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Home My WebLink About01-1302 FX . . . .... .- ..,-" . d, " ,~,- ,'.;. Of. :Ii ;F."':ti"':ti ,.,"'''' . ;F.;F. iF.;F.;F. "'''' :Ii :Ii:li "'''' . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . . STATE OF PENNA. . " . BEATRICE P. RADABAUGH, Plaintiff NO. 01 - 1302 CIVIL TERM " VERSUS . . " . . NORMAN H. RADABAUGH, IN DIVORCE . . . . . . . . AND NOW, " . . DECREED THAT . . " AND " Defendant DECREE IN DIVORCE vV1 [.DJ- I '\ :ZtJO , , IT IS ORDERED AND BEATRICE P. RADABAUGH , PLAINTIFF, NORMAN H. RADABAUGH , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRlMONY. THE COURT RETAINS JURlSDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAlSED OF RECORD IN THIS ACTION FOR WHlCH A FINAL ORDER HAS NOT YET BEEN ENTERED; " . . . . " . . NONE . . . . . . . . . . . . . BYT ATTEST: PROTHONOTARY . . .. Of. ;F.:ti Of. '" . . . ;to '" '" '" J. . . . . . . . . . . " . . . . . . . " . . . . . . . . . " " . . . . . . . . . . . . . . " . . "i~i.w '"",.~' ~.";;; . .' . '. ~~M.~.t;' _A.o~_""",'J~~',. :lfi :"",,'c,~,.'; ',)'i':.J, '>'. . ':... .' - "lIlliliii:jjl:Ii!ItI1l!~"" ,;..,' ~ ~-- )I.' ~p ;Z ~ ~ I(/-(/.,$ ~ r ~ ~ 4 /'V Ie?- Iff.}!. "f~_, , .j ~ i., , ."~. _""". ,.,. '~i~.i.G:.~ ,," __ > ',i - ,,, ""-"'~~'"-. ,,,,"",",,,'~ ...Jj ,I ""' 'iIliii' ~ ,'-,;""'.- ~lllM.iiJjf"'"::: , ~ , BEATRICE P. RADABAUGH, Plaintiff V5. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 - /3 oJ.... CIVIL TERM NORMAN H. RADABAUGH, Defendant IN DIVORCE NOTICE 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 the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 A VENUE CARLISLE, PENNSYLVANlA 17013 (717) 249-3166 SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: i~""' ~-. >~ 1-- " ~ I _ n ~~_ _~~_'.' BEATRICE P. RADABAUGH, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2001 - /3 0 2- CIVIL TERM NORMAN H. RADABAUGH, Defendant : IN DIVORCE COMPLAINT BEATRICE P. RADABAUGH, Plaintiff, by her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is BEATRICE A. RADABAUGH, who currently resides at 41 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania, where she has resided since June 2000. 2. The Defendant is NORMAN H. RADABAUGH, who currently resides at Lot 76, Big Spring Terrace, Newville, Cumberland County, Pennsylvania, where he has resided since 1995. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 28, 1988, at Shermans Dale, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties except that, upon information and belief, Defendant herein filed a Complaint for Divorce in the Court of Common Pleas of the 41st Judicial District, Perry County Branch, Pennsylvania, approximately five years ago. A search of the docket by the Prothonotary does not locate such a Complaint filed January 1, 1995 to the present. i"~~'-"'~1' " ~.........J,~ ,., . ~ , 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: Date: 1fJ/101 I 1 --. Jl..!llililll~~- . SAlOIS SHUFF, FLOWER & LINDSEY ATI'QRNEYS'AT'LA W . "26W. High Street Carlisle, P A ~;--, VERIFICATION I, the undersigned. hereby 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. 