SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Jody Deaven at 109 Woodlawn Lane, Carlisle, PA 17013 on December 12, 2002, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Jody K. Deaven" and dated December 16, 2002· Thomas J. Willi6ms, Esquire Swom to and subscribed before me this 31 st day of December, 2002. Publi~' NO,T, ARIAL SEAL TRICIA D. ECKENROAD, Notary Public Carlisle Bom, Cumberland County ~~x~.nim.s Dc2. 23, 2004 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: C. Date of Delivery from item 17 r-lyes If YES, enter daiivery address below: [] Ne 3. Service Type ~ Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandiee [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) ~ yes 2. Article Number ('rmnsfer from sent/ce/mbeO 7 0 0 1 2510 0009 2827 5638 PS Form 3811, August 2oo~ Domestic Return Receipt 102595-02-M-0835 m Return Receipt Fee ' 'I O" (Enclorsement Required) r'-t Restricted Delivery Fee ' F:\FILES\DATAFILE\General\Documents\9813-3.pral/tde Created: 12/09/02 04:43:08 PM Revised: 04/22/03 01:23:51 PM 9813.3 SCOTT DEAVEN, Plaintiff V. JODY DEAVEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5893 CIVIL ACTION - LAW IN DWORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw the Divorce Complaint filed in the above action and mark the action discontinued without prejudice. Date: MARTSON DEARDORFF WILLIAMS & OTTO By '"~~ Thomas J. Williams,~j~uire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attomeys for Plaintiff CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: John A. Abom, Esquire ABOM & KUTULAKIS 8 South Hanover Street Suite 204 Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: