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Home My WebLink About07-1423w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHEILA JEAN MOORE Plaintiff Vs File No. 07 IN DIVORCE DOUGLAS PAUL MOORE 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 action within twenty (20) days after this complaint and notice are served by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to the telephone or the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SHEILA JEAN MOORS Plaintiff NO. 07-1423 Civil Term VERSUS DOUGLAS PAUL MOORE Defendant DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT AIL' JEAN MOORE PLAINTIFF, AND DOUGLAS PAUL MOORE ,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; BY THE COU rv OTA RY R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHEILA JEAN MOORE Plaintiff Vs File No. o''- 111.23 a,d/ _7z' IN DIVORCE DOUGLAS PAUL MOORE Defendant COMPLAINT UNDER & 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Sheila Jean Moore , who currently resides at 1341 Old Willow Mill Road. Mechanicsburg Cumberland County, Pennsylvania, 17050 since November 2006 2. Defendant is Douglas Paul Moore , who currently resides at 3727 Betsy Lane, Higley , _ Maricopa County, Arizona, 85236 since December 2006 3. Plaintiff and/or Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 28, 2004 , at 12 Simmons Road. Mechanicsburq; Cumberland County, Pennsylvania 5. There have been no prior actions of divorce or for annulment between the parties. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. This marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. 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 falsifications to authorities. Date: V4 h ?, I i (I 1 i Signa ure of PI ntif f (T) ri Print Name (gig adto-UL36-y- Telephone Number Q c 1 v w Q rv C? 0 5-171 ca , R i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHEILA JEAN MOORE Plaintiff 1 2 Vs File No. arL IN DIVORCE DOUGLAS PAUL MOORE Defendant AFFIDAVIT OF SERVICE I, Sheila Jean Moore , hereby verify that on day of 2007, 1 served the Defendant with a true and correct copy of the Divorce Complaint by one of the following methods: (CHECK ONE) M Service was made by United States Postal Service, first class mail, postage pre aid, certified, restricted delivery, return receipt requested to the Defendant, on the day of IM ?ch , 20Q?. The return receipt signed by the Defendant is attached hereto. () The Defendant was personally served with a true and correct copy of the above pleading by hand-delivering the same to the Defendant. Personal service was made at the following location and time: on the day of , 20_, at o'clock. 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: 3-c,- 61 ignature of t Person who Made Service R )F4- V, I OWL Postal m m Only; CERTIFIED MAIL RECEIPI .. M. 8ff ru ra pip $ 9 U Q CertOW Fee S C3 p Return Redo" Fee ?E.r.ement Required) 19 Zp01 C3 ntNery Fee Restricted DelRequired) u1 (Endorseme m 'a Totei postage s Fees S 1 7 $ O o or PO Box IVo. -.._--------------- ? Cfiy. State, ZIP+4 • - .. ?-•- ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, f or on the front if space permits. 1. Article Addressed to: &t La A. Sig X ? Agent AAA- %W%-,' D Is d nrery a rise ifferent from Rem 1 ? e: If YES, enter delivery address below: 0 No 3. Type Rice ertified Mail ? Express Mall egistered 0 Return Receipt for Uemhandiae 0 Insured MW6==-Q•C.Q D. 14-Restricted Delivery? (Extra Feat ? i? 8 2. Article N?mb$r 1 (? 11304 j 3 5 [J 01104,1263 (rmnsfer worn! service Is k --- PS Form 3811, February 2004 Domestic Return Receipt 102595.02-M-1540 A* C7 cr% ^C "I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHEILA JEAN MOORE Plaintiff r"fir f Vs File No. 14a3 IN DIVORCE DOUGLAS PAUL MOORE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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. Date: Signature of aintiff 0 -?7 r O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHEILA JEAN MOORE Plaintiff Vs File No. n? U 1- 14 ? IN DIVORCE DOUGLAS PAUL MOORE Defendant 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. 1 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. 1 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 under- stand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date:, -42 Signature of PI tiff .?? ?? ??': ?: ? c-' ? ?"'- ?C'.J 3 -rl '?' G O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHEILA JEAN MOORE Vs Plaintiff File No. I IN DIVORCE DOUGLAS PAUL MOORE Defendant AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on h'nwh I3Ijaq 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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. Date: / S '?L S' na of Defendant C3 ?°?, t??; ? - ? _. Us ??` +? -ta 3 `? ? -G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHEILA JEAN MOORE Plaintiff PP Vs . File No. f " 14 l ? IN DIVORCE DOUGLAS PAUL MOORE Defendant 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. 1 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. 1 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 under- stand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: 07/? Signatur f Defendant G E•'? y SHEILA JEAN MOORE : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION VS. DOUGLAS PAUL MOORE Defendant NO. 07-1423 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Certified Mail, Restricted Delivery, Return Receipt Requested on 3-23-07 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff 07-18-07 , by Defendant 07-15-07 4. Related claims pending: None 5. Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: 730107 Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: 7130%7 Date: Q? Jh h- ??u -,?- ?v Signature of P intiff