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HomeMy WebLinkAbout01-0761 FX , , , , , . . . , , , . , . . . . . . . , , , . . , . . . . . , , , . , . , , , , . . . . . . , , , , , , . , . . , . , ,.. .,. .'. i ~., " j ,. . :Ii'" :Ii;+: "':Ii <+:if. "''''''',.,:+; :f. "';Ii it::Ii:f.:t: , , , , , :f.;F.;f. '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF SullO O. Ferbu8. PlaiiaUff VERSUS PENNA. No. 01-761 OiTll Tern! 2001 Albert W. Forbus. Def.lld8.ltt . AND NOW, DECREE IN DIVORCE ~~ ~ ~:L/'7f',vI . J<<>{ , IT IS ORDERED AND DECREED THAT SueD O. l"erbu. , PLAINTIFF, AND Albert W. 'erOO. , 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; , ;f. if. :Ii :Ii,.,,., , leae. By. ATTEST: ~~ "' ~'OTHONOTA" , " ;to :f.;F. "'if. ;F.'" :f.:f.Of. , , :f. '" "',., :f. ;t;1li '" , i'," , , , , , , , , . . . . . . . , , . , . , . , . , , . , . , , , , , , , . . . . . . . . . . . . , . . . . , , , , , , , , . J. , , . . , , , . . . . . . . . , , , , . . . , , , . . . , , , ;t: ;F.;t;'f. ~, ,-, - ~~ ~I J,"l~ ,_"'~' ~~, , //-I/tJl ~'0cJ/ ~" -~~. d,/.~_~;t 4$~ ~~~~. . ''''',- ",'-', , ~" ",_",I'!I\iII1~Il"l~1~~~o/'l""""~' 1~"'1:!l!:_~!1 ~_ ~-~"'"",~ ~ ',,1,,0, ." . ":' ,1 ; ~..; ~ ._, 1 ".. , """_~_iL' t' , k-. ~ . SUSAN C. FORBUS, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : No. OJ- 'f(. I ~ ,- JL.L,v--- ALBERT W. FORBUS, Defendant : ACTION 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 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. Where 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 at the Office ofthe Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 (717) 249-3166 .. "" - . . ~-~,,'-'" ,'~-,"' ~\ SUSAN C. FORBUS, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. bl-'1(.1 ~ T~ ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is Susan C. Forbus, an individual sui juris, who has resided at 22 Brian Drive, Carlisle, Cumberland County, Pa. 17013, for approximately one year. 2. Defendant is Albert W. Forbus, an individual sui juris, whose address has been P.O. Box 239, Marion, Pa., 17235, for approximately two months. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on July 21,1992 in Weyers Cave, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together, namely, Tyler W. Cutchall, dob 4/19/90, and Andrew W. Forbus, dob 8/15/92. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces ofthe United States of any of its allies. .-----,______c.__ i~",- ,>'"~" ~. i --,_,~,--_" _ ~ ", ',,~ ('i' ,4 , . 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken; WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. ~1.Dl\n c.. --4cn.btu:J Susan C. Forbus, Plaintiff Respectfully submitted, Date: d- -6- -01 an Adams, Esquire I. . No. 79465 7 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF OO~~"'''''I\I'1l:.....~~~~~!!i\l~''-';1~iliil!:>!~li:Jili';:ttjltH,i'lMlltm'WMili!l;!l~",.bii&"ii'-''''-_'-:i-;;.<<<I;i,t*~w.iUt "FP '- IS '" Lv --l "" '" 0 \.., '" ,"",,,,"," ""'lu~I:iNi:i.~M,_"j,;j~~i!IIMl;i1 liiik4:lill~'-~ ~'W'it~'IIiiJ " ... " ~ 0 0 () C , ~ -" ""0(",' ,""1 -~ fTlf'i::', OJ Z:1J :2':,' , :~ (j) ):". ~,-t - - ~/ .~C) --- r- ~',.- -'"0 ~~~~ :fG ~",~ :l>i=' ~ ;::-:~ r,j Z ;.n :;3 ~ 51 I...' ~~ @ rP ~ <<! -'" --I 0<) lit c v, (J" g ~ cJ ~ ..,~-. ~ ' , ... ,. , SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA ; No. OJ- '1t./ ~C-J.T~ vs. ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated in December 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I 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 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. Date:.Q ~5-o I ----611[:)0..