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HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
35 EAST HIGH STREET
CARLISI.E PA 17013
(717) 243.6090
ATTORNEY FOR PLAINTIFF
TERESA L. MATTHEWS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION. LAW
: NO. 98 . 4333 CIVIL TERM
RICHARD L. MATTHEWS,
Defendant
: IN CUSTODY
PRAECIPE TO TRANSMIT RECORD
Please 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 3301 (c) of the Divorce Code.
2. Date and manner of service of the complaint: On or about August 12, 1998 defendant
was served with a copy of the divorce complaint by certified mail addressed to him at 1158 Newville Road,
Carlisle, PA 17013, certified mail return receipt No. Z 126 560 803.
3. Complete either paragraph (a) or (b):
(a) Date of execution of the affidavit of consent required by Section 3301 of the
Divorce Code: By the plaintiff: 111''<'< ;.. <{ , 1999
By the defendant: H4/C~"3I, 1999
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce
Code: N/A ; and (2) Date of filing and service of the plaintiff's affidavit
upon the defendant: N/A
4. Related claims pending: None
5. Complete either (a) or (b):
(a) Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached: N/A
(b) Date plaintiff's Waiver of Notice in Section 3301 Divorce was med with the
Prothonotary: tI I Z- , 1999
Date defendant's Waiver of Notice in Section 3301 Divo e was filed with the
Prothonotary: ~ , I V , 1999
April /2-;1999
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2. The Father shall have primary physical custody of both children, subject to
periods of partial or temporary physical custody and visitation with the Mother on every
other weekend, from Friday evening until Sunday evening, and at such other times as
the parties may mutually agree.
3. The parties shall share holidays on a mutually agreeable basis, it being
the intention of the parties to spend time with the children on holidays and the children's
birthdays on an equal basis as much as reasonably possible. The Father shall always
have both children on Father's Day and the Mother shall always have both children on
Mother's Day.
4. The Mother shall also have up to two weeks vacation time with the
children each Summer. The Mother shall give notice to the Father by May 1st each year
of the weeks she wishes to exercise this vacation time.
5. Neither party shall reside with the children outside of the Commonwealth
of Pennsylvania without first securing the consent of the other party or further order of
this Court. Whenever either parent takes the children away from their respective
primary residences on vacation, they shall provide a means for the other parent to
contact them in an emergency.
6. Both parties agree that each party shall have reasonable telephone
contact with the children while the children are in the other party's custody and that the
children will be permitted to call the noncustodial parent as desired while they are in the
custody of the other parent. Both parties will continue to advise the other as to their
respective telephone number and address from time to time.
7. The parties will keep each other advised immediately relative to any
emergencies concerning the children and shall further take any necessary steps to
ensure that the health, welfare and well being of the children is protected.
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5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the
grounds upon which this action is based that the marriage between the parties is
irretrievably broken.
6. The plaintiff avers that she has been advised of the availability of
counseling and that she has the right to request that the court require the parties to
participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between
the two parties.
I verify that the facts contained herein are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904
relating to unsworn falsification to authorities.
July 17 .1998
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TERESA L. MATTHEWS, Plai Iff
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35 East High Street
Carlisle, Pennsylvania 17013
(717) 243-6090
Supreme Court 10 No. 29920
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TERESA L. MATTHEWS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 98 . 4333 CIVIL TERM
..1
RICHARD L. MATTHEWS,
Defendant
: IN CUSTODY
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was
filed in this matter on or about July 28, 1998 and served upon the defendant on or
about August 12, 1998.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of the service of the complaint.
3. I consent to the entry of a final decree in divorce after service of notice of
intention to request entry of the divorce.
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I verify that the statements made in this affidavit are true and correct.
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TERESA L. MATTHEWS
understand that false statements herein made are subject to the penalties of 18 Pa. C.
S. Section 4904 relating to unsworn falsification to authorities.
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