The URL can be used to link to this page

Home My WebLink About00-06502 " ,~;.:;' " ,,:- " "--_0 *' * " , . . . . . IN THE COURT OF COMMON PLEAS * . OF CUMBERLAND COUNTY * PENNA. STATE OF James Go Bennett, NO. 2999 6592 Chi! . Pl:::.int-i-F-F , . . . VERSUS . . Patricia E. Bennett, Defendant. DECREE IN DIVORCE . AND NOW, \W-W2 ,~ ,'2001 , IT IS ORDERED AND DECREED THAT James G. Bennett , PLAINTIFF, AND P:::.t-ri,....i:::. 'R 'Rennett , DEFENDANT, ND it is further ordered that the terms of the marital settlement agre dated September 20, 2000, is hereby incorpoated, but not merge d, with ARE DIVORCED FROM THE BONDS OF MATRIMONy. D ecree. 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; ~ . J. ATTEST: . PROTHONOTARY . , . * * . " I ~ '" , j-. -, \'",~-,~ , ~ -- . ..' ._ _ a_..," _c_ ~_~ ,~~, '" .. ~,~"' <,,~ 3)01 dd-~~~~ 3/,qt7/ 71~ ~ '$ ~. ~~~~;!j~~ ~ """","",,~ ,~, e. J _ _ ,-7,,'<~'_ _ ",_~~"_""""""_,,,~~~.RLln 0_ _ "";"v,;; .. " -, JAMES G. BENNETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 6502 Civil . PATRICIA E. BENNETT, Defendant. : CIVIL ACTION - LAW PRAECIPE TO TRANSMIT THE 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 9(3301 (c)) of the Divorce Code. 2. Date and manner of service of the complaint: September 27,2000 by certified mail, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff 1 /30/01 by defendant 2/6/01 (b)(l) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: None ,~. >.-1' , """-' --- _...~ 5. (Complete either paragraph (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: (b) Date plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: 3/8/01 Date Defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: 3/8/01 Respectfully submitted, ABOM & KUTULAKIS Date: March 8, 2001 J son p, Kutulakis, Esquire A orney J.D. No. 80411 Suite 204 8 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ...J", ~~ ri~W~~~Il!'iti~,JiI.;iM~~'N.MtiiE'l.i'lJli:-"'~' ~-'.~.~ __,c ,_ _.~,., .., -~. - ". . '~"""~Ii!lb!i=~ --~ " ~ ,-, - ~. "~ ",! .. , - ~ e c fi? ~l - ::ll:" :to; ,'rt Z@ ::0 IT7:tJ I <-' (tj::z: co ~Df1i ~t5 :,O--!.~ "'~- ~8 ~ ::::,.~. ~'i) ,- :n l.J:f) ~ C..;> 6n'1 " 01 ~ N -< ~ 'a-'. . ,,- "-;>i",Z~'" ,~-1e;;'"',>~ ~".,,~ iM: - " ,- '"' JAMES G. BENNETT , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 -<'D502 Civil PATRICIAE. BENNETT, Defendant CIVIL ACTION-LAW 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 CONNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 2 Liberty Street Carlisle, Pennsylvania 17013 (717) 249-3166 -,'-'- ,-.. ~ , ~ '. .hi, . r , JAMES G. BENNETT , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 - t:.50:l.- Civil PATRICIA E. BENNETT1 Defendant CIVIL ACTION-LAW NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT You have been named as a Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with 93302 (c) or (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Cumberland County Courthouse, Cumberland County, .1 Pennsylvania. You're advised that this list is kept as a convenience to you and you're not bound to choose a counselor from the list. All necessary arrangements , , and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within (20) days twenty of the date on which you receive this notice. Failure to do so with constitute a waiver of your right to request counseling. 0"--- -~;.."- . .,--, M,<_ I, , JAMES G. BENNETT , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 - (,:)0,)...- Civil PATRICIA E. BENNETT, Defendant CIVIL ACTION-LAW COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is James G. Bennett, an adult individual, who currently resides at 115 Richland Road, Carlisle, Cumberland County, Pennsylvania, 17011. 2. Defendant is Patricia E. Bennett, an adult individual, who currently resides at 12 Bentley Place, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 1, 1966 Lompoc, Santa Barbara County, California. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff in this action is not a member of the Armed Forces. 7. The Plaintiff and Defendant are both citizens of the United States. 8. The marriage is irretrievably broken. __"d -~ ~-- ~, -, ~ .".,.,', -,---'._",-'''"-"-,.;,.,, "1~,:_ , . 9. The Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to the divorce decree being handed down by the Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, MARSHALL & HADDlCK, P. C. Date: September 19, 2000 Jas6 P. Kutu akis, Esquire Att. I.D. No: 80411 20 South 36th Street Camp Hill, PA 17011 717-731-4800 Attorney for Plaintiff .' ^ ',;~, ~_ . --"c';'--, '><'_', , "!l.t< '. . VERIFICATION I hereby verify that the statements of fact made in the foregoing Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date: September 20, 2000 ....