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Home My WebLink About03-0100THERESA L. MOORE, Plaintiff, VS. JAMES R. MOORE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - 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 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, 1 Courthouse Square, 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. I.AWYER REFERRAI. SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 (717) 249-3166 THERESA L. MOORE, Plaintiff, VS. JAMES R. MOORE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. C53 - Civil Action ~ In Divorce COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff, Theresa L. Moore, is an adult individual currently residing at 7073 Carlisle Pike, Lot 85, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, James R. Moore, is an adult individual currently residing at 801A Valley Green Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plainfiffhas been a bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 19, 2001, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There has been no prior action of divorce or annulment of marriage between the parties. 6. Defendant is not a member of the Armed Services of the United States of America or its Allies. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays that a Decree be entered divorcing the said Plaintiff and Defendant from the bonds of matrimony heretofore contracted between them. 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 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities. Date: THERESA L. K40~ORE' ~ Respectfully submitted, TOMASKO & KORANDA, P.C. 219 State Street Harrisburg, PA 17101 Telephone: (717) 238-1100 MICHAEL A. KORANDA PA ID# 58808 THERESA L. MOORE, Plaintiff, VS. JAMES R. MOORE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-100 (CIVIL TERM) · Civil Action - In Divorce AFFIDAVIT OF SERVICE_ COUNTY OF DAUPHIN : SS: COMMONWEALTH OF PENNSYLVANIA ' I, Michael A. Koranda, Esquire, being duly sworn according to law, hereby deposes and says the following: 1. On or about January 9, 2003, I served the Complaint in Divorce in the above- captioned matter on the Defendant, James R. Moore, by regular and certified mail restricted to the Defendant. 2. On January 10, 2003, the Defendant accepted delivery of the Complaint, as evidenced by the return card attached hereto. MICHAEL A. KORANDA SWORN TO and subscribed before me this 'q~ of~ 2003- Ic ~ N'O'T~:~IAL SEAL . I Deborah J. Worthingte~, _Notaff Public [ Her~'~y, Dauphin COunty I COmmission E 'res Aug, 25 2003 I · 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. ,Nticle Addressed to: 2. Article Number (Transferfromsendcelabel) 7BD'I, 194B A. Received by (Please Print Clearly) B. Date of ~ I D:~I~f'd~iver~ ad'dress'different from item 17 [] Yee If YES, enter delivery address below: [] No 3. Service Type ~Certified Mail [] Registered [] Insured Mail [] Express Mail [] Return Receipt for Memhandlea [] C.O.D. 4. Rea~dcted D~ivery? (Extra Fee) 0001 2175 7269 PS Form 3811, March 2001 Domestic Retum Receipt 102595-01-M-14~4 INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. THERESA L. MOORE, Plaintiff Versus JAMES R. MOORE, Defendant DECREE IN DIVORCE AND NOW ..... I~//.,~. 2,2.. .............. I~ .......it is ordered and decreed that TU~.RESA ~.. MOOR~., plaintiff, and .................... J.~.s. 5.: ?.qq~.E.,. ....................... 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; THERESA L. MOORE, VS. JAMES R. MOORE, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 03-100 CIVILTERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under §3301(c) (Strike out inapplicable section). Date and manner of service of the complaint: certified mail, restricted delivery January 10, 2003, by regular mail and Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff Apr±l 1.5, 2003 ; by defendant Apr±l 15, 2003 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: NONE Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Attorney for Plaintiff / Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BRADLEY S. WHISTLER NO. 4655 of 2000 VERSUS KRISTINA M. WHISTLER AND NOW, DECREED THAT DECREE IN DIVORCE , IT IS ORDERED AND BRADLEY S. WHISTLER , PlaiNTiff, AND KRISTINA M. WHISTLER , 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; Spousal support, alimony pendente lite, alimony, equitable distribution of maritalproperty,~c costs and expenses BY T ATTEST: ~ J- )NOTARY BRADLEY S. WHISTLER Plaintiff KRISTINA M. WHISTLER Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 4655 OF 2000 CIVIL TERM : CIVIL ACTION - CUSTODY :IN DIVORCE PRAEClPE 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 breakdown under Section 3301 (c) of the Divorce Code 2. Date of the execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: By plaintiff: 4/19~03; By defendant: 4/18/03. 3. The following economic claims have been made and are reserved: spousal support, alimony pendente lite, alimony under sections 3701(a) and 3702 of the Divorce code, equitable distribution of marital property under section 3502(a) of the Divorce Code, and counsel fees, costs and expenses under sections 3104(a)(1), 3323(b) and 3702 of the Divorce Code. 4. Date of execution of Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: By plaintiff: 4/19/03; By defendant: 4/18/03. Date Respectfully Submitted, GREASON LAW OFFICE Carlisle, PA 17013 (717) 241-3030 ID #78269