(1 {\ '1-0n. ~l1Q Susan C. Forbus, Plaintiff ~l,~,. Jil!>;" '.n ~l'!~4'll1Ji;M.I~i!l$j%lt1ltjliill~!:4i!J~~.\&Mi;~1rl~1iJ."~"O",":4"-";"ijji~,;';i;"'t...;i;i',\J\;;'-,*i",\;)"'ll~~~.it__I!iltjgli~j~'I~~~~i!M~!&'IlIINk:~~lilIIIiiIlIiIiIJtJil.~t411I!ii~~f~~_t.'11 ., ~ [:} ~ ~(}'.. !..'Ir'~, ;g:.::e ~'r-,: (:0'l-. ;:s, ~~~ ~C-J .b: - <,. ~r--"~' -'-, S;; ~ ,.,. ,~~,~. '-- '.-, .o~,_ .~ ~,. "",_ , C) - () 'II -'1 ["11 ':0:;, I ....., .' -;!"T"'; -~ 1-''- ,':':,l(~,; ::y --:-'. .;:J;A! (5T:<l 'bj ':0 -<:: i'\) '. :..r, en ~ ,.,<'"~- "" - -- ~', ~- 1'-' il U--"~f~ " - :':jI , SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE TO: Albert W. Forbus P.O. Box 239 Marion. Pa. 17235 DATE: March 7, 2001 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 330l(d) affidavit. Therefore, on or after March 27.2001 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a fmal decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO TmS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE TmSPAPER TO YOUR LAWYER AT ONCE. IFYOU 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 (717) 249-3166 ','"-~ 'h"'''''''' =~= '-' ,-<, ~u ,I ~ . . t SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) of the DIVORCE CODE 1. Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. _(b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. _(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if! do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verifY that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: Albert W. Forbus, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. ~ . '-~ , ~~~_~!"".J,illln~~~1,;5;~i~:iMC":,{i'~':W","'1E""",".,;i~""f4ih14ti:!t:i.l.~~ ,-=, "' ~^ - ~,- """"""1li!.lIllilHlll*'i'*IiillOii~;:~.I!IIII:;:""""~'. " ~... '-IlU([ '.~ . 0 0 l~: c: "U1::;::; u",~ 'i:"" ~~~r :~-ZJ Z \--- N co CO -< " ,- C" or --0 :i> (') -'-~ Z .--.. 5> u C~'? c: -/ ~ W f'" lil.1l ~ . SI ." ....-~ .0 l .ld'.h<;~,:( t SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE AND COUNTER-AFFIDAVIT AND NOW, this March 28,2001, I, Jane Adams, Esquire, hereby certify that on March 8, 2001, a true and correct copy of the NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE AND COUNTER-AFFIDAVIT were served, via certified mail, return receipt requested, addressed to: Albert W. Forbus P.O. Box 239 Marion,Pa.I7235 DEFENDANT Respectfully Submitted: ~ e Adams, Esquire .D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FORPLAJNTIFF .-'~~~, .. '-"'--'ko "',"," "'t' Cdrhplete'tteh;s 1', 2, and 3':;Al~~"complete item 4 if REtstricted Delivery is desired. . Print your name and address on the reverse go that we can return the card to you. . Attach this card to, the back of the maltp'iece, or on the front if space permits. 1. '1\rticle Addrossed to: Af b~"r+ W, FDrbvS A o. Vf>n( d--3 CJ fha.00Y\ I PI4 J 7 d.. '3>S-- A. Received by (please Print- Clearly) Il C. Signature X ~see D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3.~ ~ 0 Express Mail o Registered 0 t=l;etum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery?-(E,WaFee) :D-Yes 2. ArtIcle NumlJer (Copyfrorp service fabeQ _'- -,-. .,,' '! : ; ::: ' :r?~~ft.i1t.j~f>(fI)J~f1O~{;+k~7 .... PS Form 381 ~,J~ly 1999 Domestic Return Receipt 10259S-99-M-1789 c+. -.~ '" . ~-"" , '. _ ".'~,;"': .'1 ~- ,. '. l SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DNORCE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE :IDi Albert W. Forbus P.O. Box 239 Marion. Pa. 17235 DATE: March 7, 2001 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after March 27. 2001 the.Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for eco~omic relief. A COlJNTER-AFFIDA VIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF'THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 (717) 249-3166 .. " ( " , , "" '_' ,', , ",,_1 ,<.~ '"'""'~ ,", ..-- I .-,,- - .Yi~- .-.-:'(_,,: "._,~-~ , I / / SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE COUN'IER.AFFIDAVIT UNDER SECTION 3301(d) oftbe DIVORCE CODE I. Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. _(b) I oppose the entry of a divorce decree because: (Check (i~,(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. . _(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _(a) Ido not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if! do not claim them before., a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If! fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be. entered without further delay. I verifY that the statements made in this counter-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: Albert W. Forbus, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. llit~~:J.-:un~"iiJlh!-l"<3jh:\,;,;,,;!j""I~~~~;r.:-il!~,.nl"~;;""~'~"i."Zf",..""tj"_'I"'0-J~,,&~i\l~iiiii\:i~jjl~....,i,,- ~ '::.ilt~Ilk~~~JI!diWQr L , ~:... ........;iir - < "'-~ ,",,'" Wl~!~I~ 0 c:;:;, c: <- -U C~; illf~-: :;~:J-=-I 2:1: N ~~?: co '-..- ,::: c: ,] I'" j; C. .',"" Z C'! ---... )> , , (:~) c: '";": Z ::::-1 ':.0 :::'~:: =< ~J Iv -( ~ " it;, I I I I I I I i , , . , - -'Sl ~- . ~ !UBI.! ,,-,,.',;-, .. SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE TO DEFEND. COMPLAINT. AND AFFIDAVIT OF SEPARATION. AND NOW, this February 19,2001,1, Jane Adams, Esquire, hereby certify that on February 14, 2001, a true and correct copy of the NOTICE TO DEFEND, COMPLAINT, AND AFFIDAVIT OF SEPARATION were served, via certified mail, restricted delivery, return receipt requested, addressed to: Albert W. Forbus P.O. Box 239 Marion, Pa. 17235 DEFENDANT Respectfully Submitted: Jan Adams, Esquire I.D No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTITF ~.m:~;illl!b!lk~~i;lI""~ifog~J;:iJi;f"'1''''\'il;E,,,,f,'Mf'N'i,"~:MJi;'-;&jU,]lb1l,.'4]'-'~hlilIr!jlllmli!iii""""'."'--"Jlfr ~ .~ -" ~ ,~' ,^ o C -tJ~; n'!r" Z::C ~~~i', ~~:~ ,;'::",..---.. ~t: - L-. Z =< . ,. ~- ,~~ ~~ 1iiIIIlJ, t;:-.:) "'1 ,""'1"1 :',:;0 f'0 -TJ L- r'-" ~ fi' ,-,~ , - , I . ',' ''--".t-, ,;. -<',,,~, ~",_"-_',:, ~_. -"" --,,-.......- -,-,',- . Com~lE!le items'1. 2,. snail: Also complete item 4 ~ Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card .10 the back of the mailpiece, or on the front If space permits. 1. Artiqle Addressed to: D. Isdellvery__trum_1? If YES, enter delivery address below: o Agent o Addressee Dyes DNo ~t.u.Iiwbu5 I? a LSott" 231 AtP1AO"i1" fa. ./7:;)Js;- (/ f- 2. Article 3. Service Type o Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) " o PS Form 381 1: July 1999 Domestic Return Receipt 102595-GG-M-1789 .. ., " --------,--- ,- ' - ~--.._'~-,~--~._~._-'-- .' ~ ,'. '-''''~''!llI-'''1''' SUSAN C. FORBUS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant ACTION 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 &330Hd) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted delivery. return receiot requested. delivered on: Februarv 14.2001. Affidavit of service was filed Februmy 19.2001. 3. Date of execution of the affidavit required by ~3301(d) of the Divorce Code: By Plaintiff: Februmy 5. 2001. Date of filing and service of the plaintiffs affidavit required by ~3301(d) of the Divorce Code on respondent: Filed: Served on Defendant: Affidavit of Service filed: Februmy 7. 