-'" 0 ~ O~ ,~ . , .; ~, - ~, . ""-" tc'~ SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. ~4304.1(a)(3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBERS PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: March 8, 2001 DOCKET NUMBER: 2000 - 6502 Civil PLAINTIFF/PETITIONER SS # 323-36-0524 NAME: James G. Bennett DEFENDANT/RESPONDENT SS # 558-76-8674 NAME: Patricia E. Bennett ~- ^ . _.,11--,- JAMES G. BENNETT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 - 6502 Civil PATRICIA E. BENNETT, Defendant CIVIL ACTION-LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under S3301 (c) of the Divorce Code was filed on September 25, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. VJdDD I .~ -,,;,.,,,,,., "'-"'"-"~>;~-""'MI'J~~]Iil~li&Jlil!~;'1j11i/ii1lj~ItI\'~'" ~-" ~,., '""< - , ~",:.....-~~_.....--~~-- -'" > ., ^ ,~ ", ,'-~'" ' '-~,"< - '," . . - ~'~ ~ ~I ~ 0 0 -n :;1: --\ "'O.f:P """ j:'.'" --n ~n :=0 :'r;~;::;:; :r; , ~C'm .~ CP ~~~) ~S ~C) ~-f'i -0 :t:"1"1 JS :;: 0(", Z,rt'. ~ ~ ~ ,- ? {ft ~ - 5~ - ,~ - ,*,~, " JAMES G. BENNETI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 - 6502 Civil PATRICIA E. BENNETI, Defendant : CIVIL ACTION-LAW 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 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:h~ .:$ <.D) a 00 \ fJ~ A ES G. BENNETI ~. , ~_~t!'~"~il--r. &~~~~lll!!gi&:'r'-"""~~''-'''j~~'i'rr" ,-" .""'~...~~ ~ .." " .. " ,'~ ... <, - ~~ ..... o - 2 ~\ ~i ?,tJ j8 ~ $ 'P" ;;0 \ d3 --0 ::;i: tJ:l ., tJ\ - ". ~ ~2 J~ '~~~ '0',6 'Zrn 9- ~ ~ ,-. :W,i JAMES G. BENNETT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 - 6502 Civil PATRICIA E. BENNETT, Defendant CIVIL ACTION-LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under S3301 (c) of the Divorce Code was filed on September 25, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904 relating to unswom falsification to authorities. Dat~".f9. ~. tl.,06 I 1 ---fJ!A.<"'~~ PATRICIA E. BE NETT ~'~.:~1fJ ,',< "-~ "~, ,.-. ~ .-lr~p'~ ';~~'~_.'~J:Ul~mr~"-' '. -.- - ~ ^"., ~_~o. ~.,,' _ ~_~ , ~~. ~ ~a~1lllNN i:.!ll.IlJiJiil . t..ci- 2 Cl 0 ~-n ::;!t; .~ ~ :f:~'; ~~ "'" "'" ~,Ji'''r: I .,,~O or; <:P (')eO ~z: --'t~-'l 20 -0 J:--4:J ~8 ~ ';;~ t.f! ~ ; c1l ~ - m 0' ~ ilI\,llU;'-, JAMES G. BENNETT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 - 6502 Civil PATRICIA E. BENNETT, Defendant : CIVIL ACTION-LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER!j 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 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Da~.e4r-~/ J.C()f ~vLzW{ PATRICIA E. BENNETT ~ -'"-"""'~-"""1li!~!lillljj1 i..L~l ~j;;_~~~iin.,..,:wgfu:t'_{--!il;'-~"~"'~'" ,-~ <~",", .~_ .,,_ '''''"_'~ """"",,_,, c_.. _,~_,"" ',~ ,~ -"" '""'-', ~- , ................'".. ~"- " 0 0 0 ; 'T} ::x ~ "" :;U H'i-n ,- I :;~F .-:2: CO '0 ..." ~~ ::c I J8 :x C>?5 .t:1 z. 'C Om Z Ql ~ =<!' -< " --'" -,~,-, '''" -, ~,; .... . ~ JAMES G. BENNETT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 2000 - 6502 Civil PATRICIA E. BENNETT, Defendant CIVIL ACTION-LAW AFFIDAVIT OF SERVICE I, Jason P. Kutulakis, hereby certify that I served a true and correct copy of the Complaint Under Section 3301 (c) of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached return receipt card on September 27, 2000. Respectfully submitted, Date: 10 - 3 -00 . Kutulakis, squire Attor y I.D. No: 80411 20 South 36th Street Camp Hill, PA 17011 (717)731-4800 Attorney for Plaintiff ~~-" - , 'J.S. Po',tal Service , CERTIFIED MAil RECEIPT , (Domestic Mall Only; No !nswance Coverage ProvIded) ~,' ru "" CJ .ll .~ [I"' "" CJ CJ .-'I : CJ CJ postage $ Certified Fee p_aI1< Return Receipt Fee Here (Endorsement Required) Restricted DelivaI)' Fee (Endorsement Requlred) Total postage & Fees $ CJ ru ru Ni'fe (Please PrJnt C~y) (To be cot!J!./sted by mailer) rn Yo,,;m!;'.t~ '\"::'C(\V\eTI ......................._._....._..... ~i~;A~ti~B~::e:~~.........._......_.._._._..._.. ce:~J'it~~? \ 10 \ S ,[I"' '[1"' CJ l'- .. .. . ~ . :11 ~ cdrripiete item~ 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 retum the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No I Po..trlC\ Ct. JY::v\Yle..tr- 1 \J. ~+ \~ P\o..CJl CD-.v\\S\(J (Ja. 110\3 I , I ) I i 1 3. Service Type !;!(' Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise DC.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (Copy from service Jabelj '0<19 ~ d.d{) ()o\n PS Form 3811, July 1999 Domestic Return Receipt 0ifI Y. /.o()?;'::+' 102595-99-M-1789 ~ eo .. 1~ ." <","" ~r!"""'"'''i0' . " .,-) 'J" -",'.' -", iili-ik .. ~ CERTIFICATE OF SERVICE AND NOW, this 3rJday of OciDber, 2000, I, Jason P. Kutulakis, Esquire, hereby certify that 1 did serve a true and correct copy of the foregoing Affidavit of Service upon all counsel of record and unrepresented parties by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: VIA FIRST-CLASS MAIL Patricia E. Bennett 12 Bentley Place Carlisle, PA 17013