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Home My WebLink About99-01350 'SCOTT A. CAWTHERN, Plaintiff IN TilE COURT OF COMMON PLEAS Or' CUMBERLAND COUNTY, PENNSYLVANIA v NO. 99-1350 CIVIL TERM KRISTYN L. CAWTHERN, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE OF 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 Section 3301(d) of the Divorce Code. 2. Date a. b. c. of filing and manner of service of the complaint: Date of filing of Complaint: March 6, 1999 Manner of service of Complaint: personal acceptance Date of Service of Complaint: June 6, 1999 of service 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a. Plaintiff: N/A b. Defendant: N/A OR Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code and date of service of the Plaintiff's 3301 (d) affidavit upon the Defendant: a. Date of execution: b. Date of filing: c. Date of service: January 23, January 31, February 7, 2001 2001 2001 4. Related claims pending: None 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) (1) (i) of the Divorce Code: a. Date of Service: February 28, 2001 b. Manner of Service: u.S. Mail Date Waiver of Prothonotary: a. Plaintiff's b. Defendant's Notice in OR Section 3301 (c) Divorce was filed with the Waiver: N/A Waiver: N/A RADCLIFF, ESQUIRE c-?448 Tri Ie Road -Camp . ,PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 ..- ...-. .~.- >- ,,- ~ c:; -" ... 1- en .." luR (')$ Vt-, 2= ~") L; , ''l; ,!.- -.r 1"12 ~~)( , . ) cr, ':"cn ::'-'7: I -~z ~-; L '-, r....:: . "'- .~Jt.u .0. c... -::'1n. ... ,- -= ". N ::1 c' 0 t,) . .. DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA J701l (717) 737.0100 --. ", .,.........-..... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT A. CAWTHERN, Plaintiff v. NO. 99-1350 CIVIL TERM CIVIL ACTION - LAW DIVORCE KRISTYN L. CAWTHERN, Defendant COUN'l'ER-AFFIDAVIT UNDER SECTION 3301Cdl OF THE DIVORCE CODE 1. Check either (a) or (b): [1 (a) I do not oppose the entry of a divorce decree. [] (b) I oppose the entry of a divorce decree because Check (i), (ii) or both: [ 1 (i) The parties to this action have not lived separate and apart for a period of at least two years. The marriage is not irretrievably broken. [ 1 (ii) 2. Check either (a) or (b): [ 1 (a) I do not wish to make any claims for economic relief. 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 wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. [ 1 (b) I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: Detendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA 17011 17171737.0100 IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT A. CAWTHERN, Plaintiff v. NO. tJ q - /3 '.ro C~ I u..--- CIVIL ACTION - LAW DIVORCE KRISTYN L. CAWTHERN, Defendant DIVORCE COMPLAINT AND NOW, this g+-- day of T4A)) ~, 1999, comes the Plaintiff, SCOTT A. CAWTHERN, by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT II DIVORCR 1. The Plaintiff is SCOTT A. CAWTHERN, an adult individual residing at 506 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. 2. The Defendant is KRISTYN L. CAWTHERN, an adult individual residing at 229 Shauffnertown Road, New Cumberland, York County, Pennsylvania. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 27, 1988 at New Cumberland, Cumberland County, Pennsylvania and separated on January 9, 1999. 5. There have been no prior actions of divorce or annulment between the parties. - 2- 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties have been living separate and apart since January 9, 1999, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. Or in the alternative, c. That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render condition intolerable and life burdensome, and that this action is not collusive. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. 9. COUNT II: EOUITABLE DISTRIBt~ION Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. Plai.ntiff and Defendant have acquired property and debts, both 10. DIANE G. RADCLIFF 3448 TRINDlE ROAD CAMP Hill. PA 17011 (717) 737.0100 - 3 - VERIFICATION SCOTT A. CAW'I'HERN verifies that the statements made in this Complaint are true and correct. SCOTT A. CAWTHERN understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~.qAW~~ OIANE G. RADCLIFF 3448 TRINOlE ROAD CAMP Hill, PA 17011 1717) 737.0100 - 5 - .