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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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STATE OF ~~ PENNA,
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CYNTHIA K. TAYLOR
PIa inti ff
i\; (I. 5986
Ci".i~ , It) 97
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JAMES P. TAYLOR
Defendant
DECREE IN
D I V 0 R C E ~3-''JS",.A
AND NOW, ....,...... .~OO .,;t..... 19f1.. it is ordered and
decreed that,....... C,Y~THI.A. K:. .TAY.LOR..............,...... plaintiff,
and. . . . . .. . . . .. . .. .. .JAM.ES. P:. .~AY.LOR. .. ., . .. . . .. . .. .. . . '., defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following c1,aims which have
been raised of record in this action for which a final order has not yet
been entered;
There are no outstanding issues.
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ny T
Prothonotary
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CYNTH IA K, TAYLOR. ) IN TilE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY.
} PENNSYLVANIA
vs. )
) CIVIL ACTION - LAW
JMIi:,S P. TAYLOR, )
Defendant ) NO, 97-5986
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record. together with the following information, to the court for entry of a divorce
decree:
I. Ground for divorce: irretrievable breakdown under Section 3301(c) 3J01l~ of the
Divorce Code. (strike out inapplicable section)
2. Date and manner of service of the Complaint: Oc tober 31, 1997. by cert i tied
mail. restricted deliverv, return receiot reauested
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce
Code: by Plaintiff May 12. 199;%y Defendant May 7. 1999.
(b)( I) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code:
; (2) date of filing and service of the Plaintiff's affidavit upon the respondent:
4, Related claims pending: There are no cutstanding issueD
S. Complete either paragraph (a) cr (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 Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: Mailed to Prothonotary 05/19/99
Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: Mailed to Prothonotary on 05/19/99
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CYNTHIA K. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VI,
NO, Q'1- srlS'<.o l i , ' (,-..
,Lcc....Y l~r(Y)
JAMES R, TAYLOR
CIVIL ACTION - LAW
IN DIVORCE
Defendant
-
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 in 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 are 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:
Office of the Prothonotary
Cumberland County Court House
One Courthouse Square
Carlisle, Pennsylvania, 17013
11' YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYERS FEES. OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THESE.
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
Cumberland County Court House
Fourth Floor
One Courthouse Square
Carlisle, PA 17013-3387
717-240-6200
CYNTHIA K. TAYLOR,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANJt\
NO.97- }'} Pc" CIVIL TERM
VI,
JAMES R. TAYLOR,
DEl-ENDANT
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Cynthia K. Taylor a citizen of Pennsylvania, residing at
1305 Brandt Avenue, New Cumberland, PA 17070
2.
Defendant isJames R. Taylor
a citizen of Pennsylvania, residing at
202 Old York Rd. Apt. C.. New Cumberland. PA 17070 .
3. Plaintiff and Defendant are sui iuris and have been bonafide residents of the Commonwealth of
Pennsylvania for at least six months immediately preceding the filing of the Complaint.
4. The parties are husband and wife and were lawfully married on 8-27-83
5, The marriage is irretrievably broken.
6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its
allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940
and its amendments.
7, There has been no prior action for divorce or annulment instituted by either of the parties in this
or any other jurisdiction.
8, The Plaintiff has been advised of the availability of counseling and of the right to request that
the Court require the parties to participate in counseling. The Plaintiff, upon being so advised,
does not wish marriage counseling.
COUNT I
Request (or Divorce Due to Irretrievable Breakdown
Under 3301(d) o( the Divorce Code
9. The marriage of the parties is irretrievably broken.
10, Upon ninely (90) days elapsing from the date of service of the Complaint, Plaintiff intends to
file an Affidavit consenting to a divorce. Plaintiff believes that the Defendant may also join in
and file the same, or similar Affidavit of consent to a divorce.
I L Upon separation of two (2) years, Plainliff intends to file with the Court an Affidavit indicating
the he/she has lived separate and apart in excess of two (2) years.
WHEREFORE, if two (2) years have elapsed from the date of separation and/or Plaintiff has filed
hislher Affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to
3301(d) of the Divorce Code.
COUNT II
Request (or Equitable Distribution o(
Marital Property Under 3104 and 3502(11) oCthe Divorce Code
12. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
13. Plaintiff and Defendant have acquired property, both real and personal during their marriage
from the date of said marriage until the date of their separation.
14. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said
property.
WHEREFORE, Plaintiff respectfully request the Court to equitably distribute the marital property of
the panies, pursuant to 3104 and 3502(a) of the Divorce Code.
