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Home My WebLink About97-04854 ~ ~ ~ ~ t ~ " " , , \ , , , . I ,II i' i'. i'l , , , , , " , , "I , " " , , " " , , 'i I , , 'i. , , ~ ',I , , "I , ' j' , , I.' " , i ," I'"~ , , , , , ' ( " " 'I, " " " " ,:, I I r ,j, I' I , " " , ,I I : , , " ~ , " IF, I I " ~i' , ! ", " i., , , I( " , , Ii i( ii' ;' I d , , , , i.'., :1 ,I HEATH A. JONES, Plaint,1. H IN THE COURT OF COMMON PLEAS or CUMBER/MD COUNTY, PENNSYLVANIA CIVIL DIVISION v JODI L. JONES, NO, 97-4854 CIVIL TERM Defendant PllUCII'II TO '1'IIANINIT DCOm To the P~othonota~YI T~anlmit the ~eco~d, together with the following into~mation to the cou~t fo~ ent~y of a divo~ce dec~eel 1. G~ound fo~ divorce: irret~ievable b~eakdown unde~ 5330l(c) 330l(d) (1) of the Divo~ce Code, (Strike out inapplicable lection.) 2. Date and manner of, le~vice of the Complaint: September 12, J,997 - certified mail, ~elt~icted delivery 3. Complete eithe~ paragraph (a) or(b). (a) Date of execution of the affidavit of the Divo~ce Code: by Plaintiff ill2..._ December 20, of con.ent requi~ed by 53301(c) 1997/ by Defendant Decembe~ 16, (b) (1) Date of execution of the affidavit r.qui~ed by 53301(d) of the Divorce Code: I (2) Date of filing and service of the Plaintiff'. affidavit upon the Respondent: 4. Related claims pending: No claims pending 5, Complete either (al or (bl, (a) Date and manner of service of the notice of intention to tile pr.ecip. to transmit ~ecord, a copy of which il attached: (b) Date Plaintiff's Waiver of Notice in 53301(c) Divo~ce w.. filed with the Prothonotary. December 23, 1997 Date Defendant's Waive~ of Notice in 53301(c)' Divorce we. filed with the Prothonotary. December 23, 1997 ~ Chri.topher C. Hou.ton, Attorney for Plaintiff 52 W.st fomfret Street Carlisle, fA 17013 71'1-241-5970 E.quire " ~ . . , if ~. i , \ , \ , ~.~.- .- f- ....,-.. ~ HEATH A. JONES, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v I CIVIL DIVISION - LAW I 97-~ JODI L. JONES, I CIVIL TERM Defendant I I IN DIVORCE ~ICE 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, 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 HOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THB OFFICE SBT FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE I 717 - 240-6200 HEATH A. JONES, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v I CIVIL DIVISION - LAW I JODI L. JONES, 97- oLIIS"1 CIVIL TERM Defendant I , I IN DIVORCE COMPLAINT Plaintiff, Heath A. Jones, by his attorney, Christopher C. Houston, Esquire, sets forth the following: 1 Plaintiff, Heath A Jones, is an adult individual residing at 915 North pitt Street, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Jodi L. Jones, is an adult individual residing at 719 Jackson Road, Apollo, Armstrong County, Pennsylvania. 3 The parties were married on February 23, 1995, in Carlisle, Cumberland County, Pennsylvania. 4 Plaintiff has been a resident of the Commonwealth of Pennsylvania for at least six months prior to the oommenoement of this aotion. 5 This aotion is not collusive. 