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Home My WebLink About03-1821 JAMES J. DePALMA Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 63 - / Y J. I Q,.v I) ELLEN M. DePALMA Defendant CIVIL ACTION - LAW DIVORCE NOTICE YOU HAVE BEEN SOlID 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 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 tbe marriage, you may request marriage counseling. A list of marriage Counselors is available in the office of the Court Administrator, 4th Floor, Cumberland County Courthouse, 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Court Administrator 4th Floor CUmberland County Courthouse CarliSle, PA 17013 717.240.6200 JAMES J. DePALMA Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. ELLEN M. DePALMA Defendant NO. () 3 16;(.1 CIVIL ACTION - LAW DIVORCE COMPLAINT Offices, HarriSburg, pennsYlvania, and files the fOllowing: through his attorney, James W. Abraham, ESquire, Abraham Law AND NOW, comes Plaintiff, James J. DePalma, by and COUNT I DIVORCE PURSUANT TO SECTION 3301 (c) OF THE DIVORCE CODE Pennsylvania. whose current address is PO Box 3511, Harrisburg, Dauphin County, 1. Plaintiff, James J. DePalma I is an adult individual who resides at 904 South Market Street, Mechanicsburg, Cumberland County, PennsYlvania, 17055. 2. Defendant, Ellen M. DePalma, is an adult individual of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 3. Plaintiff and Defendant have been bona fide residents 2001 in Jamaica. 4. Plaintiff and Defendant were married on October 3, annulment between the parties. 5. There have been no prior actions of divorce or for 6. The marriage is irretrievably broken. --............- Court require the parties to participate in cOUnseling. available and that Defendant may have the right to request that the 7. Plaintiff has been advised that coUnseling is Forces of the United States. B. Plaintiff and Defendant are not members of the Armed enter a decree in divorce dissOlving the marriage. NlmRBPORR. Plaintiff requests YOUr Honorable COurt to Respectfully submitted: ~~ DATE: 4/22/03 ----. James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff James J. DePalma --..-...... verify and confirm that I have reviewed the foregoing document and 3lERIFICATION J:l'rIMO J )10 f'~U<1A-- the undersigned, hereby I, the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: V-/7-D3 CERTIFICATE OF SERVICE certify that I have served a true and correct, date-stamped copy of the foregoing document by certified mail upon the fOllowing person I, James w. Abraham, Esquire, the undersigned, hereby at the fOllowing location on the date stated below: Ellen M. DePalma 904 South Market St. Mechanicsburg, PA 17855 DATE: 4/22/03 James W. Abraham, Esq. C) '\"'- c ~ ~ rf;! ~ 'K' ~ \.J Jj r _ - D ~ -1:::.. r;:' "'\ ~ .-J::) ~ ~ -U ~ ~ (-;. -, - 1 . _1 -------..--.----- "-'---,. ._'--_._-_._.,.._-------._,._-----_.__.,....~--_.._.._.~..... --,..._~._._-~..,--- Mag. Dist. No.: ; ;.' ,03 - tP77 e,~Ul( ~~ NOTICE OF JUDGMENTITRANSCRIPT PLAIN TIF'F.. CIVI L CASE NAME and ADDRESS ~UNGUILD I/II COND. ASSOC. JfO.BOX 622 :(i.QOYNE, PA 1704:3-0642 Uii. "",~" ' '\/S; DEFENDANT: NAME and ADDRESS rii. ' . . BEAR, NEIL, ET AL. 1077-12 LANCASTER BLVD MECHANICSBURG, PA 17055 L COMMONWEALTH ,OF HE COUNTY OF: CUMBER OJ Name: Hon. , 09 - 3405,( :~:.~~x1' . GAYLE A. ELDER i\d~r~~s:.:S'O'7~. ,YORK ST. .'~'..;,:..;,'.MEbBANICSBURG, \::\_>~,,',_: /' ;ii~~" ,',.::i-.' : <:., ':\'.;.,:~.b:.~.>,::i:::-,,!i::~',"!:{:":,:-);;,:::",- i,:',' >i-"':", ;-:r, "'-'~I.';. .:, p~~,., . . , , ':A~.~~.~'il~c.1~(-ri;!oJ'",i.'