The URL can be used to link to this page

Home My WebLink About97-05940 " ~ i ~ ~ " ~ ~ I I :0.. I .~ ~ ~ (). \:) to.:. ~ ... ~ ._- _ _ _..... ....__.at- .-...... <111:.... 'lOC' '....... ...'.C______ ---~ . -~-~- IJ - : IN THE COURT OF COMMON PLEAS : 8 OF CUMBERLAND COUNTY . 8 . 8 .~ . . STATE OF ~~ PENNSYLVANIA . 8 . 8 , . 'UNA L'iNCIl,.1 . 1 iff NO...V.~.~.H9.. ................. 19 , pai!lt,. i tlt.. 'I · . Versus Iii :1 lI! 8 . FREPE, LYNGH, . ...... ... ....... I · . Defendant.... ; . · t i , DECREE IN ~ · DIVORCE . -,..J · ~ AND NOW, .. .. .~.. .. . .. .. :3. .. .. .. ", 19,~. r. It I, ordered and , , ~ IfIi decreed that.......,....."... :r;r1'l)\ ,t.:lNc:lJ.................., plaintiff. ~ , . ~ :;ed ~I~;~~~' ~;~~ . ;~~' ~~~~~. ~/~::~;:~::.~~~.. .. .. , .. .. . .. defendant. : . . , 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; ; . ...................- '" , ......................................................,. . -....,..".."...,.,..,..,.,...,.......................... . . . , Dy Th . ! .,;.;" {:Jd~mJ: ! II I Prothonotary t: _ .. ... ... _ _ ... _ _ ___ .. .. .. -...'1oi,...ic--1i ... '.. ... ... ... __ ... ... _ J ..3 .y fS' t.{!,1.l/7 ~.;~ d" ;;4 ~A~ 3 'y ()f /~tb /m~ --$ (2;# #~ " , TINA LYNCH, I IN THF. COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 97-5940 I I CIVIL ACTION - LAW I IN DIVORCE Plaintiff v. FRED E. LYNCH, 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. Grounds for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint; On October 28, 1997 by personal hand delivery at the Law Offices of Jay R. Braderman. 3. (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff I on January 28, 1998; by the Defendant: January 28, 1998. 4. Related claims pending; All claims settled by agreement. 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which 1s at,tachedl Plaintiff's Waiver of Notice executed on January 28, 1998 and is being filed simultaneously with this Praecipe; Defendant's Waiver of Notice executed on January 28, 1998 and is being filed simultaneously with this Praecipe. Respectfully submitted, Datel DERMAN, . . No. 07047 1 6 Locust Street .0. Box 965 Harrisburg, PA 17108-0965 (717) 232-6600 Attorney for Plaintiff " r'l I r C " , , " , ~ ... ( . 'r , I , " l, ,. " I, u.. I r) \ <, t,;\ l.J '~ ~,t ..~ ,', \.1 \' .. ~ " . ~ ~ , \\ , "" , \ " ~ , [ .-. ~ I , ~~ ~ , . c. ,.. ~~ ~ , , ~ ~ coO '.) , . . z I or( t:: 8 0; m @ :s ~ ~ Q ~s~ a ~ ~ ~~~ f ID ;)Ill Z ... ~ . 8 ci ~ ~ .J ~ .J':l1. ~ ),lllci~ i('" a: .oJ _ ;) ~ . III I- l/l a: It <( :t . .' ~ .. . . , . ~ ." TINA LYNCH, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I 9 ), 5'9t,/{l (,;4 edcl,.. v. I NO. I FRED E. LYNCH, I CIVIL ACTION - LAW Defendant I 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 irretrievable breakdown of the marriage, you counseling. A list of marriage counselors Office of the Prothonotary at: is indignities or may request marriage is available in the Cumberland County 1 Courthouse Carlisle, PA Court House Square 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. Court Administrator Fourth Floor Cumberland County Court House Carlisle, PA 17013 Telephone No. 717-240-6200 AMERICANS WITH DISABILITIBS ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. v. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA : NO. (11. H'IV {!(.I...:.i -ru- I I CIVIL ACTION - LAW I IN DIVORCE TINA LYNCH, Plaintiff FRED E. LYNCH, Defendant COMPLAINT DIVORCE UNDER SECTION 3301 tC) OR 3301 tD) OF THE DIVORCE CODE 1. Plaintiff is Tina Lynch, an adult individual who is sui juris and resides at 10 Cedarhurst Lane, Camp Hill, cumberland County, Pennsylvania 17011. 2. Defendant is Fred E. Lynch, an adult individual who is sui juris and residen at 10 Cedarhurst Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 17, 1994 in Hanover, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its allies. v. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. '11. ~.'