HomeMy WebLinkAbout01-05356IN THE COURT OF' COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF °~ PENNA.
AMY D. ANDERSON,
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N O. 01 5336 CIVIL TERM
Plaintiff
VERSUS
GEORGE P. ANDERSON.
Defendant
DECREE IN
DIVORCE
DECREED THAT AMY D. ANDERSON
AND NOW, 1 k 4~`\y M~ ` ~ , ~~Q IT IS ORDERED AND
GEORGE P. ANDERSON
PLAINTIFF,
AND
,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 TH~nE COURT:
VY
ATTEST: J
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PROTHONOTARY
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AMY D. ANDERSON
vs.
GEORGE P. ANDERSON
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
No. 01-5356 CIVIL TERM
Defendant CIVIL ACTION -LAW IN DIVORCE
PRAECH'E TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
Grounds for Divorce: Irretrievable breakdown under Section 3301(c).
2.
3.
4.
Complete either Paragraph (a) or (b):
(a) Date of executiou of the Affidavit of Consent required by Section 3301(c) of
the Divorce Code: By Plaintiff June 8, 2005 ; By Defendant: Mav 18, 2005.
(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the
Divorce Code: N/A (2) Date of filing and service of the Plaintiffs Affidauit
upon the Respondent: N/A.
Related claims, pending:
No related claims are nendin~ with this Honorable Court.
Date and manner of service of the Complaint:
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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 Section 3301(c) Divorce was filed with
the Prothonotary: June 14, 2005; Date Defendant's Waiver of Notice in
Section 3301(c) Divorce was filed with the Prothonotary: June 8, 2005.
Respectfully Submitted,
WILEY, LENOX, COLGAN &
MARZZACCO, P,C.
Date: ~~ab ~~ By:
Timothy J. Co ire
Supreme Court LD. #77944
130 West Church Street, Suite 100
Dillsburg, PA 17019
(717) 432-9666
(Attorney for Plaintiff)
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AMY D. ANDERSON
vs.
GEORGE P. ANDERSON
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
No. Ul - 535, ~ic>c~,~~./z»-~
Defendant CIVIL ACTION -- LAW
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.
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 YORK COUNTY COURTHOUSE, 28 EAST MARKET STREET,
YORK, PA 17401.
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. ~
Court Administrator
Cumberland County Courthouse
3 S. Hanover Street
Carlisle, PA 17013
Telephone: (717) 697-0371
AMY D. ANDERSON
vs.
GEORGE P. ANDERSON
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff ~} c~,.~
Defendant CIVIL ACTION -- LAW J
COMPLAINT IN DIVORCE
COUNTI
1. The plaintiff is Amy D. Anderson, who currently resides at 6 Holly Road, Marysville,
Pennsylvania since July 2001.
2. The defendant is George P. Anderson who currently resides at 6028 Hummingbird Drive,
Mechanicsburg, Pennsylvania since April 1996.
3. There are two minor children of the parties: George P. Anderson, Jr., dob 8/18/96 and Devin W.
Anderson, dob 9/12/97.
4. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
5. The Plaintiff and Defendant were married February 14, 1998 at Mechanicsburg, Cumberland
County, Pennsylvania.
6. There have been no prior actions of divorce or annulment between the parties.
7. Neither party is presently a member of the Armed Forces on active duty.
8. The parties have not entered into a written agreement as to alimony, counsel fees, costs, and
property division.
9. 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. Being so advised, Plaintiff does not
request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued
by the Court.
lO.The cause of action and section of the Divorce Code under which Plaintiff is proceeding is
§3301(c). The marriage of the parties is irretrievably broken.
11. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiffrequeststhe Court enter an Order dissolving the marriage between the
Plaintiff and Defendant.
Q Respecly submitted,
Dated: 9 l ~( '~~~
Timothy J. Colg ' e
WILEY, LENOX, COLGAN
& MARZZACCO, P.C.