/ Telephone: (717) 766 -4575 17055 'I SUNGUILD I/II COND. ASSOC. C/O PHI POBOX 622 LEMOYNE, PA 17043-0622 -.J Docket No.: CV-0000323-02 Date Filed: 11/20/02 ,~ :~ . .'. ,~i . "., .. ,. "Tt-f1S'IIS TO NOTIFYVOU THAT: . Judgment: . [i):JUdgment was ehtered\ for: .. 4;, , DEFAULT JtJDGMENT PLTF (Name) RTlNnnTT.n T /TT C"1)Nn ~RRnc C'../n [i):Judgment was entered against: (Name) REAR, NRIT. .1. in the amount of $ 1,201i ::\7 on: (Date of Judgment) 12/1q 102 . . D Defend.cl.nts are jointly and severally liable. o Damages will beasse.ssed QlJ: D This c~se dismissed without prejUdice: Amount citJudgme~t Judgment Costs Interest on Judgment Attorney Fees Total 1.114.87 . 90.50 .00 .00 1,205.37 I. .. p."...o....:~..I t.,..JUdg[1lent Credits. ~e~~dgme.nt Costs :' C~if.Jd Judgment To1al $ $ $ ------------ ------------ . .. Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE Of=APPEALWITH THE Pi=lOTHONOTARY/CLERK OF THECOURTOFCOMMON PLEAS, CIVIL DIVISION. YOU MQSI.INq.~1l9EA COpy OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORMWITH YQUfi' NOTfCI;,OF APPEAL. 'ii':~)(:'. ........... ........... . '.. . . , ..' ..... ..' .. ",'~ . "')'< ~:.~.;,.1<fl-:.~e-;".......: ,:.:::>, '::c:.Di'sfri;t Ju~tice .Icerti~at this is a true and correct copy \j . /. cY7~ate . , District Justice My cor.nmission expires first Monday of January, AOPC 315-99 2006 SEAL i ,) --._.,,-------.-~---..,.,.-._~'-:--~-.,.,..~.-...,..-;--------~,.-. ---'~---'----"'-- THIS IS TO NOTIFY YOU JHA T: JUdgment: ' 00 Judgment was entere~r: (N~~ "'=TI.n TIlT 00 Judgment was entere~gai~: (Natfe) HhWR, T.ORR~ '-.-.)( .- in the amount of $ ,,<" ~2n~7 0' o Defendants ,are jOint'~dS~YrraIlY ~/e. '(~ r.., ",',,- o Damages will be ass~~ed dn: .C/-' o This case dismissed without prejudice. "J . ~., COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Disl. No.: 09-3-05 OJ Name: Hon. GAYLE A. ELDER Add'ElS$'507N. YORK ST. MECH:ANICSBORG ,PA :'relephone:(7i7) '.766:4575 '17055 SON,GUILD I/II COND. ASSOC. C/O PHI POBOX 622 LEMOYNE, PA 17043-0622 '.~,' ."'- ,-,',' ',~ '~~- ." , /. .. / .,' ... '. -,,' / / :' J", ,,-'T~"":"'''' ,., ". \- I .......) , l, i -:"" /. ,t...''Y'' NOTICE OF JUDGMENT/TRAN'SC'FU~ PLAINTIFF~ CIVI~M~~~D~ESS "fSUNGUILD I/II COND. ASSOC. C/OPMI' PO BOX 622 LEMOYNE, PA 17-043,:,0622 L ~ VS. DEFENDANT: . NAME and ADDRESS fBEAR, NEt.I., 'ET.AI.. 1077-12 LANCASTER BLVD MECHANICS:sORG, PA 17055 L Docket No.: CV- 0000323 - 02 Date Filed: 11/20/02 , ~ DEllAm.T .nmGMRNrr PLTF .,.-'" -......, O Amount of JudgmenVSQbject to Attachment/Act 5 of 19-96 $ ......-, (J.- ~ days or 0 generally stayed. '0 o o Levy is stayed for Qbjec~ion to levy has beenfiled:a,ndhearing will be held:, . ''', . . ... 1 Date: Place: Time: (".own lLf:lf:lnl'". l'"./n . (Date of Judgment) 12/1Q/02 - - (Date & Time) Amount of Judgment $ 1.114.87 Judgment Costs $ 90.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 1.205.37 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORMWfTH YOUR NOTICE OF APPEAL. lJ.lq,o:Lvate My commission expires first Monday of January, AOPC 315-99 2006 , DistrictJustice proC~ntaining the judgment. .. " District Justice SEAL tN~~ ~ ~ 'i. ~ ~ F c;:; -- lI) ~ ...Q -, ~ ~ ~ P flJ ~ /.f)f- ~ 1: ~ J) ~ .. .r (") ~;; 'N ~, ~, , -, ~ . , " ~ JAMES J. DePALMA Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03 -1821 ELLEN M. DePALMA Defendant : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, as attorney for Plaintiff, James 1. DePalma, in the above-captioned action, hereby affirm that the Complaint in Divorce filed herein, was served upon Defendant, Ellen M. DePalma, by certified mail on April 24, 2003, as verified by the green return receipt card from the US Post Office, which is attached below: . Complete items 1, 2, and 3. Also complete item 4 jf 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 mail piece, or on the front if space permits. '~~dM, ~~/wo, q () 1..