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HomeMy WebLinkAbout03-2015Russell W. Nutter Karen L. Nutter Plaintiff Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : NO. :CIVIL ACTION - LAW :IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. Ifyou wish to defend against the claims set forth in the following pages, you must take prompt action. You are wamed 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 claim of 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 grounds for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 Lawyer Referral Service 2 E. Liberty Avenue Carlisle, PA 17013 (717) 249-3166 DATED: BEINHAUR & CURCILLO Russell W. Nutter Ye Karen L. Nutter Plaintiff Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03 ,. :CIVIL ACTION - LAW : :IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OR SECTION 3301 (d) .OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Russell W. Nutter, by his attomey Joseph A. Curcillo, III, and seeks to obtain a Decree in Divorce fi.om the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Russell W. Nutter, is an adult individual who resides 918 Hawthorne Street, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant, Karen L. Nutter, is an adult individual residing 918 Hawthorne Street, Enola, Cumberland County, Pennsylvania. Plmnt~ffand Defendant have been bona fide residents of the Commonwealth of Pennsylvania and have resided therein for a period in excess of six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 24, 1992 in Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant are both citizens of the United States of America. 6. Plaintiff avers that the ground upon which this action is based is that the marriage is irretrievably broken. 7. There has been no prior action of divorce between the parties in this or any other jurisdiction. 8. The Defendant is not a member of the Armed Services of the United States of America. 9. Plaintiffhas been advised that counseling is available and that Plaintiffmay have the fight to request that the court require the parties to participate in counseling. 10. There are no children bom of this marriage. WHEREFORE. the Plaintiffrequests this Honorable Court to enter a Decree in Divorce from the bonds of matrimony. Respectfully submi~e~g~ ~ ~eme Court I.D.~I~0 3964 Lexin~~eet Harrisburg, PA 17109 (717) 651-9100 Attorney for Plaintiff 2 CERTIFICATE OF SERVICE AND NOW, this 1 ~day of.]~, ~ ,2003, I, JosephA. Curcillo, III, hereby certify that a tree and correct copy of the foregoing Complaint in Divorce will be served by the undersigned by United States first class certified mail, return receipt requested, postage prepaid, addressed as follows: Karen L. Nutter 918 Hawthorne Street Enola, PA 17025 DATED: Respectfully submitted, BEINHAUR & CURCILLO Supreme)2~urt I.D. 3964 L/elington . Hanfp/b~g~ {7109 (717}-65ff59100 Attorney for Plaintiff 3 VERIFICATION I, Russell W. Nutter, have read the foregoing Document and hereby affirm and verify that it is true and correct to the best of my personal knowledge, information and belief. I verify that all of the statements made in the foregoing are tree and correct and that false statements made therein may subject me to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. Russell W. Nutter DATE: Russell W. Nutter, Karen L. Nutter, Plaintiff, Defendant, :IN THE COURT OF COMMON PLEAS OF :DAUPHIN COUNTY, PENNSYLVANIA ; .* No. 03-2015 Civil Term : :CIVIL ACTION - LAW : :IN DIVORCE AFFIDAVIT OF CONSENT (Under Section 3301(c)) 1. 1. A complaint in divorce under Section 3301(c) of the Divorce Code was signed April 15, 2003, and filed on and is time stamped April 29, 2003. A time-stamped copy was served on plaintiff. 2. The marriage ofplaintiffand defendant is in~etrievably broken and ninety days have elapsed fxom the date of filing the Complaint. 3. I consent to the entry ora final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property. Lawyer's fees or expenses ifI do not claim them before a divorce is granW~l. 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. Cons. Stat. § 4904 relating to unswom falsification to authorities. Russell W. Nutter Russell W. Nutter Karen L. Nutter Plaintiff Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : :No. 032015 Civil Term : :CIVIL ACTION - LAW :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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 fights concerning alimony, division of property, lawyer's fees or expenses ifI 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 thc 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. §4904 relating to unsworn falsification to authorities. Date: Russell W. Nutter, Plaintiff Russell W. Nutter, Karen L. Nutter, Plaintiff, Defendant, :IN THE COURT OF COMMON PLEAS OF :DAUPHIN COUNTY, PENNSYLVANIA : No. 03-2015 Civil Term : :CIVIL ACTION - LAW : :IN DIVORCE AFFIDAVIT OF CONSENT (Under Section 3301 (c)) l. A complaint in divorce under Section 3301(c) of the Divorce Code was signed April 15, 2003, and filed on and is time stamped April 29, 2003. A time-stamped copy was served on plaintiff. 2. Thc marriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaim. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property. Lawyer's fees or expenses ifI 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 fa/se statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Karen L. Nutter Russell W. Nutter, Karen L. Nutter, Plaintiff, Defendant, :IN THE COURT OF COMMON PLEAS OF :DAUPHIN COUNTY, PENNSYLVANIA _. No. 03-2015 Civil Term : :CIVIL ACTION - LAW : :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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 ifI 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Karen L. Nutter 4 Russell W. Nut,er Karen L. Nutter Plaintiff Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :No. 03-2015 Civil Term :CI¥~IL ACTION - LAW :IN DIVORCE PRAECIPE TO TRANSM/T RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divome: irretrievable breakdown under § 3301(c) 33P~l(d)(1) of the Divorce Code. (Strike inapplicable section) 2. Date and manner of service of the Complaint: United States first class certified mail, return receipt requested - April 30, 2003. 3. (Complete one) (a) Date of execution of the affidavit of consent required by § 3301 (c) of the Divome Code: by Plaintiff: September 9, 2003; by Defendant: September 9, 2003. (b)( 1 ) Date of execution of the affidavit required by § 3301 (d) of the Divome Code: (2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related clam pending: NONE 5. (Complete either (a) or (b).) (a) Date and manner of service of thc notice of intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date PlaintifFs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice fin § 3301 (c) Divome was filed with the Prothonotary: On or about September 25, 2003. 3964 Lexington Street Harrisburg, PA 17109 (717) 651-9100 Attorney for Pla'mtiff Defendant Date: 09/24/03 IN THE COURT OF CUMBERLAND OF COMMON COUNTY STATE OF ~ PENNA. PLEAS ... RUSSELL.,~.._NU~TER Versus ...... KAR~.~,..NU~TB.~ ......................... DECREE IN DIVORCE .............. ,.J~L~... .... it is ordered and decreed that ....... .~.u.s.s..~.L.~..,g,..Nu. TT.~A ...................... plaintiff, and ........KAREN. ~.,. NU.TTER ................................ 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 Attest: Prothonotary