HomeMy WebLinkAbout00-08504
. .
_,'_ ,;1-,
-,,,'-
, '-- ~-
.
.
. ..
.
.
.
. . .
.
. .
il:>fiili"""''''
;t;:t:;t::+;
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
PENNA.
STATE OF
ROGER D. MOREFIELD,
.
No,
2000-8504 CIVIL TERM
Plaintiff
VERSUS
.
.
SUSAN E. MOREFIELD,
.
.
Defendant
.
.
DECREE IN
DIVORCE
.
AND NOW,
~ );)..
@,4:ff'/Pf.
2001 , IT IS ORDERED AND
.
DECREED THAT
ROGER D. MOREFIELD
, PLAINTIFF,
AND
SUSAN E. MOREFIELD
, 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
.
ATTEST'~~ J. .
.
PROTHONOTARY .
. ,
.
. , , . . :+::F.:f.iIi . , , . . .. .
.l.
,
. "
.
.
.
.
i
'I
'!
.
.
,
.
.
.
.
.
.
.
.
.
.
.
.
.
"
I,," ' '
~ .
" ,," ",'"
tj./?-tJ/
1'I?tJl
.
~~
Il'Inr~
.- ."
"'" ,. .'''- .~ .~~- ...
"'""~ ~-""~,,~ ...- -~
,\V
,
W $Jo/ ~$cn/~&o
~~ ~,4 ~~
,,,,,,
_.-,~_~ ~!"""","''1'iffiji!~~~~'i1il!~~I:~'i!J~. '. ,N n!i'ijlll!WJ~~~~"'j~~~,;J!M!l~m
ROGER D. MOREFIELD (402.68-3959),
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-8504 CIVIL TERM
SUSAN E. MOREFIELD (162-46.5373),
Defendant
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 3301 (c).
2. Date and manner of service of the Complaint: AcceDtance of service on 28 December
2000 (AcceDtance of Service filed on 8 Januarv 2001\.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section ,3301 (c) of the
Divorce Code: by Plaintiff: 2 Auaust 2001 by Defendant: 2 Auaust 2001
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce
Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the
Respondent:
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:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 2 Auaust 2001. filed 13 Auaust 2001. Date Defendant's Waiver of Notice
in Section 3301 (c) Divorce was filed with the Prothonotary: dated 2 Auaust 2001. filed 13 Auaust
2001.
Date: J ~ LUll
BYS~J;W
Attorney for Plaintiff
II
~ '''' --' '- -,~. . '~>>''-'licii.t'4illil~I.Ua1!1 ,., .
,---~< .1I1t~L,~ ,",_~""",. "'~~ .
;~< ~~~"'H~""-~
.-.
~, -~--
,.Co"
.,"
,,',}
"'" ~.illIIIlllsl
ILJ
o
c
<"
~2:
0S:
~~(.
~~2
::-:::
:<
<,,- "
".~""",
'" .
c '
Ci)
"'"
-"~:J
,
cr',
:::>
(j.
"
.
!_'
..
ROGER D. MOREFIELD,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. iY/). 'iJSD'/ ~ T~
SUSAN E. MOREFIELD,
Defendant
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
foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 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, PA 17013
Telephone: (717) 249-3166
II
'~Lc'.
...
..
ROGER D. MOREFIELD,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. ov. 'iS1J'f~.J T~
SUSAN E. MOREFIELD,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
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
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
il
.~
.
...
-
ROGER D. MOREFIELD,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. lJv.goi ~ 1.Lo-
SUSAN E. MOREFIELD,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, ROGER D. MOREFIELD, by his attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is ROGER D. MOREFIELD, an adult individual who currently resides
at 419 Cherokee Drive in Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is SUSAN E. MOREFIELD, an adult individual who currently
resides at 419 Cherokee Drive in Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residence of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing of
this Complaint.
4. The Plaintiff and Defendant were married on 25 August 1984 in Carlisle,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
II
, ~~
-
.
...
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the
Divorce Code of Pennsylvania.
"
i', f
' I
Date:J...Gk, ,
f
~
D.
RD. MOREFIELD
..
,~
Attorney for Plaintiff
. Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
II
ROGER D. MOREFIELD,
PLAINTIFF
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVil ACTION - lAW
NO, 2000-8504 CIVil TERM
SUSAN E. MOREFIELD,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
The undersigned, SUSAN E. MOREFIELD, does hereby accept service of the Divorce
Complaint filed against her in this matter and acknowledges receipt of a certified copy of
that Complaint.
Date: P<1?.C~n1 kr :Lf, J..trO/J
,
II
'~lu~.~-i-'- '~.<rI"t_~lW_~~~~Jf~-"'.;j;;
~ l-
'<'_;h'_,,^_~'. ~'_~'F' "_'''''''.~~"P._,,~_" ''''_,",,' _,"." ,,,,, "
---",~~ ,."" ""
,..~., ., -"-
~~'_:;';" t-~;- -",Ie-';'; .,;..(., "-" . ^ ~"
~ 0
.. j
"..
