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Home My WebLink About03-0918 JENNIFER L. WARNER, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 03 - qlP C'Q~l ~~ MICHAELJ. WARNER, Defendant CIVIL ACTION - LA \V 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office ofthe Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 LA WYER 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 Courthouse 4th Floor, One Courthouse Square Carlisle, P A 17013 (717) 240-6200 JENNIFER L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 03 - 9,f c.-o;l y~ MICHAELJ. WARNER, Defendant CIVIL ACTION - LA W IN DIVORCE COMPLAINT IN DIVORCE Count I Divorce Under Section 3301(c) 1. Plaintiff is Jennifer L. Warner, an adult individual whose address is 341 Fifth Street, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Michael J. Warner, an adult individual who resides at 311 Fifth Street (Rear), Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on December 23,1991, at Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that plaintiff has the right to request that the court require that the parties participate in counseling. 8. Defendant is not a member of the armed services of the United States or any of its allies. WHEREFORE, plaintiff requests the Court to enter a Decree of Divorce Count II Equitable Distribution 9. Paragraphs 1 through 8 are incorporated herein by reference. 10. Plaintiff states that the plaintiff and defendant possess various items of both real and personal marital property which is subject to equitable distribution by the Court. WHEREFORE, plaintiff requests that this Court: a) equitably distribute all property, personal and real, owned by the parties b) such other relief as the Court may deem equitable and just. Count III Alimonv 11. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 12. Plaintiff lacks reasonable support to adequately maintain herself. WHEREFORE, plaintiff requests this Honorable Court to enter an award of alimony in her favor. ~ Timo hy J. O'Connell, Esquire TV ER AND O'CONNELL 4415 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff Verification I verify that the statements made in the foregoing Complaint are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: 2-- Zc.l--Q3 ~ifer L. Warner ~~ -'9- "iQ. 9J '- c,..., &8 - 9 f'" c:; ....J ~ o vt tn C () C' 0 - - I 0 t 'V '-' -p::~ S ~ (,) 'Z r ~ -J,' nl; Z.:' -, . L.. ~:;.c_ r' ~.- :<'- ~': ~c. #'~c ::'-: ; _U . ; fi'i ,:~ ::> :':D -<. c:> _( :,) C) ,-: s,~ c': ..- ~~! . t -., ;'1 ::'J :""',,-=, ()') --,.1 .' . i'r 'f JENNIFER L. WARNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 03-918 CIVIL TERM MICHAEL 1. WARNER, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please reinstate the complaint in the above captioned matter. -~--'--)2_, Date: May 24, 2005 Timothy 1. O'Connell, Esquire TURNER AND O'CONNELL 4415 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff ~ ,; ,-- JENNIFER L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-918 CIVIL TERM MICHAEL 1. WARNER Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must tile a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted, Plaintiffs Affidavit Under Section 3301(d) of the Divorce Code 1. The parties to this action have continued to live separate and apart for a period of at least two years, since January, 2003. 2. The marriage is irretrievably broken. 3. 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. 1 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.A. Section 4904 relating to unsworn falsification to authorities. Date: S:;) 3~crc;- c~ , ,4~(!t!(~Oc~=-- Je~ L. er " ~ ./ .-- (-:' ,.. .