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HomeMy WebLinkAbout01-0557 FX . . . . . . . . . . . . . . . . . I~' "I .~ -,. ,,~' , ' . .. ~-,,-:,:~'::. / '- '~'- -- ,,;,. . . . . ~ ~ ~ ~~~ ~ ~ ~ ~ ~ ~ ,.,:F.:Ii:li IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Rri~n.1 .Tnhn~nn Plaintiff No. 2001-557 Civil Term VERSUS Debra A. Johnson Defendant DECREE IN DIVORCE AND NOW, 2.". 2001 ,IT IS ORDERED AND Julv DECREED .HAT Brian J. Johnson , PLAINTIFF, AND Debra A. Johnson , 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; ND~e By THE COURT: / . 4~ .~~ PROTHONOTARY . :Ii :F. :ti "'Of. :F. :F. :Ii :Ii . ~. . . . , , , . , , , , , , , , , , . , . . . . , , , , , , , , . , , , , , , , , , , , , , , , . , , , , , , , , , , , , J. , . , , , , , , , , ~ _ ,-'7_, ~" -''W. 1~ ~ 7 -,;).'l)-tN 7'"'''' aiL,'"' -0/ ~ " , >or " . '. ,';ot" &.;/- ~ ~~'4~ J71~ ~ z dfT "'" ~ JIIilIIIIIJ _ .' _~~~,11'II!!!)!L~~~_ . n_" ' _ ~"~~';_ ,_"= ~_' ~~_ c^ " BRIAN J. JOHNSON Plaintiff v. DEBRA A. JOHNSON Defendant - :.1 "~""""";-.I ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 2001-557 Civil Term CIVIL ACTION - DIVORCE SOCIAL SECURITY NUMBERS OF PARTIES BRIAN J. JOHNSON DEBRA A. JOHNSON 177-60-9269 182-46-4857 r " " 'i' BRIAN J. JOHNSON Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 2001 - ~r7 (L~ lY~ DEBRA A. JOHNSON Defendant CIVIL ACTION - 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 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 Prothonotary Dauphin County Courthouse, Harrisburg, P A. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 TillS 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. CUMBRELAND COUNTY REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Ave. Carlisle, Pa 17013 "'" ~ ,~ ,--."' "-'ill'_ BRIAN J. JOHNSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001- :,-.5'7 ~ ~ DEBRA A. JOHNSON Defendant CIVIL ACTION - DIVORCE COMPI,AINT UNDER SECTION 3301(c) OF THE DIVORCE CODE TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Brian Johnson, by Bryan S. Walk Esq., and represents as follows: COUNT I DIVORCE UNDER SECTION 3301(c) OF TIm DIVORCE CODE I. Plaintiff is Brian Johnson, who resides at 299 Drescher Rd., Palmyra, Pennsylvania, and has resided there for approximately 9 months. 2. Defendant is Debra Johnson, who resides at 1061 Nanroc Dr., Mechanicsburg, Pennsylvania, and has resided there for approximately 11 years. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 8,1991, in Mechanicsburg, Pa. 5. There have been no prior actions of divorce or annulment between the parties. , ~~ ,-I,,' " <c: 6. Plaintiff avers that there are 0 children under the age of 18. 7. The Plaintiff is a citizen of the United States of America. 8. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 9. The marriage is irretrievably broken. 10. The Plaintiff has been advisedthat counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and the Defendant. By4~~~ S. a1lc I.D.# 63881 108 - 112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 ATTORNEY FOR PLAINTIFF Y' . ' o--k '"~ 7' ~, '"~ w.;.'i_ . i - . VERIFICATION I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsification to authorities. Date: 0l1l./ , , . .', -, , , !4.B"" BRIAN J. JOHNSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001 DEBRA A. JOHNSON Defendant CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I hereby certify that on th~3 Day of January, 2001, A copy of the Divorce Complaint was served by certified mail, restricted delivery,retum receipt requested, addressee copy of Plaintiff's Complaint In Divorce upon the person named below, in accordance with the applicable Rules of Procedure, addressed as follows: Debra A. Johnson 1061 Nanroc Dr. Mechanicsburg, Pa 17055 ~-------- B S. Walk ttorney ill No. 63881 108-112 Walnut Street Harrisburg, PA 17101 (717) 238-5113 Counsel for Plaintiff .~ J -. ~ ~,-~ ,. ~ '= ~. lllllili,r'IT', ,. BRIAN J. JOHNSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001 -l:S7 DEBRA A. JOHNSON Defendant CML ACTION - DIVORCE ACCEPTANCE OF SERVICE ~~ lDCP./ ~ bV'. MP~I~~ -- ~ nD$'5 \ D. Is delivery address diffe from item 1? If YES, enter delivery address below: 0, Agent Addressee DYes o No 1, Article Addressed to: 3. Service Type ~rtified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C,Q.D. 4. Restricted Delivery? (Extra Fee) ~ 2. Article N~mber:rC9RY f"?fl? ~ervicfl /abe!) PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M.1789 '-""-'i~-' '1~""~W~ibiJt.FG1~,!~~~~~~~~;jji~llI&-'~~ -, '," ''''';'""'-''''''-.&1if~~ > -~ ~ <. < ~~,~ "-. ~, " .d ~ I ~h ",,. 5-i ~~~. ~ "" "" ~ . >: . Ii I' Ii 'I ;] 1 'J 1',1 , , , :! ,:j ~ i ::j ~J ~ i " ;i 'I ~i li I, Ii i1 'I II I <:) c <: ~~t? %I::':::':~ S:2]-: C:::C-; -.:- ,. ~' J . '"~ j'.