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HomeMy WebLinkAbout01-04235i IN THE COURT OF COMMON PLEAS NEIL P. SUNDAY VERSUS AMI M. HAND-SUNDAY N O. 01-4235 Civil Term DEGREE IN DIVORCE AND NOW, ~`~~-" ' l~ ~' ~; y 9 ~'.,M . 2001 , IT IS ORDERED AND DECREED THAT NEIL P. SUNDAY ,PLAINTIFF, AND AMI M. HAND-SUNDAY -,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 ATTEST: J. PROTHONOTARY ..d...~,~,cr .. _ _ i : _ _ _ ... .... .,_. ,~.~._,n... I ~.. YYw :m.:etr.:~sxs ~ai7xxa,mw,vnra.o- ~~w ~ 111/S ~a i - '~ . rte, ~". c.,.~P'uQ, ~o- ~Ca~~~ , ~e*~t'r Ud" ~f ~~ 1 I /!Sloe - 'n°~°' .rr~~ __ d"~<~c~^'~ '°"'""~"- d' 03 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEIL P. SUNDAY Plaintiff No. 01-4235 Civil Term vs. AMI M. HAND-SUNDAY Defendant In Divorce- §3301(c) PRAECIPE TO TRANS1bIIT 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 §(3301(c) of the Divorce Code 2. Date and manner of service of the complaint: Julv 13, 2001, by Acceptance of Service. 3. Date of execution of affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff October 12, 2001 by Defendant October 12, 2001 4. Related claims pending: None. All claims settled by written agreement between the Plaintiff and Defendant 5. Date Plaintiffs Waver of Notice in S(3301(c) Divorce was filed with the Prothonotary October 18, 2001 Date Defendant's Waver of Notice in S(3301(c) Divorce was filed with the Prothonotary October 18, 2001 -~ ~ ~ '! _ -L: Cv O Z~~~ '°F ~- __ n _ ~ ;-, ~,-_ .. ~ ~.Ca (] N _~ '- I'i =i R1 ~ G c 3 ~~s c~ „_ wrn-x= ns ~s-rna~~x a r .~+vru¢. +..awn~*v±;. s. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEIL P. SUNDAY vs. Plaintiff CIVIL ACTION -LAW NO. C91 - ~l~$ CIVIL TERM AMI M. HAND-SUNDAY Defendant 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 foregoing 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 annuhnent maybe 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 also 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania, 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUI~TSEL FEES OR E.YI'ENSES BEFORE THE i'INAL DEC:2EE OF DIVGRCE GR 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 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEIL P. SUNDAY vs. AMI M. HAND-SUNDAY Plaintiff CIVIL ACTION -LAW NO. CIVII, TERM Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEIL P. SUNDAY CIVIL ACTION -LAW Plaintiff CIVIL TERM AMI M. HAND-SUNDAY Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, NEIL P. SUNDAY, by his attorneys, Blakey, Yost, Bupp & Hershner, LLP, and seeks to obtain a Decree in Divorce from the above-named Defendant. 1. Plaintiff is Neil P. Sunday, who currently resides at 119 7~' Street, New Cumberland, Cumberland County, Pennsylvania 17070, having resided there since 1999. 2. Defendant is Ami M. Hand-Sunday, who cun•ently resides at 6163 Spring Knoll Drive, Harrisburg, Dauphin County, Pennsylvania, having resided there since February 2001. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 3, 1998 in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests your Honorable Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests your Honorable Court to grant the relief requested. BLAKEY, YOST, BUPP & HERSHNER, LLP By Per~j(y V. Ayers, sc(uir~ S. Ct. I.D. #847 1 Attorney for Plaintiff 17 East Market Street York, PA 17401 Telephone (717) 845-3674 VERIFICATION I verify that the statements made in the foregoing Complaint 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. .~ v eil P. Sunday Dated: .rte ~..,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NE1L P. SUNDAY CIVIL ACTION -LAW Plaintiff n vs. NO. (51- ~{,Zc3S l;[CUC, CIVIL TERM AMI M. HAND-SUNDAY Defendant IN DPJORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint. ~--VC\ V~~/ XI 111 ~ ~l~ Q n/ Ami I-Pand=SundayU 6163 Spring Knoll Drive Harrisburg, PA 17111-6805 Dated: __ ~~ ~„ssv-~xk ~a=ayrvpn=~!m~'.. mot IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NEIL P. SCINDAY NO. 01-4235 Plaintiff vs. CIVIL TERM AMI M. HAND-SUNDAY IN DIVORCE Defendant A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 11, 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 initial 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. 