COUNT 111
Request for Counsel Fees, Costs, Expenses and Alimony, APL, Under
3104,3323, 3502(e) and 3702 of the Divorce Code
15. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
16. Plaintiff is unable to pay the necessary counsel fees, costs and expenses and Defendant is more
than able to pay them.
WHEREFORE, reserving the right to apply to the Court for temporary counsel fees, costs and
expenses, prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to
pay Plaintiff's reasonable counsel fees, costs and expenses.
Respectfully submitted,
DATE /P' z.~~ Y 7
By /?,-, /t-.A..
JA S M, BACH, ESQUIRE
At mey I.D.# 18727
352 S. Sporting Hill Rd.
MECHANICSBURG, PA 17055
(717)737-2033
VERIFICATION
I, ,..{. (~\.(\~\c.l-C~erify that the statements made in this Complaint are true and
correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C,S. 14904
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relating to unsworn falsification.
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CYNTHIA K. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
vs.
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CIVIL ACTION - LA W
IN DIVORCE
NO. 97-5986 CIVIL TERM
JAMES R. TAYLOR,
Defendant
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
MICHAEL L. BANGS, being duly sworn according to law, deposes and says as follows:
I. That he is the attorney for the Plaintiff herein.
2. Th9t on October 23, 1997, a true and correct copy of the Divorce Complaint filed in
the above-captioned matter was delivered to the United States Postal Service in Mechanicsburg,
PennsylvanIa, as certified mail (Receipt No. Z 227 574 146) return receipt requested, addressed
to the Defendant herein.
3. That a return receipt card was received from the U,S. Postal Service signed by the
Defendant herein showing 1.1 date of service of October 31, 1997. Said card is attached hereto as
Exhibit A.
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CYNTHIA K. TAYLOR.
Plaintiff
IN TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COuNTY,
PENNSYL VANIA
vs.
NO, 97-5986 CIVIL TERM
JAMES P. TAYLOR,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on
Octobe. 28. 199ilndwasservedupontheDefendantonorabout October 31. 1997.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint and the date of service of the Complaint on the
Defendant.
3. I consent to the entry of a final Decree in Divorce either after service ofa Notice of
Intention to Request Entry of the Decree or upon filing of my Waive.' of the Notice ofIntention
to Request Entry of the Decree.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted.
5. I have been advised of the availability of marriage counseling, understand that the
Court maintains a list of marriage counselors and that I may request the Court require my spouse
and I to participate in counseling and. being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to the divorce becoming final.
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.
Date
.'i-IZ-11
~t. \r
C A K. TAYLOR
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CYNTHIA K. TAYLOR, . IN THE COURT OF COMMON
.
Plaintiff . PLEAS OF CUMBERLAND
.
. COUNTY. PENNSYLVANIA
.
v. NO. 97-5916 CIVIL TERM
JAMES P. TAYLOR CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint In divorce under ~3301 (c) of the Divorce Code was
flied on October 2 B
, 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 of divorce after service
of notice of Intention to request entry of the decree,
verify that the statements made In this affidavit are true and
correct.
understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. !iQ90Q, relating to unsworn falsification to
authorities.
Date: Mav 7 , 1999
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CYNTHIA K. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
vs.
JAMES P. TAYLOR,
Defendant
NO. 97-5986 CIVIL TERM
CIVIL ACTION - LA W
IN DIVORCE
W AIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION JJOHc\ OF THE DIVORCE CODE
I. I consent to the entry of a final decree in 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 di vorced 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 J 8 Pa. e.s. Section 4904 relating to
unsworn falsification to authorities.
'5-IZ -'1'
Dated
C'~i. ,~
CYNT 'A K. TAYLOR
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CYNTHIA K. TAYLOR,
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
NO. 97-5986 CIVIL TERM
PlaintIff
v.
JAMES P. TAYLOR,
CIVIL ACTION - LAW
IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
13301(c) OF THE DIVORCE CODE
1, 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 flied with the prothonotary.
correct.
verify that the statements made in this affidavit are true and
understand that false statements herein are made subject to the
penalties of 18 Pa, C.5, ~q904. relating to unsworn falsification to
authorities,
Date: Mav 7 , 1999
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CYNTHIA K, TAYLOR,
PlaintilT
NO. 97-5986 CIVIL TERM
JAMES R, TAYLOR,
Defendant
CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please enter the appearance of Michael L. Bangs, Esquire, as attorney lor Plaintiff,
Cynthia K. Taylor, and withdraw the appearence of James M. Bach, Esquire, as attorney for
Plaintiff.
DATE: November 12.1998