- ~ ;;;>",,; BRIAN J. JOHNSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001-557 Civil Term DEBRA A. JOHNSON '. Defendant CIVIL ACTION - DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND W AlVER OF COUNSELING 1. A Complaint in Divorce under Seqtion 3301(C)ofthe Divorce Code was filed on January 26'\2001 2. The marriage of Plaintiff and Defendlmt is irretrievably broken and (90) ninety days have elapsed from the date of filing the Compla#J.t. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to request entry ofthe Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. / Date: 7-9-0/ jj]1WlW,~~~ Cl.<~~' J$l)j-.~Jlj;;~~~~,OO~~~:liU :"'~~'"l>'''-~'~'''~"Ilia''''''''''''''Jliii "'<UJI ~ r , I, r I ~: ; I I: i! Ii iI " !I " :1 II II jl 'I ;:-:1 C_:~- I I c i ''''"" - , , l_D I I :,) '--1 "-'~ .'. '" :,,' .,--"""'.. BRIAN J. JOHNSON Plaintiff IN THECOQRT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001-557 Civil Term DEBRA A. JOHNSON Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY! OF A DIVORCE DECREE UNDER SECTION 3301 (c)OF TlIEDIVOR€1E 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 in do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Qecree 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. Date:-:7- 94 >lit. . ;'~lIiiii ' , .' ~Hf!M';;::~~1l'3-1I ~~,~~-d'~~;o~i.li!!'l~,;Mi1'L'i;"",U&~~~i1i!idtF''''-''''''"--'ti:l.1AiMI -'" _.- \ ,~ - .. (') C <7 2i[":- ",,'- .. UJ' .. I::! ~::i !,I ;i;! I':] 1,'1,' " ::1 :'1 ii iii It, Iii [, 1',1 " I!I c=~ ',,() . :'~, ':'.) ~ ..",I ., - ~ ~-~ -, BRIAN J. JOHNSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001-557 Civil Term DEBRA A. JOHNSON Defendant CIVIL ACTION - DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (C)ofthe Divorce Code was filed on January 26th, 2001 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date:~lr~\<::>\ ~~~~~~ EBRA A. JOHNSO --- .,' ~;'i'"'il ,,;",L"'~:'__~M~&~IW;';lMdlid_'-~%t';'0:J,*~" "'~' '0- -,'"..,.",' .-' liliulJ:Y"'" "~_i_l (-", '--.- ',^ \_iJ ;::.,-. :.,) '- ..: :.'~. . .~ ~~.. W", . BRIAN J. JOHNSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001-557 Civil Term DEBRA A. JOHNSON Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TOREOUESTENTRY OFA 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 in 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. Date: 7\~\b\ ~o~~~ BRA A. JOHNSO -- I:iii .' ""N' 1ill:-';"'~-"""'1I~~li'j~)~.l;il~<t';;I)n!liglfu';;}k-;0>_ld*,",.;:ir.a",g",iI4W;,@~liiIldI. _ _ ~ ,",'_ .~~~, "~. .~,~.J '~~'.dll fU _.=~~: ,- .~ , ..,' " Ii I,' . I! Ii Ii ~ " , " j! , 'I " 'I Ii I II I' i! i I I I I I I " I I I , . I ~. i) I II I I l.,.c.i I I I I :-,) I <--1 i I I . ~ -, ~ ~ ,,~ , - "~~ (..,-" " c BRIAN J. JOHNSON Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. 2001-557 Civil Term DEBRA A. JOHNSON Defendant CIVIL ACTION - 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. Grounds for divorce: Irretrievable breakdown under Section 3301 C of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service by Defendant by first class mail, certified delivery return receipt on January 31, 2001 3. (Complete either paragraph (a) or (b) ) (a) Date of execution of the Affidavit of Consent required by Section 3301 <<':i of the Divorce Code: by Plaintiff on Julv 09. 2001 and signed by Defendant on Julv 13. 2001. (b) (1) Date of execution of the PLAINTIFF'S Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the PLAINTIFF'S Affidavit upon the DEFENDANT: - ; ,,--, ~ ~~"i:i " , . r 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (check one) (a) Decree to be entered under 3301(d) (I) of the Divorce Code; (b) Decree to be entered under 3301 @oftheDivorce Code; x (c) Not Applicable. (See Waiver filed by Defendant on Julv 13.2001 and filed by Plaintiff on Julv 13.2001.) Date: 7 f.~/a' .~- all . Walk Attorney ill No. 63881 Counsel for Plaintiff :_"-'-'0" _ ..l'"",~~~~~~";;W.4'kffi>,!!1R<l;:~~~ i~'N"" .~-~~ ~.'".-~;',-i ,",' ., ,.-,.' '"' C'",", "~" '0 C) 'C C- " , C( , , "'--- , " U} t::) r=: .).':;' -'7') ,:~ f) .J:.-.-" c-. r,,) . i .. -.-' ~' , ::'u .'< c....;, -< .."!: r' , . ,~' , I ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . ',- . ~_ ,J ._, ,.' ,_ . c- : ,,"' "-~-.., . ;<, . . . .. .. . .. ~ ~ ~~~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Rr;,m .J. .J ohnson Plaintiff NO. 2001-557 Civil Term VERSUS Debra A. Johnson Defendant DECREE IN DIVORCE AND NOW, Julv 2001 ,IT IS ORDERED AND DECREED THAT Brian J. Johnson , PLAINTIFF, AND Debra A. Johnson , 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; By THE COURT: ATTEST: ;,^,,-. J. ~, " . ". . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . PROTHONOTARY . . :F. fF. ff. ff. . . . . . . .