HomeMy WebLinkAbout03-0172IN HIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff, No. C)~ -- l ?,,~
BOYLE,
Defendant.
COMPLAINT UNDER SECTION
3301(C) OR3301(D) OF THE
DIVORCE CODE
Filed on behalf of the PLAINTIFF
Counsel of Record for this Party:
MICHAEL B. GREENSTEIN, ESQ.
PA ID #62950
VOELKER, GRICKS & GREENSTEIN, LLP
Suite 1220, Grant Building
310 Grant Street
Pittsburgh, PA 15219
(412) 281-3007
(412) 391-0668 facsimile
tN TI lI'_ COl JRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
; .\:4{ )N B _)5 LE.
Plaintiff, No. (2)2
- /?ok
INA BOYLI:~,
Defendant.
NOTICE TO DEFEND AND CLAIM RIGHTS
'~{m bare been sued in court. If you wish to defend against the claims set forth in the following pages, you
~m~:,1 take prompt action. You are warned that if you fail to do so, the case may proceed without you and the
( ',mri ma? enter a decree of divorce or annulment against you. A judgment may also be entered against you for
~mx olher claim or relief requested in these papers by the plaintiff. You may lose money or property or other
~'i:shi sim ponant to you, including custody or visitation of your children.
Whcn linc ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request
~ ~ria~c counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of
Prothonotary. Cumberland County, One courthouse Square, Carlisle, Pennsylvania 17013
1!: YOI ~ DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR
!' ~ P !:'NS F,S BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
, ~,d ~1/~. ~ OF THEM.
SI IOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
1..?, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
1717) 249-3166
tN Tt I1'~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
~I ",SON B()YLE.
Plaintiff, No. (~3 /~ /~o2~
BOYLE,
Defendant.
COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE
Plaintiff is Jason Boyle, who currently resides at 3415 Lorraine Avenue, Room 207, Ft.
Alaska 99703, since November of 2001.
Defendant is Cristina Boyle, who currently resides at 404 Walnut Bottom Avenue,
t¥:nsbt I g, Cot qty of Cumberland, Pennsylvama 17257, for a period greater than six month previous
filing of this Complaint.
3. Defendant has been a bona fide resident in the Commonwealth for at least six months
immcdialcly previous to the filing of this Complaint.
The plaintiff and defendant were married on October 5, 2001 at Pheonix City,County of
,~ ~:ch. Alabama.
There have been no prior actions of divorce or for annulment between the parties.
The marriage is irretrievably broken.
7. Plaintitf' has been advised that counseling is available and that plaintiff may have the right to
;,.,:?c~ ~l]at the court require the parties to participate in counseling.
Plaintiff requests the court to enter a decree of divorce.
that the statements made in this Complaint are true and correct. I understand that false
herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to un-sworn
fication to authorities.
~'JasoI t~oyle-7.Pt~tiff .-~]
~~1~1 aGin~l i EFfN S ~'EIN y
PA ID #62950
1106 Fifth Avenue
Pittsburgh, PA 15219
(412) 232-1218
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
Plaimiff,
No. 03-172 Civil Term
VS.
CRISTINA BOYLE,
Defendant.
ACCEPTANCE OF SERVICE
Filed on behalf of the PLAINTIFF
Counsel of Record for this Party:
MICHAEL B. GREENSTEIN, ESQ.
PA D #62950
VOELKER, GRICKS & GREENSTEIN, LLP
Suite 1220, Grant Building
310 Grant Street
Pittsburgh, PA 15219
(412) 281-3007
(412) 391-0668 facsimile
ORIGINAL
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
,~('~N ,~oYLE.
Plaintiff,
No. 03-172 Civil Term
Defendant.
ACCEPTANCE OF SERVICE
i :it:c el-,~ service of the Complaint under Section 3301(c) or 3301(d) of the Divorce Code.
::~:~.:: .![mua~.'y 10. 2003
Cristina Boyle, Defendant (at
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
VS.
Plaintiff,
No. 03-172 Civil Term
CRISTINA BOYLE,
Defendant.