(')
c
<.
'l:"J "..:t
n-di'.;
~~.
~c
..;0
~~~)
2:
=<
c'c... w """'.'
C)
(~?
--',
I
co
'~-,;
<~~'j
2:c',
,-,
'-_/
:::~2
~~11i
::0
-<
::)1
.t:'"
~
.'-.-
~.
ROGER D. MOREFIELD,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVil ACTION - lAW
NO. 2000-8504 CIVil TERM
SUSAN E, MOREFIELD,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 7
December 2000 and was served upon the Defendant on or about 28 December 2000,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3, I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and 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.
.1. a ~ ,;ls!e/
DATE
D
il
,'-
;.;""...> H~ li~II~~ ".,," c.""
.l 1
ilia
. ~_J ~ ~_
",- ~iii1ii"'ilfoi~~~~i~~i~illW$i~1' '--
-~, ~.
'<r___~~ ,.,
,,-0"'
;,,- "'---
0_ "'~llfj~
-,
,. -,~,
-,
W1~ '
" . ~-,
o
~-
<2
2:.
-0&
1'Di;%
~,-'
/-=-~;>
'!1..~?c,
r:;:C'
L ('""".
~\
~
';::.-:
"PP
--
Ce.';
'Pc/<
-::t
....0-
.'
-
,.,
!'i
'-,'
.,~-"
,i ;:::,
,"
c:"
',:f~r'
':-;:"\
.~
-
ROGER D. MOREFIELD,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-8504 CIVIL TERM
SUSAN E. MOREFIELD,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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. Section 4904
relating to unsworn falsification to authorities.
C}JJ?
b.
!!
II
iillJ11t "'^,~~ " ".iAI.i!lill;""''''';''';~-'''~lWlJ~!iIl:W~.~Itii:LL ~"L~", '",
- ~" ~
".
-" - - --~-
" ,~'"
.'--<J"
"'IlIllb <<--. IiiiilI. d-~
0 C,:) (;
c
<"" "
-0-""; "'"
me;:, G=5
2m , -r::~
~"
2,'"
cj)~- "'~-i r..:c!
-<~'~. G,:, ,
.' , _~J Y
r::i5 ' .
~ . ;p,
~o ..-.- '-,-
.'1';'" .
5>0 --'-"- (~
c I.:? 6 ,:'
~ U'1 s;:
(J') Xl
-<
. '
.
, L
"'t,:
"
ROGER D. MOREFIELD,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-8504
SUSAN E. MOREFIELD,
Defendant
CIVIL LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
L A Cornplaint in Divorce under Section 3301(c) ofthe Divorce Code was filed
on 12/7/00.
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. I understand
that false staternents herein are rnade subject to the penalties of 18 Pa,C,S,A, Section 4904
relating to unsworn falsification to authorities.
Date: -PI z lof
I '
Susan E, Morefield
,,~ ,
~,~ ';m"~~~il~';''''~~'~'-Jll dWJ\l.~~~j~R,t,~_~...~i&>l61~i1.t" .,=....;;
-~ ".,> ~
-,''''
,.'
.......
1i_;!lL
""~-"~
2
s:
-0 eo
rnr
2:J::
25
U?~?'
;:;.(L.
'2c~
-r.:>-r'.
?-:?~ "
,!2;:;O
YC
2
::2
~.
~
~
(f)
-
(.....:1
~,
'..j
\';
?:
~"
-~~~ (~.~
'- -.,
:;,)~jl
'(5"
~
:.<:
UJ
."
(.l'\
(1'
~ -,-'_~ , - 'I
',J<'
d,"'",- ,
.
ROGER D. MOREFIELD,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-8504
SUSAN E. MOREFIELD,
Defendant
CIVIL LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER 1l3301(c) OF THE DIVORCE CODE
L I consent to the entry of a Pinal Decree of Divorce without notice,
2, I understand that I rnay 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 staternents herein are rnade subject to the penalties of 18 Pa. C.S, ~4904, relating
to unsworn falsification to authorities.
Date: g /Q-/CO I
I I
~'>',
i,,,,,",_i~~ "~l."'';'''';'"_OO~j.,ll,~~",i;',"",-~W1~llil-twll~i~
,"",.~d .
.,<.~<
~, ~,.
',-'
'. _'~"'<i.
^",."
~_~_,,' ~,_~ _~e<,~_.
,;'; ,. ~_~ " .0,'._
'H
.
g C:J (-"
- ,
;;;: :~
ri1 OJ ;S \~.:
fn
:Z:1:] , .,
Z~ c
~:z: 0-" . '
,,'
~O -;,
;po . ,_~ ----r.
;Zo ::1t: ~p
s;;g 'f!
~ ',)'1 ~j
0'> :<
.