}'Iv fl<.il 7lL_ I I CIVIL ACTION - LAW I IN DIVORCE TINA LYNCH, plaintiff FRED E. LYNCH, Defendant AFFIDAVIT Tina Lynch, being duly sworn according to law, deposes and saysI 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in couneeling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ( JL\rf\OJ)h});/t)(1M) , ~INA LYN ,; TINA LYNCH, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 97-5940 I FRED E. LYNCH, I CIVIL ACTION - LAW Defendant I IN DIVORCE CERTIFICATION OF SERVICE The undersigned hereby certifies that on October 28, 1997, a true and correct copy of the Complaint in Divorce in the above matter was served upon the Defendant by personal hand delivery at the Offices of Jay R. Braderman, Esquire as evidenced by the Acceptance of Service signed by the Defendant attached hereto. Date: ERMAN, ESQU RE o 47 LOCUST STREET P. O. BOX 965 HARRISBURG, PA 17108-0965 (717) 232-6600 ATTORNEY FOR PLAINTIFF , , I < .' \ <, ( ~) ; /":' i- l:: .. " I , I i I~ , .1. e,;,. , ( " 'J I.:., I "' ( i; L'.: "'- -. !!. c:' U C" (J - .----.. . . ...,..... w _.......... '-. ____;,:,. ,- ., TINA LYNCH, I IN THE COURT OF COMMON PLEAS Plaintiff I DAUPHIN COUNTY, PENNSYLVANIA I vs. I NO. 97-5940 I FRED E. LYNCH, I CIVIL ACTION - LAW Defendant I IN DJ,VORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Complaint was filed on October 27, 1997. 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 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. Section 4904 relating to unsworn falsification to authorities. II)(? /9 '8 Da te f (.J l n (~jyrrcK) L:TINA LY . TINA LYNCH, I IN THE COURT OF COMMON PLEAS Plaintiff I DAUPHIN COUNTY, PENNSYLVANIA I v. I NO. 97-5940 I FRED E. LYNCH, I CIVIL ACTION - LAW Defendant I IN DIVORCE WAIVER or NOTICE or INTENTION TO REQUEST ENTRY or A DIVORCE DECREE UNDER SECTION 3301 (c) or 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 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. section 4909 relating to unsworn falsification to authorities. Datel I !~ff /9~ I / Gw. ~ io ~l:,1 ~' TINA LYN . , " " L ~~ ) l.~ '. ~"-, l.," I I , \ \.>- I ,., " , . I TINA LYNCH, I IN THE COURT OF COMMON PLEAS Plaintiff I DAUPHIN COUNTY, PENNSYLVANIA I vs. I NO. 97-5940 I FRED E. LYNCH, I CIVIL ACTION - LAW Defendant I IN DIVORCE AFFIDAVIT OF CONSINT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Complaint was filed on October 27, 1997. 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 in divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statemente 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. Section 4904 relating to unsworn falsification to authorities. Dot: Jill If -i/i-~tL ~ FRE E. LYNCH , ..' : ~ t I c:.: \ -' ,c, ( I I I . , \ I '" l .- " r u '_J 11 " TINA LYNCH, I IN THE COURT OF COMMON PLEAS Plaintiff I DAUPHIW COUNTY, PENNSYLVANIA I v. I NO. 97-5940 I FRED E. LYNCH, I CIVIL ACTION - LAW Defendant I IN DIVORCE "AIVER or NOTICE or INTENTION TO REQUEST ENTRY or A DIVORCE DECREE UNDER SECTION 3301 (c) or 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 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. Section 4909 relating to unsworn falsification to authorities. Datel ~t.~ FRED E. LYNCH " IN THE COURT OF COMMON PLEAS O~' CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW //NA L~tiJ:t . . I : Plaintiff . . File No. en ~ 54'10 . . : vs. IN DIVORCE FRED [;. LY NU-t__ Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the -~ day of {\f\f\~ ,19~, hereby elects to resume the prior surname of :9\-JAf=Tl. . and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE:J,,2gJ~, /qqJ' cttx(~Q~hJ . '-...-' n re J ~gnature sumed COMMONWEALTH OF PENNSYLVANIA: : SSe COUNTY OF CUMBERLAND ;l<~~.L., On the 17d day of ~ . 19 'Ii?' , before me, a <//~!i ~ry PY&44c.-personally appea~d~e above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. - seal. In Witness Whereof, I have hereunto set my hand and official <.- , (J (,I J/ " / /'"...,",( i". <f<,-~b'i:t.-'Y <r)A...6.k_-z~ tiC t-aFy P\l c' ,r ....... IIl.,-DlllI1" M...........__. IIY COMMlSSIOIl 0Pll0 .... ~ ~ ". ... 'S (" .. ~ -.u COMj~:.o:i~~''''41''iIIIY'''' l'1li\II ...,' Cl'\;lJlIll 1110 anw ....IlllIYI IlUlIIOl N III 11(1_ IlIIYlilll'Inl' v I , : , ~ { I I , ,. " I I r.: , , .. (..' <: ,