6 There have been no prior aotions for divorce or annulment in this or any other jurisdiotion within the knowledge of the Plaintiff. . , HBATH A. JONBS, I IN THB COURT OF COMMON PLBAS OF Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I v I NO. 97-4854 CIVIL TBRM I JODI L. JONl!lS, I Defendant I IN DIVORCE APrIDAVIT or SERVICE I, Christopher C. Houston, Esquire, being duly sworn according to law do depose and state that a copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead and a Notice of Availability of Marriage Counseling was served on the Defendant, Jodi L. Jones, by Certified Mail - Return Receipt Requested, restricted delivery, a copy of said return receipt evidencing delivery being attached hereto. Said service 011 September 12, 1997. C r stoph C. Houston, Ssqu re Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 717 - 241-5970 Sworn and subscribed to 1'''- before me this ..,f.:~ day of ...J.i, (t,nt.4l.',,- , 1997. " , 4AU\...: d. ..O~ l.v Notary Publi -- -,......~- __- - ......eo.r.N life, ' ....._..._ ~ HBATH A. JONES, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v I CIVIL DIVISION - LAW I JODI L. JONES, I 97-4854 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT or CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on September 8, 1997. 2, The marriage of Plaintiff and Defendant is i1retrievably broken and 90 days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. I verify that the stntements 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 un.worn falsification to authorities. DATEI ()l1ce.... i", ). () It'O ~~ - " rfI' HBATH A. JONBS, I IN THE COURT OF COMMON PLEAS OF Plaintifl I CUMBERLAND COUNTY, PENNSYLVANIA I v I CIVIL DIVISION - LAW I JODI L. JONES, I 97-4854 CIVIL TERM Defendant I IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 8, 1997. 2, The marriage of Plaintiff and Defendant is irretrievably broken and 90 days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in 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. S 4904 relating to unsworn falsification to authorities. DATl!l1 /,J - / (p - 9 7 #i'ft; K ~<l-J i L. Jom!S 'I't "., ',; . - 1, ,.) ,<I, , ....' too i" II!. , ( ~: ' ~:> ;,~~'::. t:::I; ."~f (.. I' (.J ~-,,; Ul ,':-'f';~ -: 1::'~_~I'J'):. if, ~~ "...~ 'I j..'. 'j':'~;: ~ _~'L ~l~lt!r';:'J!.j j,-:: '~~'\~,~ ';:::.. ,''',', f to ...-t ,t, .jii;,i,' 'l;f , tb.~t ~r H.;a ;t:r J';.1 t'! ,'1.,( !I ,\-j' .; 10-/) ;:-I'Jio' .~. 't.'j 4,"",>'11 ~:~ ' , . G: L," r-.... 1:./' ~'l-~, :;, ;; ~~. ~-,:"; r!U'''' 1,,"; Ir.'c!J' ,~ ..) t\ i' r~ If) " , .. :',. ...., I' I ,;';'1 I I ,', iI , , I i;" I, {'i , ,', " u , I.; C,-' \ ,~, j It' ._\.. h ~,l t '~, r- :-J ,I G' ::.J , I I' 'I " r,1 ,I f 'c, ',I HEATH A. JONES, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v I CIVIL ACTION - LAW I JODI L. JONES, I 97-4854 CIVIL TERM Defendant I IN DIVORCE KAIVBR or NOTICE OF INTENTION TO REQUEST ENTRY or A DIVORCE DBCRBB UNDBR S 3301(c) OF THB DIVORCB CODr. 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. r 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 falsification to authorities. Date I {)ecef"1/u.,. a" Iffr ~-~- Heath A. Jopis' Plaintiff- " ~ ~ .... " " ... ,'" ~ " , '" J1t,' fI j- <1" ... .~ . ~. t-. '\! "~.lt~. . .. ''''\ ',' ".. ,. 'I) ~ ~ J j ,,. , j :to' c.I "Ie "'?4 ~ ::~~ ' IX' ~"\ LJ.l(" (;.)(li f,~.i c:Y J. ~. I.", l'" :1 ri:1 r--- Li:~ ;r" , ~c~l ., .;' ,'~ ,I ...~' I' ~.I I! n' I . ~l" 'j ,;'I:,.t: 1.1)' '--', C": U' j :..) I,;