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Home My WebLink About03-1518CARRIE L. NUGENT, ' Plaintiff ' VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · oa - 1 1ov PATRICK J. NUGENT, · Defendant · IN DIVORCE CIVIL TERM 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 of the Prothonotary at: CUMBERLAND COUNTY COURT HOUSE~ CARLISLE~ PENNSYLVANIA 17013. 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, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 TOLL FREE: 1-800-990-9108 CARRIE L. NUGENT, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PATRICK J. NUGENT, ' Defendant · IN DIVORCE CIVIL TERM COMPLAINT 1. Plaintiff is Carrie L. Nugent, who currently resides at 180 Ashford Drive, Enola, Cumberland County, Pennsylvania. 2. Defendant is Patrick J. Nugent, who currently resides at 523 Race Street, Millersburg, Dauphin County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately preceding the filing of this Complaint· 4. Plaintiff and Defendant were married on July 26, 1994, in Norfolk, Virginia. 5. There have been no prior actions for divorce or for annulment between the parties. 6. Plaintiff avers, as the grounds upon which this action is based, that the marriage between the parties is irretrievably broken. 7. 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· 8. Plaintiff requests that the Court enter a Decree of Divorce under Section 3301(c) of the Pennsylvania Divorce Code. Respectfully Submitted, Attorney for Plaintiff ID//41954 39 West Main Street Mechanicsburg, PA 17055-6230 V~FICATIO~ 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 - Date £' authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLFIRST, f/k/a DAUPHIN DEPOSIT BANK AND TRUST COMPANY, VS. Plaintiff, JANET B. NOCHO, Defendant. CIVIL DIVISION NO.: 03-1519 Civil Term PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please mark the Complaint in Mortgage Foreclosure filed at the above-captioned term and number reinstated. Respectfully submitted, JAMES,BY: SMIT~ I .x Scoff~A. D~I IETTERICK & CONNELLY LLP ~ttenck, Esquire Attorneys for Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 CARRIE L. NUGENT, Plaintiff VS. PATRICK J. NUGENT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1518 CiVIL TERM 1N DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301( c ) of the Divorce Code was filed on .. April 2, 2003 and served on _April 10, 2003 . 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce aiter service of notice of intention to request entry of the decree. 4. 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. §4904 relating to unsworn falsification to authorities. Date P ttrick / CARRIE L. NUGENT, Plaintiff VS. PATRICK J. NUGENT, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1518 CIVIL ACTION LAW IN DIVORCE .WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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. Section 4904 relating to unswom falsification to authorities. Patrick Jk_Nu~nt, ~'r~ndanr CARRIE L. NUGENT, Plaintiff VS. PATRICK J. NUGENT, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-1518 CIVIL TERM IN DIVORCE _AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301( c ) of the Divorce Code was filed on April 2, 2003, and served on Avril 10, 2003 . 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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. 4. 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. 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 Carrie L. Nugent CARRIE L. NUGENT, Plaintiff VS. PATRICK J. NUGENT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA NO. 03-1518 CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE UEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry ora final decree ofdivome 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 divome is granted. 3. I understand that I will not be divorced until a divome 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. Section 4904 relating to unsworn falsification to authorities. ~)ate CARRIE L. NUGENT, Plaintiff VS. PATRICK J. NUGENT, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND ,COUNTY, PENNSYLVANIA NO. O,-g-/5'-],~ CWIL TERM 1N DIVORCE ACCEPTANCE OF SERVICE Date accept service ,of the Divorce Complaint. Patric~k ~ ~~ · ~.N~gent, l~fendant CARRIE L. NUGENT, Plaintiff VS. PATRICK J. NUGENT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1518 CIVIL ACTION LAW IN DIVORCE PRAECIPE TO TRANSMIT RECOR~ To the Prothonotary: Please transmit the record, together with the following information, to the Court of entry of a Divorce Decree: 1. Ground for Divorce: Irretrievable breakdown under $ 32;01 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service (attached) signed by Defendant on April 10, 2003 3. Date of execution of the Affidavits of Consent and Waivers of Notice required by 6 3301 (c) of the Divorce Code: By Plaintiff By Defendant 4. Related Claims Pending: None July 10, 2003 July 9, 2003 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: Date Defendants Waiver of Notice was filed with the Prothonotary: Date ~ - -- July 25, 2003 July 25, 2003 Dawn S. Sunday, Esquire J Attorney for Plaintiff 39 West Main Street Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Carrie L. Nugent Plaintiff VERSUS Patrick J. Nugent Defendant PENNA. NO. 2003 - 1518 DECREE IN DIVORCE AND NOW, i~~ DECREED THAT L. Nuqent 2003 , IT IS ORDERED AND , PLAINTIFF, AND Patrick J. Nuqent , 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 4. -- + + + + + + +++++ ++ + + + + ++ + +++-