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Home My WebLink About97-01905 \ ~ ~ ... ~ '" ~ \. ~ ~ ~ '. \.." ....... '1'-. \ I I ~ \" \~ ;--.. ~ .;) <.:J \t) ~ ~) '1- ;)Lj. 97 - C?~/l.4, C<'>/'1 m 014 (tel -10 f+U7 S-IO.wL ,(.JaI,,,-\:.... m:l,lccl -Ie> ~--\.;J., : CAROL PATRICIA PARKER, Plaintiff IN TilE COURT OF COMMON PLEAS : : CUHBERLANO COUNTY, PENNSYLVANIA : VS. JAMES PEABODY PARKER, Defendant CIVIL DIVISION : : NO. 97-1905 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 breakdnwn under S3JOl(cl ~~~tiKl of the Divorce Code. (Strike out inapplicable sectionl. 2. Date and manner of service of the complaint: April 1/" 1997, Certified Mail, Restricted Delivery, Return Receipt Requested, postage prepaid 3. Complete either paragraph (alar (bl. (a) Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by plaintiff July 21, 1997 by defendant July 21 , 1997 (bl(ll Date of execution of the affidavit required by ~JJ01(d) of the Divorce Code: : (7.) Date of filing and service of the plaintiff's affidavit upon the r~spondent: 4. Related claims pending: No claims mised, 5. Complete either (a) or (bl. (a) Date and manner of service of the notice of intention t~ file praecipe to transmit record, a copy of which is attached: (bl Date plaintiff's filed with the Prothonctary: Date defendant's filed with the Prothonotary: Waiver of Notice in SJJOI(cl Divorce was ~ ;)-1,ln1- Waiv~r or Notice in SJ301(c) Divorce was 9,~9<..Q.d ;}.l 1,;1). ~f~J ! , I I i I ,~ I r I I, ,tJo.,' ., 0> L.D ~ C -.l :s. f_ ~i -oUJ r.: crilL. r- ~--'-- N V1 ~~~ ',J -:'1;..:- ;~ ~c.:.. -0 ,- -r~ ::..: 9@ \.: .......0 -"0 ta 0 ;':;:c z '::l :;;! ==l <=) ~ CAROL PATRICIA PARKER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97 - / 'it' r (!(t~..{J r;.- JAMES PEABODY PARKER, Defendant : CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND m.A 1M 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 in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013. IN 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 Countv Courthouse Carlisle. PA 17013 Telephone: /7171 240-6200 fl\div\parker.com.3-97 CAROL PATRICIA PARKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. q 'j. /t)v \~ (1';';"/0- CIVIL ACTION LAW IN DIVORCE v. JAMES PEABODY PARKER, Defendant COMPLAINT 1. The Plaintiff in this action is Carol Patricia Parker, an adult individual, who currently resides at 305 Thomas Drive, Apt. #1, Mechanicsburg, PA 17055. 2. The Defendant in this action is James Peabody Parker, an adult individual, who currently resides at 305 Thomas Drive, Apt. #1, Mechanicsburg, PA 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on October 22, 1994, in Steelton, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. -1- 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. The Plaintiff requests the court to enter a decree of divorce. 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 P.C.S. 54904, relating to unsworn falsification to authorities. Date: r// '3/ if' 7 ( / r:' /7tJJ-.fla~'r/~a.d'$J,:'J( CAROL PATRICIA PARKER STONE LaFAVER & STONE ~ /"'7 ---.... /' ~~~ZAaE~B. STONE, Esonuw' Supr~cou #60~~"- 414 Bridge Street P.O. Box E New Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff -2- tl\dlv\lmal1Irv.att . CAROL PATRICIA PARKER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v. NO. 97-1905 CIVIL . . JAMES PEABODY PARKER, . CIVIL ACTION LAW . Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) ss. COUNTY OF CUMBERLAND ) I, ELIZABETH B. STONE, of Stone LaFaver & Stone, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, James Peabody Parker, at 305 Thomas Drive, Apartment 1, Mechanicsburg, PA 17055, by United States Certified Mail, postage prepaid, restricted delivery on April 14, 1997, as evidenced by the attached Certified Mail return receipts. SWORN TO AND SUBSCRIBED befo~ me. this 2~ Tit day of b/'u j , 1997. t(or,\fi:,"~. ~:["'L 1~/\Yi: I!. l t;,::,.c,', ;; ;~':'l Pdt.>I"" , 'I CU'IlLlCI; l'lJ etl'U, t;'J:la;(', l.,~~l~ I..n. , " '. ~ " 'I 'J l '1 ,,' 1 ; . , ' COlTlilli~sjon t:~pllC~ huHC \, ,..." L'J u__ . . ,- ,:"J " __J , ., .., I , ., ) " :'..1 '.,J, ,. ';j ;; J jll' 'I :":" ,l -0.; ( ( ...;..... _. ,- '- () 1.0 0 c:: ....J -" r:'.. t- ~ -or..; c:: nlfl~ r- '-~~ ~=-! N ;:C '0 (Jl;; ...) -,". --J :;: c:; '"tl J.=H .~~C' :t: (")- Z(') (-~t-" t.:'! 0'" Pr:: "'" -/ .'" ~ '::I ~ 0 (") <D 0 C -.J "I, "'O[u '- ;;J c:: tii~ rJl"j r- Z:.u N :~ ~~j~~ 0 -.,,', 1:a ~i:.) ..." '"(" :I: ~~ "-.. ~ '':'0 W >c .. ~ '? :::l ~ s.! 0 fl\dLv\con..nt..tf CAROL PATRICIA PARKER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . ]: V. : NO. 97-1905 CIVIL i JAMES PEABODY PARKER, Defendant . CIVIL ACTION - IN DIVORCE . AFFIDA vrr OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on April 11, 1997. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 4. 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. 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. S 4904 relating to unsworn falsifica- tion to authorities. Daft ..2/ /797 , G'a~~~ tf~'l/ CAROL PATRICIA PARKER, Plaintiff . ! () l.O 0 c: --.l -n ;-: '- ::;J "tJr..d C . i:!l rill" ,- ..:.,~ ;~:J) N ~t~~ ".0 ::J ::? :i~ .' ::~n .. -~ :':~ \ J ~ Om .,...'1-- :;-l ~ => ~ (;:) -< fl'dlY\l~w&lY..not CAROL PATRICIA PARKER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-1905 CIVIL JAMES PEABODY PARKER, Defendant CIVIL ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER S 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. S 4904 relating to unsworn falsifica- tion to authorities. e.~ ~/~ CAROL PATRICIA PARKER, Plainti f Date:J1I.J~ /99? ,/ n \l:) 0 c: -' ..., ~ r_ :;:l ". -,;)u.' r.:: :ii~ nlj" ,- ;?: ~...:. N -n t~~.:. '" -, , Q ~~...:.: -U ~- o:B ~_:; (I - -r~ :~: (~l r_ ~ U ,.c..: ~ - ,~ ::~ ::q (;:l .....