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HomeMy WebLinkAbout01-0638 FX " -""" ,"' " *", ~:..;. '"'" --~,'- . . . . . . . .. :f.:f. :+:;t; '" . . :f.:f. '" Of. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . PENNA. . . STATE OF . . PAMELA D. EVANS No. 01-638 Ci vi! . . . VERSUS JEFFERY EVANS . . . . DECREE IN DIVORCE . . . . . . . AND NOW, - Jin" r 17 2003 IT IS ORDERED AND . DECREED THAT PAMELA D. EVANS , PLAINTIFF, . . JEFFERY EVANS . . AND , 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 . . . . . . . . . . . . ATTE . . OTHONOTARY . . . . ,. - ~~k . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . , ~ ,~" 6. ;tZl ?U t:- 'O)oc3 "" - , ',~,~ r 'e'",;'!'- ~, --.-~~,"' .. ,'. " '. , . (&,;/ t~ ,4<44"", $ ~,. ". 71~' ~i/ it' c1P" '""~~ '= ''''o.'_.i>~ "'," "p< ~ U/.D4ce- , "<. ~,~-,~."""".,.,.,...:"! , " ,_ [."j ,"J!lJ~:!'i<1~'l'l!f~I"~r.". , o,~~",_,'fif!'l1~~"'ll"~~"l!"''lil'm~:'lf .", ~,< PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. Ol-{cyt CIVIL TERM JEFFERY EVANS 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 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 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 the 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 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, P A 17013 717-249-3166 ~ fJ;J/~j/-- ranees H. Del Duca 10 West High St. Carlisle, PA 17013 Dated: h5 I-of "~._~ I, ' ':,;_J . , PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. (;>).(, 3 Y CIVIL TERM JEFFERY EVANS IN DIVORCE COMPLAINT UNDER SECTION 330HC) OF THE DIVORCE CODE 1. Plaintiff is Pamela D. Evans, who resides at 264 South Hanover Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jeffery Evans, with a mailing address of P.O. Box 633, Carlisle, Cumberland County, Pennsylvania, 17013 3. 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 Septemer 21,1996 in Carlisle, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, plaintiff respectfully requests the Court to grant a decree in divorce d~IJ4f/2~ ranees H. Del Duca, Esq. Attorney for Plaintiff Dated: 1-3/-() I . 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 10 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: j-.8/-{)/ ~w~" [L ~- :1,[0' (13 ! . , . ~ 4 $ :j;) I . ~ ~:!u:r>(FFiCE CF':' ' ...;':T:+)t'K)TIIHY 01 Jr.1431 I~Fill:03 CUf"Q~i;L/,it) COUNTY PENNSYLVANiA /7S'~ ,<;C)/c/ .a2fJ' ,j:/!/l FcI'~P~ /W;g-:Jr.4 /7L ' tfi' -# .;;2..:2 r;;;/ }!';t-,'t I IF? 0 I :< j -~NT&.REi~~ED'" t~~~.~::~ P~T~T^RY << ~'" -~~, "L " ". ,]k; f r1 If! tEL v'1 a /Er//!tvc: In the Court of Common Pleas of Cumberland Connty, Pennsylvania VS. No. ;:; ,f} Civil.;if,;z~ / :r rE. Ff';;/C Y /3,/ t1l/J <; I'IU tJ,vOLcAfif. , cfL.e/!> ~ tJl V f)F( C:"'f dfell)'!',IATk 'Tff1? tEc:J#1 f7L#' I/l-'/ /IV rrL";t!/? }/IN t/ YI.r- s I dlc1'7 / To Prothonotary 19~0~ ~ #~A~_- Attorney for Plaintiff -, ~,~-q*aw"JIJ,~.:i!;iii:'<;;,"l<"'t..~":~~I"",j,J;.i\:(,Hlf""'~ii:li\i!t,,M..~";;lI'J~,-6, ",",l,bJ'"""",,,,,,;,,'<;Cdo;"il,',,',E~,,,;;;~#;j~IlO.,.ii~ii!'''''''''"'''''''' .u 'i'i~ki~M&,:!k>jJJlijdiiii.llllll4i>:!mjM.~~..w~- -..~fIi,~~" '{ No. Term, 19 _ VS. PRAECIPE Filed 19_ Atty. o c -= -o~Xi n1Lf,": z.-~' ~~'----' ~? r:: c:, <- >C: Z(~> :;Pc :z ::;: ~~ ,-, Cl W o -n ~ (5' .-t; p ,!:;1'7 ~,~6 ",' -'I C,-;:-..". "=;ci --',--m S ~ ~ :% '? m m , '~ ~-~ .....~" PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-638 CIVIL TERM JEFFERY EVANS IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed January 31, 2001, and reinstated June 6, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. I consent to the entry of a final decree of divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list Of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. 