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Home My WebLink About03-0194RHONDA J. MORRISON, Plaintiff VS. TAWN S. MORRISON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2003-/ / CIVIL : : 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 will proceed without you and a decree in divorce or annulment may 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 or 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 at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 RHONDA J. MORRISON, : Plaintiff : : V. ; : TAWN S. MORRISON, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003- Iq ~ CIVIL IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 C OR 3301 D OF THE DIVORCE CODE AND NOW comes Rhonda J. Morrison, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following: 1. Plaintiff is Rhonda J. Morrison, an adult individual, currently residing at P.O. Box 502, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant is Tawn S. Morrison, an adult individual, currently residing at P.O. Box 502, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth &Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 30, 2000. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiffmay have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing divorce complaint are true and correct. I understand that fa/se statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date RHONDA j. MORRISON, Plaintiff VS. TAWN S. MORRISON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : NO. 2003-194 : CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce in the above captioned matter pursuant to Pennsylvania Rule of Civil Procedure, Rule 1930.4(d). I certify that I am authorized to accept service on behalf of defendant Date: Address RHONDA J. MORRISON, Plaintiff TAWN S. MORRISON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-194 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 13, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (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 unsworn falsification to authorities. Date~~~ on a,/l(/Morr~on, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVROCE CODE 1. I consent to 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. D ate:§4904 rela't~/}~g t° unsw°m falsificati°n t° auth°rities?/~ ~//~.~v-~,..~ ~K~/~ ~/~~~ ' ~ / /]~ionda~rri~n, Plaintiff RHONDA J. MORRISON, Plaintiff We TAWN S. MORRISON, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2003-194 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 13, 2003. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (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 unsworn falsification to authorities. ~'awn S. Morrison, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVROCE CODE 1. I consent to 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 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 unswom falsification to au~ c Tawn S. Morrison, Defendant RHONDA J. MORRISON, Plaintiff VS. TAWN S. MORRISON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 2003-194 CIVIL TERM 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 §3301 (c) q~q~l-(d)-(-1-)--ef- tho Diverc-e-Gede~. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service dated January 22, 2003, 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 June 4, 2003 ; by defendant ~Tune 4, 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: 5. 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: .Tune 12, 2003 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 12, 2003 Attorney for Plaintiff 1N THE'COURT Of COMMON PLEAS RHONDA J. MORRISON, Plaintiff Versus TAWN S. MORRISON, Defendant Of CUMBERLAND COUNTY STATE OF ~. PEN NA. NO. 2003-194 CIVIL DECREE IN DIVORCE AND NOW, ~/~- /f * DECREED THAT Rhonda J. Morrison Tawn S. Morrison AND , IT I$ ORDERED AND , PLAINTIFF, , 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 BY ThE Court: ~ PROTHONOTARY