~ - JENNIFER L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 03-918 CIVIL TERM MICHAEL J. WARNER, Defendant CIVIL ACTION IN DIVORCE NOTICE OF INTENT TO REOUEST ENTRY OF 330Hd) DIVORCE DECREE TO: Michael J. Warner You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 330 I (d) affidavit. Therefore, on or after July 18, 2005, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Courthouse 4th Floor, One Courthouse Square Carlisle, PA 17013 717/240-6200 JENNIFER L. WARNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 03-918 CIVIL TERM MICHAELJ. WARNER, Defendant CIVIL ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER OF 3301(d) DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because [check (i), (ii) or both]: _ (i) The parties to this action have not lived separate and apart for a period of at least two years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. IfI fail to do so before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree may be entered without further delay. I verifY that the statements made in this counter-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: Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ~ ij; <-- c: 'i-"~ - UJ "". -;:1:c. - - .' Q, -. ~..,., rnc ~<:1':..':< :.fl ~'i' '~~G~ :.~:~~ ?~ ~'"-)\ ::;. ~ "", '" 17 JENNIFER L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-918 CIVIL TERM MICHAEL J. WARNER Defendant CIVIL ACTION. LAW IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code 1. The parties to this action have continued to live separate and apart for a period of at least two years, since January, 2003. 2. The marriage is irretrievably broken. 3. 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. 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.A. Section 4904 relating to unsworn falsification to authoriti~. ~/ /C ( /' <.c' "'" 5-;P,-0 ~ ;, ~. '~'.- ' c~ 't ~~ (") <;.,~-: r-> = (;=:) <-'"' -:)': - - -- r-', >n --I ~f~ ;~:J, (~) :'=:".' -") ~~.;.;, , ;','rn ::::4 ~~ r,.) G", C' CJ . . JENNIFER L WARNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO, 03-918 CIVIL TERM MICHAEL J. WARNER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Timothy J. O'Connell, Esquire, attorney for the plaintiff, Jennifer L Warner, in the above captioned action for divorce, hereby certify that a conformed copy of the Complaint in Divorce was served on the defendant, Michael 1. Warner, by Certified Claim No. 70031010 000281564826, restricted delivery, return receipt requested, by depositing the same in the United States mail at Harrisburg, Pennsylvania, pursuant to Rule 1920.4 of the Amendments of the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As evidence by the green return receipt card attached hereto, the Complaint was received by said defendant on June 8, 2005. ~:::> Timo y 1. ell, Esquire Turner and O'Conne 4415 North Front Street Harrisburg, PA 17110 Sworn and subscribed to before Me this 18th day of July, 2005. ~-a~ NOTARIAL SEAL Stacey A Fogle, NotaIy Public Susquehanna Twp., Dauphin County My commission expires January 02, 2009 (" c <::: -ob:; rnrr, ~~; ~E~ J>c: ~ - \ r, C) "':) - JENNIFER L WARNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 03-918 CIVIL TERM MICHAEL J. WARNER, Defendant CIVIL ACTION - LAW IN DIVORCE 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. Ground for Divorce: irretrievable breakdown under Section 3301d of the Divorce Code. 2. Date and manner of service of the complaint: served June 8, 2005, by certified mail-- See Affidavit of Service filed herewith 3. Date of execution ofthe affidavit of the required by Section 3301d ofthe Divorce Code: by plaintiff: May 23, 2005 Date of service of plain tift's affidavit upon the respondent: served June 8, 2005. 4. Related claims pending: none 5. Date and manner of service of the notice of intention to file praecipe to transmit record and counteraffidavit, a copy of which is attached: served June 28, 2005, by depositing same in the U.S. Mail, first class. Date: 7/18/05 Timot y J. O'Connell, 're Turner and O'Connell 44 I 5 North Front Street Harrisburg, PA 17110 (717) 232-455 I Attorney for plaintiff (") ~;; r-> co' ~ (..,:, c.. ,- - ..p !; -" Q, .-I 4:-n 0"1-- -Cb -:"10 ;J.b ~~"~ :-n'\ -;:")' ~~~ 0::-'0 ::.c.. - - v:> -.0 - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + + . . . + + . . . . . . . + . . . . + . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .. . .. . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JENNIFER L. WARNER VERSUS MICHAEL J. WARNER AND NOW, DECREED THAT STATE OF PENNA. No. 03-918 DECREE IN DIVORCE )~ 1-""- 2005 , IT is ORDERED AND Jennifer L. Warner , PLAINTIFF, AND Michael J. Warner , 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 ~ ..) -', . . ~. . --'? ........... .'., ~.. .~ " ~ " , ~"'-. ..'; ,. ~..W -: , '. 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