DEFENDANT'S AFFIDAVIT OF
CONSENT AND WAIVER OF
NOTICE
Filed on behalf of the PLAINTIFF
Counsel of Record for this Party:
MICHAEL B. GREENSTEIN, ESQ.
PA ID #62950
VOELKER, GRICKS & GREENSTEIN, LLP
Suite 1220, Grant Building
310 Grant Street
Pittsburgh, PA 15219
(412) 281-3007
(412) 391-0668 facsimile
ORIGINAL
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JA S ON BOYLE,
Plaintiff, No. 03-172 Civil Term
VS.
CRISTINA BOYLE,
Defendant.
AFFIDAVIT OF CONSENT
2003.
A complaint in divorce under §3301(c) of the Diw>rce Code was filed on January 10,
2. The marriage of the Plaintiffand Defendant is irretrievably broken and 90 days have
elapsed fi.om the date of filing and service of the complaint.
3. I consent to the entry ora 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 un-sworn
falsification to authorities.
DATE:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
Plaintiff,
No. 03-172 Civil Term
VS.
CRISTINA BOYLE,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER §3301(c) AND §3301(d) OF TI-IE 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 ifI 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. § 4904 relating to un-sworn
falsification to authorities.
DATE:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
VS.
Plaintiff,
No. 03-172 Civil Term
CRISTINA BOYLE,
Defendant.
PLAINTIFF'S AFFIDAVIT OF
CONSENT AND WAIVER OF
NOTICE
Filed on behalf of the PLAINTIFF
Counsel of Record for this Party:
MICHAEL B. GREENSTEIN, ESQ.
PA ID #62950
VOELKER, GRICKS & GREENSTEIN, LLP
Suite 1220, Grant Building
310 Grant Street
Pittsburgh, PA 15219
(412) 281-3007
(412) 391-0668 facsimile
ORIGINAL
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
Plaintiff,
No. 03-172 Civil Term
VS.
CRISTINA BOYLE,
Defendant.
AFFIDAVIT OF CONSENT
2003.
A complaint in divorce under {}3301 (c) of the Divorce Code was filed on January 10,
2. The marriage of the Plaintiffand Defendant is irretrievably broken and 90 days have
elapsed from the date of 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 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 un-sworn
falsification to authorities.
3,3
DATE: l t'Cil
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
Plaintiff,
No. 03-172 Civil Term
CRISTINA BOYLE,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER §3301(e) OF TIlE 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 ifI 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. § 4904 relating to un-sworn
falsification to authorities.
DATE:.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
Plaintiff,
No. 03-1'72 Civil Term
VS.
CRISTINA BOYLE,
Defendant.
PRAECIPE TO TRANSMIT RECORD
Filed on behalf of the PLAINTWF
Counsel of Record for this Party:
MICHAEL B. GREENSTEIN, ESQ.
PA ID #62950
VOELKER, GRICKS & GREENSTEIN, LLP
Suite 1220, Grant Building
310 Grant Street
Pittsburgh, PA 15219
(412) 281-3007
(412) 391-0668 facsimile
ORIGINAL
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JASON BOYLE,
VS.
Plaintiff,
No. 03-172 Civil Term
CRISTINA BOYLE,
Defendant.
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 breakdown under §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: January 10, 2003 by regular U.S. first
class mail, accepted in writing by the Defendant.
3 Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code:
by plaintiff, April 23, 2003; by defendant, April 19, 2003.
4. Related claims pending: (none).
5. Date plaintiff's Waiver of Notice was filed with the Prothonotary: concurrent with the
filing of this Praecipe to Transmit Record.
Date defendant's Waiver of Notice was filed with the ProJaholaotary: April 29, 2003.
~ich~l B. [3rdeefistein /"
Attorney for Plaintiff
IN
THE COURT OF COMMON
JASON
VERSUS
CRISTINA BOYLE
OF CUMBERLAND COUNTY
STATE OF ¢' , PENNA.
BOYf. F:
PLEAS
No. 03-172 Civil term
DECREE IN
AND NOW,
DECREED THAT
DIVORCE
JASON BOYLE
,,:t' 3.' °
, ~>'~, It IS ORDERED AND
, PLAINTIFF,
AND
CRISTINA BOYLE
, 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
ATTEST:
p J'
ROTHONOTARY