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HomeMy WebLinkAbout98-02064 \ ~\ ~\ :\ \ a~ \ \ \ ) j' \ \ , \ , - <:J\ \ \ \ ":r\ -'\ ~\ ,;.\ ~~ "2:\ " \( 1.1\ \' \f' '.'\ \.' \~ ~-'-. (...',\. \\. " ~ .;' , I....... ,. \" , ' \:-\, (",- , ,'. l: l l' , :._.:l RALPH L. DUFF, JR., ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYL VANIA l VB. l CIVIL ACTION - LAW ) I NO. 98- ,)0 t. 'I CIVIL TERM MARLENE Eo DUFF, I Defendant ) IN DIVORCE NOTICE OF AVAILABILlTY-..QLCQUNSELlNG TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counsoling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania, You are advised that this list is kept as a convenience to you and YOLl are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 2 RALPH L, DUFF, JR" I IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYL VANIA ) vs. ) CIVIl. ACTION - lAW ) ) NO. 98- ~t>v( CIVil TERM MARLENE E. DUFF, ) Defendant ) IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, RALPH L. DUFF, JR" by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1, The Plaintiff is RAI.PH l. DUFF, JR., an adult individual who currently resides at 75 Winchester Garden, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is MARLENE E, DUFF, an adult individual who currently resides at 512 Franklin Street, Carlisle, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on 23 December 1991 in Richmond, Maine. 5, The Plaintiff and Defendant separated on 29 November 1995 and have lived separate and apert since that date. 6. Thllre have been no prior actions of divorce or annulment between the partiea. 3 I , I . i I i I I I RALPH L. DUFF, JR., Plaintiff ) ) ) ) ) ) ) ) ) vs. MARLENE E. DUFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil ACTION. LAW NO, 98.2064 CIVil TERM IN DIVORCE AFfIDAVIT OrCQNSENT 1. A Complaint in Divorco under S(',cllon 3301(c) of the Divorce Code was filed on 15 April 1998 and was served upon tho DofllncJilnt on or about 16 April 1998. 2. The marriage of Plaintitl an(l Dllfondilnt is irretrievably broken and ninety (90) days have elapsed from the date of filinR of tho complaint and the date of service of the complaint on the Defendant. 3, I consent to the entry of a final decroe in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of I ntention to Request Entry of the Decree, 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to partiCipate in counseling and, being so advised, 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 mado in this Affidavit are true and correct and I understand that false statements heroin uro rnildo subjoct to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification 10 iluthorities, ..... ') ( l, ~ ~':~~'t15.ut,Jr,~" ____!LJllJy.mu DATE RALPH L. DUFF, JR" Plaintiff ) ) ) ) ) ) ) ) vs. MARLENE E. DUFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 98.2064 CIVIL TERM IN DIVORCE Af~'l!T Of' C.ONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 15 April 1998 and was served upon the Defendant on or about lLl\m'j,l 1998 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of 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 of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court relluire 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 and 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. ./Y! ,]A /P/flfl !' ,(~116 M1rIene E, Duff '- - 17 July 1998 DATE