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HomeMy WebLinkAbout07-1136IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, Civil Action - Law Plaintiff V. No. 2007 Christopher A. Helm, Defendant In Divorce a v.m. 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 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, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. 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. Pennsylvania Bar Association Lawyer Referral Services Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, Civil Action - Law Plaintiff V. No. 2007 - //34 Civu???rJt. Christopher A. Helm, Defendant In Divorce a v.m. COMPLAINT UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE NOW comes the Plaintiff and for cause of action against the Defendant says: Plaintiff is Sherry Helm, who resides in Cumberland County, Pennsylvania with a mailing address of 215 Ridge Avenue, Shippensburg, Pennsylvania 17257 since September 2005. 2. Defendant is Christopher A.. Helm, whose last known residence and present whereabouts are in Cumberland County, Pennsylvania with a mailing address of 215 Ridge Avenue, Shippensburg, Pennsylvania 17257 since September 2005. 3. Plaintiff and defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on September 27, 1997, at Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or in any other jurisdiction. 6. The marriage is irretrievably broken. 7. The plaintiff has been advised of the availability of counseling and that the 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. Barbara B. Tow send Attorney for Plaintiff I hereby verify that the facts set forth in the foregoing instrument are true and correct to the best of my knowledge, information and belief, and that I make this verification subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to Authority, as authorized by the Judicial Code and Penrisylvania Rules of Civil Procedure. Date: c) ? ?'rL-7 T P N w r-s+y- _-{ P ? ?W 7- 1 -e Co -G IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, : Civil Action - Law Plaintiff V. : No. 2007 - 1 136 Christopher A. Helm, Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA COUNTY OF FRANKLIN : SS Barbara B. Townsend, Esquire, being duly sworn according to law, deposes and says that she sent a true and correct copy of the Complaint in Divorce to Christopher A. Helm, at his last known address of 215 Ridge Avenue, Shippensburg, Pennsylvania 17257;" by certified mail, restricted delivery, addressee only, No. 7099 3400 0017 6228 1430, receipt attached hereto, postage prepaid on March 5, 2007, from the United States Post Office at Chambersburg, Pennsylvania. ZZBarbara B. T nsend Sworn and subscrib d to before me this day of , 200 / A14 /3L/ 1'4 At Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Teressa D. Bard, Notary Public Chambersburg Boro, Franklin County My Commission Expires Feb. 5, 2001 ¦ Complete items 1, 2, and 3. Also complete item 4 R Restricted Delivery is desired. -a 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: Chri s4o pher q jry) ai5 kidge- AVe(IUL -d" i P P4 rl J l it cl PA -713t3,1 X cr./ .° B. Received by P)yldld Name a of h D. Is delivery address different 1? If YES, enter delivery address V? 1-;Jk 3. Servic pe iriied Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (rmnsfer from service label) ?? 4 (; r 3 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 O M a A Postage $ rll ill Certified Fee Return Receipt Fee t? (Endorsement Required) r-3 p Restricted Delivery Fee (Endorsement Required) PSstrnaVV Herd f ? ^ dl U >? O Total Postage & Fees $ O ? Reoi is V N e (Please Print C1rly (to be completed by mailer) M rrS c7 e -Aran Street No.;?r Box No. O City fate, ZIP +4 ?hi b l t r-c PA r? DID n ?C rn tV C:D C? C N O rn ,-q 7 -.1J IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, Civil Action - Law Plaintiff V. No. 2007 - 1 136 Christopher A. Helm, Defendant In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed on March 1, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. 1 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. 4904 relating to unsworn falsification to authorities. Date: 'r_? //1 a, kh 11 01 aintiff CD - IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, V. Christopher A. Helm, Plaintiff Defendant Civil Action - Law No. 2007 - 1 136 In Divorce a v.m. 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 entry of a final decree of divorce without notice. 2. 1 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. 1 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 Waiver are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: S erry Helm, aintiff y.y 1 - CD IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, Civil Action - Law Plaintiff V. No. 2007 - 1 136 Christopher A. Helm, Defendant In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed on March I, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. 1 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. 4904 relating to unsworn falsification to authorities. Date: ' Defendant ??? ? -, C') ? C3 C.: ? -rt .. _,?n. ? ? ?? ? ,; ? :., ? °? ;?,,? ?-? _.? ::? -• ?? rv ;? ?z? . ? ?. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, Plaintiff Civil Action - Law V. Christopher A. Heim, Defendant No. 2007 - 1 136 In Divorce a v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that 1 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. 1 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 Waiver are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: b ' 13 - 0-7 dn;?WL 14 a-?? - Christopher A. Helm, Defendant ? -'- ? 17 _? ?.? ? -- ?.J ?,=.? . F IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA- CUMBERLAND COUNTY Sherry Helm, : Civil Action - Law Plaintiff V. No. 2007 - 1 136 Christopher A. Helm, Defendant In Divorce a v.m. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit to record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Complaint was mailed to the defendant on March 5, 2007, by certified mail, restricted delivery. Defendant accepted service of the complaint on March 8, 2007. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: by plaintiff June 9, 2007; by defendant June 13, 2007. 4. Related claims pending: None. 5. Date plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the prothonotary: June 20, 2007. Date defendant's Waiver of Notice in 3301(c) Divorce was filed with the prothonotary: June 20, 2007. J Barbara B. Tow, end Attorney for Plaintiff a ss#f? v?t V/ f { V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. w.SHERRY HELM NO. 2007 1136 VERSUS CHRISTOPHER A. HELM DECREE IN DIVORCE AND NOW, 1%3\N (o IT IS ORDERED AND DECREED THAT SHERRY HELM , PLAINTIFF, AND CHRISTOPHER A. HELM -,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; NONE /A By THE COURT: ?fy,y? ? ? ? ?? 1 d : ?l •G. ., ? ,_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lm Plaintiff Vs File No. 2L(?-l : IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / de# in the above matter, [select one by marking "x'] prior to the entry of a Final Decree in Divorce, or 'after the entry of a Final Decree in Divorce dated, 1Lx _J4 ZW hereby elects to resume the prior surname of ke-CriA )3 ^Xn rj C , and gives this written notice avowing his / her intention pursuant t th-e)provisions of 54 P.S. 704. Date: 71? S' ature ri, Z A.4 4. /4' Lt'za? SSigEatuiW of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF bra v? k I n ) On the _Lq - day of , 200 before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he-/ she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. f Notary Public COMMONWEALTH OF PENNSYLVAMp Notarial Seal Teressa D. Bard Notary Public Chamberaburg Boro, Fraddin Y Comm U%n Expires Feb. 5, 2001 ??... V'? ,... -? r-? C"? t: - .?°' •_ cF-: ?,-. {Y } ;: ?_ t ??.. -J ?+ ., ,_ ?, ?} ??, ..?c c%