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. 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 19 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: c.-(Dr 03 tJ, ^ · 2 "-"f:___ Pamela D. Evans / ,;--,~".~",~"" ~n FD-()\.'T\CE 01; T,;,~",~(,:'c','(I!D:.A,R'I 03 JUH I Z M'll\: ~3 -" Mrc' .,' .. ,',r'U'11"'( vU lot.hLf-\\'1U \JV \\ PHNSYLVf\i\llA w I '1 " I m li! . ~ 11 I i I li! I I it . <'," ,-oW ~. ',;" ""Ii,; .. PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-638 CIVIL TERM JEFFERY EVANS IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed January 31,2001, and reinstated June 6, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. I consent to the entry of a fmal decree of divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list Of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. 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. 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 19 Pa.C.s. Sec. 4904 relating to unsworn falsification to authorities. Dated: (;-( tJ -~ :3 ~~ ~ANv J ry vans , \.\d~,fJ--c;\+\CE QF;:~' '\Cr ~--::\':C)iNq'{ 0: '\ \I\r,\ I') ~'"',>l\: ~'<, -...I ...,'.r" ,- l-\l .~-- CUI/'~"-" " ,', c'~" 'N"" " \ :i,:)cnL)"\;"AJ \..A)vt l' PE\\\\'-!SYLVANIA I ~ '~ ~ ;~ " I , I I . > . ~ ...-' .--,~" ..-iioltia', PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-638 CIVIL TERM JEFFERY EVANS IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l( c ) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: c,- 10- 0 '3 ~-JJJ- P ela D. Evans G'/(l~ HLED-on:iCE or \'t':, 'c'.c:nTccr'NC)\pR'I 0'3 JUN \ 2 M'\ \\~ 33 CUMBt.Kl,j:\\.'tD CUU1'~T'f PENNS'1L\I.t\N\/l.. ~ I !l I i I J I ,~ ~ - '" I ll" PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-638 CIVIL TERM JEFFERY EVANS IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l( c ) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: (;-(0- 0 <;. ~Cvr__ ffe Ev s ~~~~-- .I~)\:nct. \"",'\',',('J"'pV .-' __ ,! -;', \r;ll\ Jlnl \ (: 1\\"\ \\: 33 '" ,\ " .,.n "~,\ 'N'-r\{ \_IV ";b'cr','~../\\" AJ liJu L" PENNSYlVAN\I\ I ~ jij ~ ili I I I ~ i I # ,~ ' " .'.< -. I , " "'-"'-'~,; PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-638 CIVIL TERM JEFFERY EVANS IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ~ day of 74'AUJ , 2003, I hereby acknowledge receiving a copy of the Complaint in Divorce filed to the above term and number. ~~~ OJef Ev s SUBSCRIBED and sworn to before me thiS~day o~, 2003. -... 8IlIIII.IV,..~ NOWIYPllIIUc c.tIIIo........ CuIIIIoo!lnll.....- "Ca " ......... _KF -.--........IIlIll4. . FlL.ED-O;':FICE OF nr :c:')r:C,,\J:JTAHY U"l HII,' " q 1:'1",1 2: 01 v...,,_, .... ,". _..... CUM8[:i"jl..h:'~j C;OUNTY PENNSYLVANIA '"" . if{! I J I I j I ii j ~ . ~.j;~ " ~,h.,' PAMELA D. EVANS v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-638 CIVIL TERM JEFFERY EVANS 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) ) (3391(8)) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: Acceptance of Service of reinstated complaint on 6/6/0~ 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 6/10103 : by defendant 6/10103 (b) (1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code: ; (2) Date of service of the plaintiffs affidavit upon the defendant: 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, if the decree is to be entered under Section 3301(d) of the Divorce Code: d~ f/tif~ Frances H. Del Duca, Esquire \ "t!, FlLiD,Oi'TICE ,,~ T"" ',c~~,_., "~I'InT^RY Ut ;.1";;'" :',"" J ", :\_.. i"1, 03 JUN I 2 Ai'i II: ::! i! CU'ID'Ci"',I, ('(',' "'T" ' I~J~....j :'...r,i.U '..,I,,-,UI'JI) PENNSYLVANIA I I ~ I i I"', :0, I .1 ~