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HomeMy WebLinkAbout03-2934\~ERVER\SharedDocs\Word Processing\domestic\hal~.div complaint &notice. June03.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA Cheryl J HALL, John W HALL, Plaintiff Defendant CIVIL ACTION- DIVORCE No. 2003- ~3~ 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 within twenty (20) days after this Complaint and Notice are served. 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A Fist of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013, 717.240.6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISIONOF 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 717.249.3166 800.990.9108 \~SERVER\SharedDocs\Word Processing\domestic\hall.div complaint & notice.June03.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA Cheryl J HALL, John W HALL, Plaintiff Defendant CIVIL ACTION No. 2003 - DIVORCE COMPLAINT Plaintiff is Cheryl J HALL, who currently resides at 122 Timber Lane, Shippensburg, Pennsylvania, since June 2002. Defendant is John W HALL, who currently resides at 654 Walnut Bottom Road, Shippensburg, Southampton Township, Cumberland County, Pennsylvania, since August 1997. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on April 30, 1983 at Shippensburg, Cumberland County, Pennsylvania. \kSERVER\SharedDocs\Word Processing\domestic\hall.div complaint &notice. June03.doc There have been no prior actions of divorce or for annulment between the parties except NONE. 6. The marriage is irretrievably broken. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Fore's, Esqulre Atty I.D.# 18064 137 Park Place West Shippensburg, PA 17257 Phone 717. 532.9046 Fax 717.532.8879 e-mail fnmyers@earthlink.net \%ERVER\$haredDocs\Word Processing\domestic\hall.div complaint & notice.]une03.cloc I verify that the statements made in this Complaint are true and correct. ~ understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904, relating to unsworn falsification to authorities. Cheryl JfHALL, Plaintiff F:\Word Processing\domestic\ha[Lacl~t of svc.June03.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA Cheryl J HALL, John W HALL, Plaintiff Defendant CIVIL ACTION - No. 2003 - 2934 DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint under Section §3301(c) of the Divorce Code. Date: Johr~V HALL 654 Walnut Bottom Road Shippensburg PA 17257 \~SERVER~SharedDocs\Word Processing\domestic~hall.aff of consent. Sept03.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA Cheryl J HALL, John W HALL, Plaintiff Defendant CIVIL ACTION - No. 2003-2934 DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the E)ivorce Code was filed on June 23, 2003. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. Date: September ~.-~, 2003 Cheryl J H/('LL, 151ai~tiff \kSERVER\SharedDocs\Word Processing\domestic~hall,waiver of noticet. Sept03.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA Cheryl J HALL, John W HALL, : CIVIL ACTION - Plaintiff : : No. 2003 - 2934 : Defendant : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE. I consent to the entry of a final decree of divorce without notice. 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 statement 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:September ~_,2003 (~c/U. ~ ~/~,/~'~ Cheryl J HAL4_, Plaintiff \~SERVER\SharedDocs\Word Processi~g\domestic\hall.aff of consent. SeptO3.doc IN THE COURT OF COMMON PILEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY- PENNSYLVANIA Cheryl J HALL, John W HALL, Plaintiff Defendant CIVIL ACTION - No. 2003 - 2934 DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on June 23, 2003. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. Date: September ,~,.~, 2003 J~ W-HALL, Defendant \~SERVER\SharedDocs\Word Processing\domestic\gall.waiver of noticet. Sept03.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA Cheryl J HALL, John W HALL, Plaintiff Defendant CIVIL ACTION - No. 2003 -2934 DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF. I consent to the entry of a final decree of divorce without notice. 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 statement 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: September z~c~, 2003 HALL, Defendant IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA Cheryl J HALL, John W HALL, Plaintiff Defendant CIVIL ACTION - No. 2003 - 2934 DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD 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. Date and manner of service of the complaint: June 24, 2003 Acceptance of Service by Defendant Date of execution of the affidavit of consent required by §3302(c) of the Divorce Code: by Plaintiff September 23, 2003; by the Defendant September 25, 2003. 4. Related claims pending: None Date plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: October ~, 2003; Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with Prothonotary: October 3.~, 2003. the IN THE COURT OF COMMON PLEAS STATE Of Ch~ry] ,l' ~4AT,T,, Plaintiff OF CUMBERLAND COUNTY PENNA. VERSUS John W HALL, Defendant NO._ 2003 - 2934 DECREE IN DIVORCE AND NOW, DECREED THAT AND October !& Cheryl ,T HALT, John W HALL ARE DIVORCED FROM THE BONDS OF MATRIMONY. , J~_, IT IS ORDERED AND , PLAINTIFF, __, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOi[-OWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A F]NAL ORDER HAS NOT YEt BEEN ENTERED; None BY THE COURT: