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HomeMy WebLinkAbout07-1137LORI A. DIXON, : IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA I3 ? ??'r'r1 V. :NO. MICHAEL A. DIXON, JR., : CIVIL ACTION -- DIVORCE Defendant 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 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, One 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. Cumberland County Bar Association 23 South Bedford Street Carlisle, PA 17013 (717) 249-3166 LORI A. DIXON, : IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLANDCOUNTY, PENNSYLVANIA V. :NO. u ZA. DIXON, JR., :CIVIL ACTION -- DIVORCE Defendant COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Lori A. Dixon, whose mailing address is post office box 6806, Harrisburg, Pennsylvania 17112. 2. Defendant is Michael A. Dixon, Jr., who resides at 21 White Oak Boulevard, Mechanicsburg, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 11, 1996, in Cumberland County, Pennsylvania. 5. The parties have been living separate and apart since on or about November 11, 2006, a date prior to the filing of this Complaint. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and of the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff waives the right to request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. Plaintiff avers that this ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter a Decree of Divorce. DATED: Z - Z g,-- Q 7 Respect, y submitted, Nora F. Blair Supreme Court ID 45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VERIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dated: •F Q c- (Aj a? r rv G3 W 0 ?a ,-) -?C LORI A. DIXON, Plaintiff V. MICHAEL A. DIXON, JR., Defendant :IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1137 Civil Term :CIVIL ACTION -- DIVORCE ACCEPTANCE OF SERVICE I, Michael A. Dixon, Jr., am the Defendant in the above-captioned divorce matter. I have accepted service of the Complaint in Divorce as of this the 16 day of h4drC?' , 2007. t Michael A. Dixon, Jr. T-4 q ?-. 15 . LORI A. DIXON, Plaintiff V. MICHAEL A. DIXON, JR., Defendant :IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1137 Civil Term CIVIL ACTION -- DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on March 1, 2007, and served on March 10, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing of the Complaint and service of the Complaint on Defendant. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of Divorce Decree or at any time after the signing of this Consent if I have also signed a Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code. 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. DATED: 3 y?e8' Get Q. y[,h. LORI A. DIXON Plaintiff ov C ? a _ D33 o rn LORI A. DIXON, Plaintiff V. MICHAEL A. DIXON, JR., Defendant °`. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1137 Civil Term CIVIL ACTION -- DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33.01(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 Decree of Divorce 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 that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATED: 3. Llo ff LORI A. DIXON Plaintiff a r 0, Q S r? LORI A. DIXON, PLAINTIFF V. IN THE COURT OF COMMON PLEAS C[GERLAND COUNTY, PENNSYLVANIA NO. 07 - 1137 CIVIL TERM MICHAEL A. DIXON, JR. IN DIVORCE DEFENDANT AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 1, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of 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. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Z Z? -/4" MICHAEL A. DIXO , C LORI A. DIXON, PLAINTIFF V. MICHAEL A. DIXON, JR. DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 1137 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE ST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 'G /,- MICHAEL A. DIXON, R. ra 9 gg f..- s , MIX ?_ Ml LORI A. DIXON, Plaintiff V. MICHAEL A. DIXON, JR., Defendant :IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1137 Civil Term CIVIL ACTION -- DIVORCE PRAECIPE TO TRANSMIT RECORD UNDER § 3301(c) OF THE DIVORCE CODE To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. 2. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. Date and manner of service of the complaint: (a) Date of service: March 10, 2007. (b) Manner of service: Acceptance of Service 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: (a) By the Plaintiff. March 4, 2008 (b) By the Defendant: February 29, 2008 4. Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (a) By the Plaintiff: March 4, 2008 (b) By the Defendant: February 29, 2008 5. Related claims pending: NONE DATED: May 1, 2008 Nora F. Blair, Esquire Attorney for Plaintiff ?? " ' ,... c ?"? t 3 `=?' i : ? ....c ,.., - ?., . . . ? t ?? t . ?., Yi -? ? 3 ? LORI A. DIXON, Plaintiff V. MICHAEL A. DIXON, JR., Defendant :IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1137 Civil Term : CIVIL ACTION -- DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Lori A. Dixon, being duly sworn according to law, deposes and says that she is a party in the above-captioned divorce action, and she hereby elects to resume her prior surname of Haagen, and, therefore, gives this written notice avowing said intention, in accordance with §704 of the Act of November 15,1972, P.L. 1063, as amended, 54 Pa. C.S. 704. /-? Sworn to and subscribed to before me this 2,'160 _ day of M,q y , 2008. i Mary Public C01840NWEALTE OF PENNSYLYAW _ NOTARIAL x Lowrr W07U PnM. IN cammomi" ?C COMMONWEALTH OF PENNSYLVANIA Lori A. Dixon To Be Known As: vau. a. ?044 - Lori A. Haagen NOTARIAL SEAL NOVA F. DI.AIR, N*Wy Pd" IMM 1' at- 7w*, Dev Wn OwNy CmwNim mom Inns 6, ni I rc -tok. fl, k SZi 19 ? 0 ? fi ?` g - t C ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LORI A. DIXON „ Plaintiff VERSUS MICHAEL A. DIXON, JR. Defendant DECREE IN DIVORCE N 0. 07-1137 Civil Term AND NOW, 1*7 /3` , Loo B, IT IS ORDERED AND DECREED THAT LORI A. DIXON , PLAINTIFF, AND MICHAEL A. DIXON, JR. , 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; Na A) E PROTHONOTARY