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Home My WebLink About03-2790RICHARD J. HOLMES, Plaintiff LOIS J. HOLMES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : NO. CIVIL TERM : 1N DIVORCE NOTICE TO DEFEND 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 Cumberland County Court House, High and Hanover Streets, Carlisle, PA. 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, PA 17013 Phone: (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Corm. You must attend the scheduled conference or hearing. RICHARD J. HOLMES, Plaintiff LOIS J. HOLMES, Defendant : CIVIL ACTION - LAW : NO. CIVIL TERM : 1N DIVORCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA o$.a7~o COMPLAINT UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Richard J. Holmes, who currently resides at 1411 Creek Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant is Lois J. Holmes, who currently resides at 1411 Creek Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiffand Defendant were married in January 24,1981, in Boiling Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available, and that Plaintiffhas the right to request that the Court require the parties to participate in counseling. 8. Plaintiffrequests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & BAYLEY 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Plaintiff VERIFICATION I verify that the statements in this Complaint are tree and correct. ! understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Holmes, Plaintiff RICHARD J. HOLMES, : Plaintiff : LOIS J. HOLMES, : Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 03-2790 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301(c) of the Divorce Code was filed on June 13, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 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. Date: Richard J. l~lmes / Plaintiff RICHARD J. HOLMES, : Plaintiff : LOIS J. HOLMES, : Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 03-2790 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 13, 2003. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. § 4904, relating to unsworn falsification to authorities. Richard J. l~61mes / Plaintiff RICHARD J. HOLMES, Plaintiff vii. LOIS J. HOLMES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 03-2790 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divome Code was filed on June 13, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry ora final decree of divorce after service of notice of intention to request entry, of the decree. l 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: /ojoalo3 ~,L/ois. t/' ' / ois J. Hohnes / Defendant RICHARD J. HOLMES, Plaintiff vi. LOIS J. HOLMES, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 03-2790 1N DIVORCE 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 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 herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. I~ichard 'J~tZ~olmes / Plaintiff RICHARD J. HOLMES, Plaintiff viii· 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 03-2790 LOIS J. HOLMES, Defendant IN DIVORCE 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 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 herein are made subject to the penalties of 18 Pa. C.S. {}4904, relating to unsworn falsification to authorities. Date: Eois J. H'61mes / Defendant RICHARD J. HOLMES, Plaintiff LOIS J. HOLMES, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Lois J. Holmes, in the above-captioned action and I certify that I am authorized to do so. Date: By: '17 LOIS J.~HOLMES RICHARD J. HOLMES, Plaintiff LOIS J. HOLMES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 03-2790 IN DIVORCE TO THE PROTHONOTARY: decree: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry ora divome 1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: June 20, 2003, Acceptance of Service signed by Defendant. 3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce Code: by the Plaintiff October 22, 2003; by the Defendant October 22, 2003. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 7, 2003. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 7, 2003. Date: November 7, 2003 ~Mark ayley, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF ~~~ PENNA. Richard J. Holmes VERSUS Lois Jane Holmes N O. 03-2790 DECREE 1N DIVORCE AND NOW, I~o~.~bd {4 , _2_O~, IT IS ORDERED AND DeCrEED ThAT Richard J Holmes , PLAINTIFF, AND Lois Jane Holmes , 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 FINAi ORDER HAS NOT YET BEEN ENTERED; PROTHONOTARY