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HomeMy WebLinkAbout03-2579SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. {~)3--2s79 IN DIVORCE A.V.M. NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, if you wish to defend against the claims set forth in the follow/ng 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 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 Court Administrator j , udge s Chambers Cumberland County Courthouse Carlisle, Pennsylvania 17013-3387 Telephone No. 717-240_6200 SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. 1N DIVORCE A.V.M. NOTICE OF RIGHT TO MARRIAGE COUNSELING YOU ARE HEREBy NOTIFIED THAT AS A PARTY NAMED IN THE ABOVE- CAPTIONED DIVORCE ACTION, MARRIAGE COUNSELING IS AVAILABLE TO YOU AND YOUR SPOUSE, AND UPON REQUEST, THE DOMESTIC RELATIONS OFFICE WILL PROVIDE YOU WITH A LIST OF QUALIFIED PROFFESSIONALS WHO WILL PROVIDE SUCH SERVICES. YOU HAVE THE RIGHT TO REQUEST THE COURT TO ORDER COUNSELING FOR BOTH YOU AND YOUR SPOUSE. IF YOU DESIRE A LIST OF QUALIFIED PROFFESSIONALS AND/OR DESIRE THE COURT TO ORDER COUNSELING, YOU SHOULD CONTACT YOUR ATTORNEY OR: Cumber/and County Court Administrator Judge's Chambers Cumberland County Courthouse Carlisle, Pennsylvania 17013-3387 Telephone No. 717-240-6200 SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY IN DIVORCE A.V.M. COMPLAINT COUNT ONE- DIVORCE UNDER SECTION 3301(c) OF DIVORCE CODE I. Plaintiff is Suzanne E. Sutton, a citizen of the United States of America, who currently resides at 6 Gregory Avenue, Selinsgrove, Snyder County, Pennsylvania, since April of 2003. 2. Defendant is George R. Sutton, II, a citizen of the United States of America, who currently at 1045 Ashton Avenue, Beverly, New Jersey, since April of 2003. 3. The parties lived together at 87R Autumn Lane, Enola, Cumberland County, Pennsylvania, for over a year prior to April of 2003. 4. Plaintiff and Defendant have been bona fide residents tn the Commonwealth of Pennsylvania for at least 6 months immediately previous to the filing of this Complaint. 5. Plaintiff and Defendant were married on August 22, 1998, in Mt. Holly Springs, Pennsylvania. 6. There were no children born of the parties' marriage. 7. There have been no prior actions of divorce between the parties. 8. The marriage between the Plaintiff and Defendant is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and of her right to request the Court to require the parties to participate in counseling. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Attorney for Plain.tiff 503 North Market Street Selinsgrove, Pennsylvania 17870 Telephone: (570)374 - 5070 Date: May_/ri _, 2003 VERIFICATION I, Suzanne E. Sutton, 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. § 4904, relating to unsworn falsification to authorities. Suzanne E. Sutton Date: _, 2003 VERIFICATION I, Suzanne E. Sutton, 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. Date: ,2003 SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. oa - 0257? IN DIVORCE A.V.M. PRECIPE FOR APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTy, PENNSYLVANIA: Please enter my appearance as counsel for the Plaintiff, Suzanne E. Sutton, in the above- captioned case. Robert M. Cravitz, Esquire Attorney No. 32289 Attorney for Plaintiff' 503 North Market Street Selinsgrove, Pennsylvania 17870 Telephone: (570) 374 - 5070 Date: May 16, 2003 SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NC). 03-2579 Civil Term IN DIVORCE A.V.M. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF SNYDER Monica L. Kline, an employee of Robert M. Cravitz, being duly sworn according to law, deposes and says that a true and correct copy of the Complaint In Divorce which was filed in the above captioned case was served on, George R. Sutton, II, Defendant, by Certified Mail, return receipt requested, restricted delivery, on June 7, 2003. The Domestic Return Receipt, marked Exhibit "A", is attached hereto and incorporated herein by this reference. on~a L. Kline, Employee of Robert M. Cravitz, Attorney for Plaintiff Sworn To And Subscribed Before Me This G~43~x Day of ~:Uo'tx-t-- ,2003. My Commission Expires: Notary Public · Complete items 1, 2, and 3. Aisc complete item 4 if Restricted Delivery is desired. · Pdnt 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: George R. Sutton, II 1045 Ashton avenue Beverly, NJ 08010 A. Received by (Pl~tse Print C/early) C. Signature [] Yes r delivery address below: [-] No 2. Article Number (Copy from service label) PS Form 3811, July 1999 3. Service Type r~ Certified Mail ~ Express Mail I-I Registered [] Return Receipt for Merchandise [~ Insured Mail E] C.O.D. 4. Restricted Delivery? (Extra Fee) ~ Yes 7001 1940 0001 2223 1942 Domestic Return Receipt 102595-99-M.1789 SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. 