~ , ?: r:-~ -, 1"... .;..: .., ., , ..' . .' --' . :.':.. , - , ~~ 0' {~1 ''" ~:: ..;...: . tLU -- :) l"," , , ~~ '.:' .=:> U ".. .J' ,.- '"" t:; , , :;:'J :.') .' .n)::'; ..J:'.-. 1.:'- ) :~ , .. , en In (....1 , ~~ C'~ ,- .:tw ." .'0.. - ,'. , , :::> . (::,l u \" ' .. .roll \ . .... IN THE COURT OF COMMON PLEAS Or' CUMBERLAND COUNTY, PENNSYLVANIA SCOTT A. CAWTHERN, Plaintiff V. NO. 99-1350 CIVIL TERM CIVIL ACTION . LAW IN DIVORCE KRISTYN L. CAWTHERN, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 6, 1999. 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, which service was made on the Defendant on June 6, 1999 by Acceptance of Service. 3. I consent to the entry of a final Decree in 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. Section 4904 relating to unsworn falsification to authorities. Dated: lol(~ 11~ { ~.qA~ DIANE G. RADCLiff 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737'{)!1IO ~ "',., .. N ~: ~ .. '< l.LI~: - , _I ~- !,]' .~ l.!...f-;' (J.. Ci~ ;~ , '. -'{- co") 0" I 2 ~ WI!' O:l: s: ::rj .. l.l. ,- .-. :j ll.. en 0 tf' ,:..) ~ UJ ~ I- N ~~ ~JQ l )",:. } ~ [1: ~. Cj~: , . ' (l;~.' . C'!; . ,"') I ,~I. .. .. ~ - . 0, F c: :...j :;;,: .,.- " G. C' '-" '....:> ~ "I "- (-- - -, -, :5..,'f' .- 0 I~) :..~; IJ.J_ - <; ;! . () ::!: . Ci: ", :::J -. "'- (;..: , 'om tc: ; '" ":'':' 'c~~ , ~~j!:O ~. . at:: ~~a... ,- -J U ::J (j 0 () ". .:~ I . .. (-- , v...: ) ;.- - .. ( .- . ~-! :.:i .. ,~ , -. , . j ::.1 , ..- -, , m :::.5 '. (j'. :-' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 99-1350 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE , I r r l SCOTT A. CAWTHERN, Plaintiff Q\~w( ~ KRISTYN L. CAWTHERN, Defendant I, .eCJ.A/I.P AlFIDAVI'1' )(J./, Iz.l'f/..- OF SERVICE , being duly sworn or affirmed according to law, deposes and says: 1. I am over 18 years of age. 2. I am not related to either party to this action. 3. I served a true and correct copy of the Complaint in Divorce upon the Defendant, Kristyn L. Cawthern, by personally handing the same to the Defendant on the ~O day of j""'....(; , 1999 at her place of residence located at 678 Market Street, Lemoyne, Pennsylvania. Sworn to and subscribed before me a Notary Public in and for Cumberland county,~nnSY1Vania a this I Sr- day of l.It ,1994-' ~~~ DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717)737.0100 NOTARIAL SEAL LOUIS J. LORE, NoI8IY Public \ Camp Hili, Currberland County My Commission expires Aprl114, 2003 . SCOTT A. CAWTHERN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-1350 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE KRISTYN L. CAWTHERN, Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the 3301(d) Notice of Intent and Counter-Affidavit has been served upon the Defendant by Regular United States Mail on the 28th day of February, 2001. A copy of the transmittal letter is attached hereto as Exhibit "AU and made a part hereof. , dIe Road , P A 170n 17) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff . . ,.. ... , . ( I, .J -.-' I"~' .- '- ) .... - ~la~ g "'< <~..!:l~ P;: )0 'g...: . JIll:::: e" iri "':C ~ p-oo Q., ZJ;;tE :s< 8 o - .. ,- ?:: ,~ - ~.~ t:..: j ..- U.J~) ~) - $,] ~ . , 1-:- -- ::-j (')' ':-. J~, : C', 'If) ,- '. '1;'-:::' I.!,; % -" , r-:- i c:: tu " ll..... .! CoO ~ I.L C'> ~;, U '" G r O' -- t~ C': [-- -L ,- r~ ~ .') " ,"\ t' I :..l ~ , '. J ~'" l l. E: , ".-l~':! C) c'" "-0 . ~,,~ 1/. 7;~) ~ " :j iu c =~.~ ~:~ d.. \:: I m ~j ,.:; Co... 0 SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.10 (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAl, SECURITY NUMBERS. I'LI::ASE FILL IN THE APPkoPIUATE INr'ORMATION AND RETURN TO TilE PROTIIONOTARY'S OFFICE. DATE April 1, 2002 DOCKET NUMBER 99-1350 PLAINTIFF'S NANE Scott A. Cawthern PLAINTIFF'S SS # 202-42-6211 DEFENDANT'S NAME Kristyn L. Cawthern DEFENDANT'S SS# 174-58-8438