HomeMy WebLinkAbout01-03547
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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PENNA.
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STATE OF
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KATHY A. DONOVAN,
Plaintiff
No.
2001-3547
VERSUS
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ROBERT P. DONOVAN,
Defendant
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DECREE IN
DIVORCE
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KATHY A. DONOVAN
~', IT IS ORDERED AND
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AND NOW,
PLAINTIFF,
DECREED THAT
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ROBERT P . DONOVAN
, DEFENDANT,
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AND
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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 SEEN ENTERED;
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NONE.
PROTHONOTARY
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KATHY A DONOVAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-3547
CIVIL TERM
ROBERT P. DONOVAN,
Defendant
: CIVIL ACTION - LAW
: 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 S 3301(c) 33€lI(d) of the Divorce
Code. (Strike out inapplicable section).
2. Date and manner of service of the Complaint. Service was made on June 11, 2001 by
an certified, restricted mail signed for by the Defendant.
3. (Complete either paragraph (a), or (b).)
(a) Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce
Code: by the Plaintiff: September 19, 2001; by the Defendant: September 23, 2001.
(b) (I) Date of execution of the Plaintiffs Affidavit required by S 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, and a copy of which is attached:
(b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as
required. by S 3301(c) of the Divorce Code: by the Plaintiff: September 19, 2001; by the
Defendant: September 23, 2001.
Date: September 27,2001
GiJ0JJ
Thomas S. Diehl, Esquire
Attorney for Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001- J'lIJ CIVIL TERM
KATHY A DONOVAN,
Plaintiff
ROBERT P. DONOVAN,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RJIGHTS
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 divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage' counselors is available in the
Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania.
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, Pennsylvania 17013
(717) 249-3166
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v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001- 35'11 CIVIL TERM
KATHY A DONOVAN,
Plaintiff
ROBERT P. DONOVAN,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF
THE DIVORCE CODE
The Plaintiff, Kathy A. Donovan, through her attorney, Thomas S. Diehl, makes the
following Complaint in Divorce, and, in support thereof, avers as follows:
I. The Plaintiff, Kathy A. Donovan, is an adult individual who currently resides at
235 West Willow Street, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant, Robert P. Donovan, is an adult individual who currently resides at
235 West Willow Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Defendant and the Plaintiff have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and the Defendant were married on June 12, 1993 in Charleston,
South Carolina.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Defendant is not a member of the Armed Forces of the United States of
America or its Allies.
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7. The Plaintiff has been advised of the availability of counseling and the right to
request that the Court require the parties to participate in counseling. Knowing this, Plaintiff
does not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
WHEREFORE, the Plaintiff, Kathy A. Donovan, respectfully requests your Honorable
Court to enter a decree in divorce pursuant to 23 P.S. 9 3301(c) or 3301(d) ofthe Divorce Code.
Respectfully submitted,
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Date: 10 G L/ I.
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Thomas S. Diehl
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 - FAX
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VERIFICATION
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. S 4904, relating to
unsworn falsification to authorities.
/~~
KATHY. A. DONOVAN, Plaintiff
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KATHY A DONOVAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-3547
CIVIL TERM
ROBERT P. DONOVAN,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this 12th day of June 2001, comes Thomas S. Diehl, Esquire, Attorney for
the Plaintiff, Kathy A. Donovan, and states that he had cause to be mailed a certified copy of a
Complaint in Divorce to the Defendant, Robert P. Donovan by certified, restricted delivery,
return-receipt requested. A copy of said receipt is attached hereto indicating service was made
on June 11,2001.
submitted,
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Thomas S. Diehl
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 - FAX
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Postage $
cerdned Fee
Return Receipt Fee
(Endorsement RequIred) 13.20
Restricted Dellvery Fee
(Endorsement RequIred) .7.15
Total postage & Fees $
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~ Name (Please Print Clearly) {To be completed by mailer}
1TI SiiHf~J.~~;:~-B.W~QYMJ--_.._-_.._.._-----~-----,,--._-;,~
[I'" 235 WEST WILLOW STREET
~ City. Siiii8:"Ziiii4---.~----_.u~------"",,-~..."'..~~~-_.._-'-""'--_."""_.
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1. Article Addressed to:
ROBERT P. DONOVAN
235 WEST WILLOW STREET
CARLISLE, PA 17013
3. Service Type
D Certified Mail
o Registered
o Insured Mail
o Agent
Dves
D No
r:;J Express Mail
o Return Receipt for Merchandise
DC,Q,D.
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4. Restricted Delivery? (Extra Fee)
2. Article Number (Copy from service label)
7099 3220 0009 5574 0378
PS Form 3811, July 1999
Domestic Return Receipt
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KATHY A DONOVAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-3547
CIVIL TERM
ROBERT P. DONOVAN,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under S3301(c) of the Divorce Code was filed on June 8,
2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of 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. S 4909 relating to unsworn
falsification to authorities.
Date:~/tr~ I
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER ~3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a Final Decree in Divorce 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 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. S 4909 relating to unsworn
:~:"tion ill ootlmriti~ '&blJl. ' I~P Jvu ~
KA . ONOVAN,Pla~ff
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KATHY A DONOVAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-3547
CIVIL TERM
ROBERT P. DONOVAN,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under S3301(c) of the Divorce Code was filed on June 8,
2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of 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. S 4909 relating to unsworn
falsification to authorities.
Date: r -ZS-ZCV(
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER ~3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a Final Decree in Divorce 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 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. S 4909 relating to unsworn
falsification to authorities.
Date: 9 -2.3 -?~/
NOV AN, Defendant
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KATHY A DONOVAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-3547
CIVIL TERM
ROBERT P. DONOVAN,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Not~ce is hereby given that the Plaintiff in the above matter, Kathy A. Donovan, having
,
been granted a Final Decree in Divorce on the 2nd day of October 2001, hereby elects to resume
the prior surname of SIMES and gives this written notice pursuant to the provisions of 54 P.S. S
704.
Date: ~
COMMONWEALTH OF PENNSYL VANIA
SS.
COUNTY OF CUMBERLAND
ilD-rtf (X!...-rof3€/2- .
On the day of , 2001, before me, a Notary Public.
personally appeared the above affiant known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within document and acknowledge that she executed the
foregoing for the purposes therein contained,
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
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Not~ry ~
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NOTARIAL SEAL
SHIRLEY O. DURNIN, Notary Public
Car1i8Ie Boro., Cumberland County
CommieSIon E 'res A . 9, 2003
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