03-2579 CivilTerm IN DIVORCE A.V.M. AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 3, 2003. 2. The marriage of Plaintiff and Defendant is irretriew~bly broken and 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 divome 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 tree 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. SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE', 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. 03-2579 CivilTerm ][Iq DIVORCE A.V.M. 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 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 decree 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 divorce 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. § 4904 relating to unsworn falsification to authorities. Date f/f ,2003 SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. 03-2579 Civil Term IN DIVORCE A.V.M. AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 3, 2003. 2. The marriage of Plaintiff and Defendant is irretriew,bly broken and 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. 4. I understand that I may lose rights concerning alimc,ny, 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 false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ,2003 George~, Sutton, II, Defendant SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE; 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. 03-2579 Civil Term IN DIVORCE A.V.M. 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 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 decree is granted. 3. I understand that I will not be divomed until a divorce decree is entered by the Court and that a copy of the divorce 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. Date ,2003 SUZANNE E. SUTTON, Plaintiff VS. GEORGE R. SUTTON, II, Defendant COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY NO. 03-2579 Civil Term 1N DIVORCE A.V.M. PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please transmit the record, together with the following information, to the Court for entry ora divorce decree: 1. Ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of Complaint was June 7, 2003, by Certified Mail, return receipt requested, restricted delivery. 3. Date of execution of the PlaintilTs Affidavit Of Consent required by Section 3301(c) of the Divorce Code was September 19, 2003. 4. Date of execution of the Defendant's Affidavit Of Consent required by Section 3301 (c) of the Divorce Code was September 16, 2003. 5. There are no related claims pending. 6. The parties' Waivers Of Notice Of Intention To Request Entry OrA Divorce Decree Under Section 3301 (c) of the Divorce Code were filed on September 24, 2003. IN THE COURT OF COMMON PLEAS Susanne E. OF CUMBERLAND COUNTY STATE OF ,p~ PENNA. Sutton Plaintiff NO. 03-25?9 Civil George R. VERSUS Sutton, II Defendant DECREE IN DIVORCE AND NOW, /~ ¢..,-'~ I DECREED THAT Susanne E. Sutton Z~, IT IS ORDERED AND , PLAINTIFF, AND George R. Sutton, II ,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; namely the Equitable distribution of the parties' Marital property, Alimony & Attorney's fees and Expenses. BY THE COURT: ATT T:~ ~1~ ~ . ROTHONOTA 1N THE COURT )F COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Notice is been granted a Fi~ hereby elects to re and g!ves this writ DATE: / \ - COMMONWEALT COUNTY OF CUM On the Notary Public, persc is subscr/bed to the purpose therein con' In Witness ¥ CWIL ACTION - LAW Plaintiff: · Pn E so. O5- 2S?q IN DWORCE : % .." Defendant: NOTICE TO RESUME PRIOR SUP~NAME .'reby given that the Plaintiff/Defendant in the above matter, having .1 Decree in Divorce on the I day of (") CS-O ~r~e C' , ume the prior surname of ~ O Z_ o.r'~c'x, e._ m notice pursuant to the provisions of 54 P.S. 704. - ' \ Signature Signature 6f name being resumed [ OF PENNSYLVANIA : : SS. IERLAND : ~ day of ~X~o~.e~qk~- , 2003, before me, a tally appeared the above affiant known to me to be the person whose name ithin document and acknowledged that he/she executed the foregoing for the med. hereof, I have hereunto set my hand and official seal. Notary Public NOTARIAL SEAL C~ f',Obi~ A BREWSAKER, NOTARY PUBLIC Carlisle Boro. Cumberland County t,,:; Commission Expires April 4, 2005 ©