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Home My WebLink About01-5825RHONDA D. NEWCOMER, Plaintiff MICHAEL LYNN NEWCOMER, Defendant : iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 6/- goq IN DIVORCE CIVIL TERM NOTICE 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 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 Cumberland County Court House, High and Hanover Streets, Carlisle. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 RHONDA D. NEWCOMER, Plaintiff MICHAEL LYNN NEWCOMER, Defendant : IN THE COURT OF COMMON PLEAS OF i CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : :NO. Or" 6~g0.~ CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is RHONDA D. NEWCOMER, who currently resides at 404 Croghan Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is MICHAEL LYNN NEWCOMER, who currently resides at 404 Croghan Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiffand Defendant were married on March 29, 1975, at Carlisle, Cumberland County, Pennsylvania. 5. There have · · . been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. I verify that the statements made in this Complaint 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: ANDREWS & JOHNSON By:~ W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 II RHONDA D. NEWCOMER, Plaintiff Vo MICHAEL LYNN NEWCOMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-5825 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : COUNTY OF CUMBERLAND ) AND NOW, this /(~ day of October, 2001, I, Taylor P. Andrews, Esquire, attorney for Rhonda D. Newcomer, Plaintiff in the above-captioned action, hereby swear that I have served a tree copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at his residence at 404 Croghan Drive, Carlisle, PA 17013, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on October 15, 2001, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: ~ ~2t'orney for Plaintiff Sworn and subscribed to before me this /4 day of t~¢-~er-~ ,2001 Nota~TPublic t NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY M~Y COMMISSION EXPIRES APRIL 26, 2003 Member, Pennsylvania Association of Notaries · Complete items 1, 2, and 3. AJso complete item 4 if Restricted Delivm3~ is desired. Print your name and address on the reverse so that ~ve can return the card to you. Attach t~is card to the back 6f the mailpiece, or on thai front if space pemaits. 1. Article Addressed to: A. Received t .~) B. Date of Delivery la de~ive~3 diffem~ from item 17 [] If YES, enter delivery address below: [] No 3. Service Type ~Cerlified Mail [] Registemd [] Insured Mail [] Express Mail ~Return Receipt for Merchandise [] C.O.D. 4. Restricted Delivery? (Extr~ Fee) Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 Exhibit A RHONDA D. NEWCOMER, Plaintiff MICHAEL LYNN NEWCOMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-5825 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 8, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I co'nsent 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: Rhc~cia D~. ~q~'wc~-m&r, Plaintiff - RHONDA D. NEWCOMER, Plaintiff MICHAEL LYNN NEWCOMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-5825 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF 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 ifI do not claim them before a divorce is granted. 3. I understand that ! 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 unsworn falsification to authorities. Date: RHONDA D. NEWCOMER, Plaintiff MICHAEL LYNN NEWCOMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-5825 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 8, 2000. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Michael Lyr~n NYew~om~r, Defendant RHONDA D. NEWCOMER, Plaintiff Vo MICHAEL LYNN NEWCOMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : : NO. 01-5825 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) 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 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 unsworn falsification to authorities. Date: O/'/~. - 0,2. · / Michael Lyt~m ~vcome~ Defendant RHONDA D. NEWCOMER, Plaintiff MICHAEL LYNN NEWCOMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-5825 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of a divorce 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2 2. Date and manner of service of the complaint: Restricted, certified mail, return receipt requested on October 15, 2001. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff January 16, 2002; by Defendant January 16, 2002. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 17~ 2002 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 17, 2002 Date: January 17, 2002 ANDREWS & JOHNSON By: ~ 7g'West Pomfret Street Carlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 15641 IN THE COURT OF COMMON Of CUMBERLAND COUNTY STATE OF ~ PENNA. PLEAS RHONDA D. NEWCOMER, ...................................... 91ai~iff ............................ Versus ............................. D~fbD~nt ............................ N o ....... .o..?..s.~.2..s................... 19 DECREE IN DIVORCE AND NOW ..... ~ ..... ~ .... it is ordered and decreed that .........?.,.o?.~?. p... ??.w?.o.~?. ...................... plaintiff, and ................... ~. z.c?. ~.s. %%¥~.~.. ~. s. w.~. 9~. ~. ~. .................. 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; Attest: J. ~ , ~ h--'-/ Prothonotary