( SCI'Jft...... ftlo. r ~e f ,,5 f- U{;. c /ACU{ (CtJ kt (4 I 7U ~ 3. T Pc'llc9/Q/ " ..Matr 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7001 0320 0002 7584 5527 PS Form 3B 11 . July 1999 Domestic Return Receipt 102595-OQ-M-0952 DATE: 3/18/05 I ./1 i~., ._.._::=- _0 ~ James W. Abraham, Esquire . ~ JAMES J. DePALMA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03 - 1821 ELLEN M. DePALMA Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 22, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing of the Complaint. 3. I consent to the entry ofa Final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE: 1- / (Or /05- I . I ~~ALM~ WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SETION 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! 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904. relating to the unsworn falsification to authorities. DATE: ,Ii"l Ie .>- I ~ePALMA . JAMES 1. DePALMA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 03 - 1821 ELLEN M. DePALMA Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VlT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) ofthe Divorce Code was filed on April 22, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing 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 the Affidavit are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE::::'" \ 8.- \'()~ \ \ ELLEN M. DeP \q~ Sa. ~ {;t'3 W AlVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SETION 330l(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. 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 490 relating to the unsworn falsification to authorities. \ ( \--- . , \ DATE: .3 \:;l....; 6":\ I .. JAMES J. DePALMA Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 03 - 1821 ELLEN M. DePALMA Defendant : CIVIL ACTION - LAW : DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for the entry of a divorce decree: I. Ground for Divorce: irretrievable breakdown under Section (x) 3301(c) ( ) 3301(d)(l) of the Divorce Code. 2. Date and manner of service of the Complaint: April 24, 2003; see attached Affidavit of Service. 3. Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorced: by Plaintiff on 2/19/05; and by Defendant on 3/2/05. bXI) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of plaintiffs affidavit upon the Defendant 4. Related claims pending: None. 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 was filed with the Prothonotary: 3/18/05. (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 3/18/05. Respectfully submitted: ~<y~ L__"'/'-' DATE: 3/18/05 James W. Abraham, Esquire 2157 Market Street Camp Hill, PA 17011 (717) 763-1700 Attorney for Plaintiff, James J. DePalma . . . . . Of. :Ii ff.;t; Of. ff. ff.~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF JAMES J. DePALMA . VERSUS . ELLEN M. DePALMA . . AND NOW, DECREED THAT . AND . PENNA. No. 03 - 1821 DECREE IN DIVORCE r'rIt:)<.r..J. .?:? ,..,J 2005 , IT IS ORDERED AND ITa1'T\P-~ IT. ~Pa 1 ma , PLAINTIFF, Ellen M. DePalma , 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 . . By THE CURT: PROTHONOTARY ;+: ff. '*' '" . ~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " . . . . . . . . . . . . . J. . . . . . . .. 'T7Jlfi/-, yo c-e. [~ f ~ ~'" (,V,;.ic g ( u: i .~;P yp ~ #p'" . ---- --