1 South Baltimore Street
Dillsburg, PA 17019
(717)432-9666
I.D.#77944
VERIFICATION
I, AMY D. ANDERSON, verify that the statements made in this document 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 authorifies.
Date: 7 "'D~~/ \
Y ANDERS
Plaintiff
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AMY D. ANDERSON
vs.
GEORGE P. ANDERSON
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
No. 01-5356 CIVIL TERM
Defendant CIVIL ACTION - LAW IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on September
13, 2001.
2. The marriage of 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
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Date Amy Anderson, Plaintiff
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AMY D. ANDERSON
vs.
GEORGE P. ANDERSON
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
No. 01-5356 CIVIL TERM
Defendant CIVIL ACTION -LAW IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on September
13, 2001.
2. The marriage of 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to
unswom falsification to authorities.
Date George P. erson, Defend t
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AMY D. ANDERSON
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
No. 01-5356 CIVIL-TERM
GEORGE P. ANDERSON
Defendant
CIVIL ACTION - LAW IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
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 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. I understand that false
statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsification to authorities.
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Date Amy Ander on, Plaintiff
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AMY D. ANDERSON
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
No. 01-5356 CIVIL TERM
GEORGEP.ANDERSON
Defendant
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 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 aze true and correct. I understand that false
statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsification to authorities.
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Geor P. derson, Defendant
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AMY D. ANDERSON
vs.
GEORGE P. ANDERSON
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
No. 01-5356 CIVIL TERM
Defendant DIVORCE/CUSTODY
AFFIDAVIT OF SERVICE
I, Michele A. Reneker, being duly sworn, deposes and says that she is an adult and that she served
the within Complaint on the Defendant, at the Defendant's last known address as follows: 6028
Humingbird Drive, Mechanicsburg, PA 17055, by certified mail, restricted delivery, return receipt requested
on the 1 st day of October, 2001. The A copy of the PS form 3 8111 are attached hereto, mazked Exhibit "A"
and made a part hereof by reference thereto.
Date: October 4, 2001 WILEY, LyEyN~ OX~, "COLGAN & MARZZACCO, P.C.
By: // / (~iLe iX 0 66GI/Z
Mickele A. Reneker, Secretary to
Timothy J. Colgan, Esquire
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF
On this, the 4th day of October, 2001, before me, a notary public, personally appeazed Michele A.
Reneker, known to me or satisfactorily proven to be the whose name is subscribed to the within Affidavit and
acknowledged that she executed the same for the purposes therein contained.
WITNESS, my hand and notazial seal the day and year aforesaid.
Notarial Seal NOTARY PU LIC ~~~/®~/$
S. Dawn Gladtetter, Notary Public My Commission Exprres:
DiAsburp eoro, York Cou
My Commission Expires May 1 , 2005
Member, Pennsylvania Association of Notaries
~ -Completeifema 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 Adtlressed to:
Lrnr~'r~e ~ ~ .,;~nMt~r~
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C. Signatu
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L Atldre
D. Is d~ I'very a dress diffe nR from Rem 1? ^ Yes
If VES, enter delivery address below: ^ No
'4 .
'~ ~ Certified-~ I"lv a~i' ^ Express Mail
^ Registered ^ Return Receipt for Merchandise
^ Insuretl Mail ^ C.O.D.
4. Restricted Delivery? (Extra Fee) ~ Yes
2. Article Number (Copy from service label)
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PS Fvml .~' 1 .~ ~ Ju ' . ~ Domestip Retum Recelpt - - 102595-00-M-0852
In The Court of Common Pleas of
Cumberland County, Pennsylvania
File No. 2001-05356
ANDERSON AMY D
vs
ANDERSON GEORGE P
STATEMENT OF INTENTION TO PROCEED
To the Court:
Amy D. Anderson
Date: Q t ~-a~
intends to proceed with the above captioned matter.
Gu-~~
Attorney for plaintiff, Amy D. Anderson