4. 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. 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. §4904 relating to unswom falsification to authorities. Date: Wernher 12, 2nm ~ ~ ~l . r" :.1 ': i ~ ~L:' T ~ el - ~['` .__ _ VJ ~' -Ki` (7J ~, r' C= ;'-~ , , , r ~C c ~ ~~ tV r cS a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANTIA CIVIL ACTION -LAW NEII, P. SUNDAY NO. 01-4235 Plaintiff vs. CIVIL TERM AMI M. HAND-SUNDAY IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~'I301 (~ nF THF.11iVnRrF, C 1111F, 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. 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. Section 4904 relating to unswom falsification to authorities. bate: (lctnher 12, 2001 t'3 0 _, C ~ ,. c_, zA ~ T ~° ~ ~ - ft ~+ ---t -_ ~~:- ~ - v>>~ ~ ~_ c,:a K=C7 _• ~ G ~ w7 h7 f~, Q . .._... _,... __...... ~~ , -: ~ - ... - dcn 3 -acioy~iva ;nw-a~eru `!.'fi,~+nN~tie~4aMrsH~u. _ ,..., .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NEIL P. SUNDAY vs. AMI M. HAND-SUNDAY July 11, 2001. 2. Plaintiff Defendant NO. 01-4235 CIVIL TERM IN DIVORCE 4F'FY~Ai%T'Y' fyi! ('(iNCF;~i'1' A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the initial Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. 4. 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. I verify that the statements made in this affidavit aze 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: Wernher 12, 2001 Ami NI. Hand- day {j ~' L ) ~. ._.. _ -'.! I .~ _ ~[ __ r.~' ~ Wit. " _ `~1{"V~' ~ ~„Y 1... 1.,+-~ . ^ 7 r r ~'l ~~''r~S \~ . ~gnren¢n~xvssxrsnr ^w~x~;as~F=~~ew~eu?I.a~#~[3M~3A~'.~F~S"Rk Ht¢ ..._ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NEIL P. SUNDAY vs. AMI M. HAND-SUNDAY 1. 2. Plaintiff Defendant NO. 01-4235 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF` INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §,ii01 ~ nF THF, DIVnR( F, C',nT/F I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of properly, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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. Section 4904 relating to unsworn falsification to authorities. Date: nctnher 12,20(11 Ami . H d-S y :~~ ~ ~~; ~~ C _- -.. v c~ :-~ - ~ m r ~; - . Z ;~. ' L r-` ~ __: L ~_: -C, f: ~~o of ~_ ~'~ ~ •~ _ ~ ~ C> SOC7Ai • SECURITY INFOR1vIATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FII.L Ii I THE APPROPRIATE INFOR1bIATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: October 16. 2001 DOCKET NUMBER: 01-4235 Civil Term PLAIV"PIFF/PETTTIONER SS# 17 5- 6 4- 7 3 8 4 NAME: Neil P. Sunday DEFENDAi~IT/RESPONDENTSS~ 172-70-3465 NAME: Ami M. Hand-Sund IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N ~L ~- ~uN`~A~ Plaintiff ~I ~ ~~2~ . File No. J vs. IN DIVORCE Defendant . NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the ~''~~ day of N~~~~° _Z(,Z`j~ hereby- elects to resu me the prior surname of ~-~j~ and gives this written notice pursuant to the provisions of 54 P.S. § 704. DATE • (i~ D~ • ~- - Sign t re /L~~' Sign ure of n me being resumed ~ K, a l•/Atid COMMONWEALTH OF PENNSYLVANIA- Dau in) Ss. COUNTY OF EUMi _ On the d,~~r` day of ~aNUar c~©Q a„ before me, a 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/she executed the foregoing for the purpose therein contained. seal. In Witness Whereof, I have hereunto set my hand and official ary Pu lic PutrHc County r 7.2005 ~~ © ~a ~ ti < <, n,! .cs rC .,~ r: ~ fP 7 `ry ~ f'C ~ '~ r ~1 ~ -~' . ~_ ~- - r -~ r,, ~- ~- ~ ~ ~ ~~ ~ ~~