2001. Februarv 142001. Februmy 19. 2001. 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: Plaintiff's original notice of intent and counter-affidavit was served on Defendant on March 8. 2001. via certified mail. return receiot reauested;: return card and affidavit of service attached. Respectfully Submitted: Date: if. 2. . 0 I J e Adams, Esquire . No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ~~-"""~' ...-~ . - j. -,' ,~. ,--, ',' ;,' , "-"--~' iili'Vic,i - - ..-.' I SUSAN C. FORBUS, Plaintiff : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE IQJ. Albert W. Forbus P.O. Box 239 Marion. Pa. 17235 DATE: March 7, 2001 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after March 27. 2001 the'Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. . Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for eco~omic relief. A COUNTER-AFFlDA VIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO TillS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you wiIllose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 (717) 249-3166 '-~~~ , "~ ~ " ""-.'~ -~- - . - ,. _"0"-. 'c SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANJA vs. : No. 01 - 761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(1\) of the DIVORCE CODE 1. Check either (a) or (b): _(a) J do not oppose the entry of a divorce decree. _(b) J oppose the entry of a divorce decree because: (Check (i),(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. . . _(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that J may lose rights concerning alimony, division of property, lawyer's fees, and expenses ifI do not claim them before,a.divorce is granted. . _(b) J wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. . , J understand that in addition to checking (b) above, J must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. IfI fail to do so before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree may be.entered without further delay. I verifY that the statements made in this counter-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: Albert W. Forbus, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. - - ~ ~ ~ ~ ' .' , ., ' J \ SUSAN C. FORBUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 -761 Civil Term ALBERT W. FORBUS, Defendant : ACTION IN DIVORCE (') 0 ~ ~'-- :Jl: -oi5: :r,;,;" 92n', :;0 ~~ ~ r::::c; -""'J AFFIDAVIT OF SERVICE OF THE NOTICE OF INTENT ~ (:1 :::1: TO REOUEST ENTRY OF DIVORCE DECREE AND COUNTER-AFFIIi1rIT~ =<! Iv AND NOW, this March 28, 2001, I, Jane Adams, Esquire, hereby certify that , on March 8, 2001, a true and correct copy of the NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE AND COUNTER-AFFIDAVIT were served, via certified mail, return receipt requested, addressed to: Albert W. Forbus P.O. Box 239 Marion, Pa. '17235 DEFENDANT Respectfully Submitted: ~ e Adams, Esquire .D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF t,- o -;--) .-., ~5~;~ ~~ ',"~>R" ~ ,~ ^ ~ ,,;,. , ~" '~""' . SENDER: COMPLETE THIS SECTION . Complete Items 1, 2, end 3. .Also complete item 4 if 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 maltpiece, or on the front if space permits. 1. Article Addr~ssed to: A. Received by (PI.... Print Clearly) IJ C. Signature x ~ssee D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No Af~+W. h)V",bvs PO. B~ X ),,3 CJ fh~OYlI PI+- 17'd-3S- 3. Service Type ~ 0 Express Mail o Registered 0 RetUrn Receipt for Merchandise o Insured Mell 0 0.0.0. 4. Restricted Oellvery'l (Ei<lra Fee) ,0 Yes i'SOS""J 102595-99-M-1789 PS Form 3811, July 1999 .'DomeStic Return Receipt .