94904, relating to unsworn falsification to authorities. ;{ Date: SAlOIS SHUFl\ FLOWER , &iliffiSAY .rtn1I1MlXlj0,4J'olAW 26 W. High street Carlisle,PA ,",,' '",., ,~-" -,-,", t I>, .. '. I:' ,;' BEATRICE P. RADABAUGH, Plaintiff :,:! ';f ~ vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : NO. 2001. /3oJ- CIVIL TERM NORMAN H. RADABAUGH, Defendant : IN DIVORCE I:, k: I: i", f': !:~ i:1 I m AND now, this CERTIFICATE OF ~, ) ~, day of , ~ 1': i; ,2001, I, CAROL J. LINDSAY, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & ''i i-~ f;" LINDSAY, Attorneys, hereby certify that I served the Defendant, NORMAN H. I' [' -':: RADABAUGH, on March 13, 2001, with the Complaint in Divorce by Certified Mail, ~;j i:~ I" 1 1 Restricted Deliver, Addressee Only, Return Receipt Requested, addressed to: Norman H. Radabaugh Lot 76 Big Spring Terrace Newville, PA 17241 , i' .;' and proof thereof, the signed Return Receipt Card, is attached hereto. 'i (,j SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By Caro J. ndsay, Esquire ID 4 3 26 West High Street Carlisle, PA 17013 (717) 243-6222 i, I II SAIDIS SHUFF ROWER " &LOOSAY ATlOllNElSo,tr.lAW 26 W. ffigh street Carlisle, PA BEATRICE P. RADABAUGH, Plaintiff V5. NORMAN H. RADABAUGH, Defendant ~ oJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 - l,3o:L IN DIVORCE CIVIL TERM PROOF OF SERVICE . Complete items 1, 2, and 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 mailpiece, or on the front if space permits. 1. Article Addressed to: ~~~~ ho~'ll" ~~~~ ~o.co- ~,,~\.\~ ((A \l~4 \ l 2. Article Number (Copy from service label) 17D9'1 0<1D6CDI?'] .:!:JO</-'1 PS Form 3811, July1999. 7/'-11 x D. ]s delivery address different from item 1? If YES, enter delivery address below: ~ No Lf1/ q f~Ni1 .rU- J t&WW'h-! f}ICl ~ \10 70 3. Servlc pe ertified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise DC.G.D. 4. Restricted Delivery? (Extra Fee) DYes "'--- - - - --- - - ~_. '. ,- "- Domestic -Retum Receipt 10259S.00-M.09S2 ,_n,"""'" __~ ~ SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS'AT'LAW 26 W. High Street Carlisle. PA ~~k BEATRICE P. RADABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2001 - 1302 CIVIL TERM NORMAN H. RADABAUGH, Defendant : IN DIVORCE AFfiDAVIT OF CONSENT 1. A Complaint in Divorce under 1'> 3301 (c) of the Divorce Code was filed on March 7, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information 13nd bel,ief. I understand that false statements herein are madesubject to the penaifies on8 Pa.C.S.49D4 relating to unsworn falsification to authorities. II ~ ~ - ~ . +, ',' ,."' _ '-0,_ _ _ _ ~. .....JlI;i\t<h!~"'" c) li-;, ')0- , ~2: (:3~;; :,)~~ '::J:..J ..'>- '~<~? - ~. :::-,;: .-....... '-j:Jz-]~ '> ") <') C~~ '-",j .,J SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEVS'AT'LAW 26 W. High Street Carlisle, PA ~-~, BEATRICE P. RADABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION. LAW : NO.2001. 1302 CIVIL TERM NORMAN H. RADABAUGH, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER s3301 (el 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. 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. eatrice P. R~U9h' Plainti Date: ~ 4; II Cl u-: >- t"'- -~ ~;;i - , ):S ~)~E <'::~ ,>- -_'? \J) ):-~ :::7 -,jt2 '-:;-. :'5 C..) (:::1 '..j ~ JOOZ 0 l lnr , . i', ,,~- ;-~'- ,"--." '" ',-.- SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle, PA ~, BEATRICE P. RADABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2001 - 1302 CIVIL TERM NORMAN H. RADABAUGH, Defendant : IN DIVORCE AFfiDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on March 7, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. ~.w . /4 ~ / L A , Norman H. Radabaugh, Defendant Date: '7 ~ 70-,rl . II "i-''''_iiih!!lBv.~"~'itiiiri1l!i.~Wt:r-~-'~-;~'~!!l~iMmtllili!m'4HI~!IDl'ii~iill!iW: .I-.....:r eH1T_~J'" . ~~-'. ~ ~~= . g 0 0 .0 s: ;po -UCP ~ --;1 mln G5 r= Z::c I ..-,m 75;; ''I=' ~~; ~~~ _C./ -0 ~O :x ;i>g t;-? Qill ~ 0 ~ .;;:- ~ . SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle. P A , - '_~ 1-" " -oJ' "~ BEATRICE P. RADABAUGH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2001 - 1302 CIVIL TERM NORMAN H. RADABAUGH, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER s3301(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. 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. -t/tl.. -we/LA , , Norman H. Radabaugh, Defendant Date:~ /0-",1 II .~.:. ,-", ,I' ,-~'" ~t!~IiI:Uii ~ :alJ~_~Mo!4~"..Jij~~~i,lli~~JtjI~fjj 1["='''' ~ ...~~~ .'10,='-' "'. ~ ; () 0 C) C -r: $:: ;co. ..-4 ~m ~ ~+i~ :J;;' a=; Zs;,: I Tl.rn :j~~O ~~, .";;." L_ ~,~~ !,:::O -0 ~C :Jt.: -0 )>C ~ Om ~ --I 0 ?{j .c- -< . - f. ~ ., " '" r\' BEATRICE P. RADABAUGH, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 2001.1302 CIViL TERM NORMAN H. RADABAUGH, 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) 2201 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified Mail, Return Receipt, signed by Defendant, Norman H. Radabaugh, March 13, 2001 and recorded March 28, 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 the Plaintiff July 8, 2001; by the Defendant July 10, 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: _ 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 3301(c) Divorce was filed with the Prothonotary: August , 2001 Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: August ,2001 ..~<~.J.r.J~lil~~lW--g,"-"--";(IlLiI~~_~,"fIj'~'''';h<iM'''i';:Ii-,,~ME<-';''''"';,,-'t.~' ~lI'~ Iii ~ 00, ~.. ~--~ ~.~ ~.l!I ,."", '" ": (') CJ C 5~. ~ 'V'OJ ,::n mrT\ Z""" \ ZC \,,0 (/'U:- '~- .) 2-'- ..,";-::,:'-! r--~ -0 :.::::"-'_.- ~'~," .~--} ;::;.~ ~9 -.,,. ~;,~.rf -l~ r;-? '3 ;poc -;7 :::.J :n ~ 0::> -< ! ~._~ -, ~I - .1,.--, 1lA1~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~U(ce_~/JM~,,4. Plaintiff Vs File No. o?OO ( - cY l-3oO!. IN DIVORCE ) ;b/2/f1l"V/l I-I./?J,J,0/c4. , De!'endant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one 6y marking ''x''] _ prior to the entry of a Final Decree in Divorce, or -X- after the entry of a Final Decree in Divorce dated f;? ?,k,1 hereby elects to resume the prior surname of i!,eev!;tfCl!- f? CroIJJe , and gives this . written notice avowing his I her intention pursuant to the provisions of 54 P.S. 704. Date: (./3/0 Y ~6~-n-:~CtA/p t.- , SIgnature T~ /?~/M~ Signature of name being resumed COMMONWEALTH OF PENNSYIfV ANIA ) COUNTY OF ~r6end On the ,3rcl day of -9 lJ..J\Jl , 200i before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. CJ. fLU~---- q ~M Notary Public NOTARIAL SEAL CLAUDIA A BREWBAKER, NOTARY PUBLIC Carlisle Bora, Cumberland County My Commission Expires April 4, 2005 -- :::r w,? ~ C::' UJ-.;~ 0"'" ~-o l-'-"T' !.j-~ ~~ W --'w 1I:c I- 15 .' co ..:.T .-, ~ :;;,: E.= z ;,:;1<( ~3~ :,:J~ '~'~:5~ ~~rj dJ tOfl... "> 5 o ("') I Z :::> ..., .:r = <::> ..... - _'..0-.. " "~,,_\iK-i,'" ~