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Home My WebLink About99-02824 •:0 <?? «• <o ....:?:--.:ei :L'? Lo>"te: W. •;o: !o; <e? •:o> •:e> •:o:• <!:• :e:• •;e? to>':• :o:.. .:mac:{o:•:lC£•..:e•. Ste, ?: ,e.. ..:P•:'{4 IN THE COURT OF COMMON FLEAS ••` OF CUMBERLAND COUNTY s o STATE OF PENNA. v s s 6 e J73AI=.L...YOUNG, ...... ..... ..... ...... N l i i P a nt ff c?......... 99-2824 ................. Versus ...... .KOM..R._.YOUNG,... _. e Defendant ti o i DECREE IN DIVORCE AND NOW, ...........N.ovc,,,(, • 3• • 19.!... , it is ordered and Jennifer L. Young• • • ... • • , .. • • • • • • • , . • ...... , plaintiff, decreed that .. . ... and .............. IC4zeY..R, .Xoung ............................. defendant, c are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action fcr which a final order has not yet c been entered; None ..........................................................................• 12y TI c Courl' j, P Aunt: J. ProliunuHary r '. i ...... ............ . .... r. i . _ •iei ti ?? •A:• 'X.• •:o;• •:e;• •:e;• •;e;• •;e;• te: tie;• :ei •Y} ;e;• ?:e:• •:e;• titi :?; -:ei titi ce; titi W. ifi :Si :1? :e:' :ei •:!:• te; ?:e:• JENNIFER L. YOUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 2824 CIVIL TERM KOREY R. YOUNG, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD i 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(c) 5394{d)(3-) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified Mail, Return Receipt, and Acceptance of Service signed by Defendant, Korey R. Young, dated May 17, 1999. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff October 22, 1999; by the Defendant October 18, 1999. (b) 04-Bate-e€-execa' the I iveree Gede• (2) Date of seMGe of the of t•k affidavit 4. Related claims pending: None 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 Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: :?, <•? ,.?;. _. ?,_ ? , ?_ ?, ' i;; ? .? -? , ,.. - ? ?. ?; ' ,, , ? > JENNIFER L. YOUNG, Plaintiff, Vs. KOREY R. YOUNG, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 99 - „ZQ , V CIVIL TERM IN DIVORCE NOTICE YOU HAVE SUED IN COURT. If wish to t the clais set forth in the following pag s, you Nmust take prompt ct on.u You a e warned gthat 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, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PENNSYLVANIA 17013 (717) 249-3166 D4a*7at54l FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: Carol J: L' dsay, Es ire ID # 446 3 11 East High Street Carlisle, PA 17013 (717) 243-5513 JENNIFER L. YOUNG, Plaintiff, VS. KOREY R. YOUNG, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 99 - R ?.?)4 CIVIL TERM IN DIVORCE COMPLAINT Jennifer L. Young, Plaintiff, by attorneys, FLOWER, FLOWER & LINDSAY, P.C., respectfully represents: 1. The Plaintiff is Jennifer L. Young, who currently resides at 379 Locust Point Road, Cumberland County, Mechanicsburg, Pennsylvania, where she has resided since March 8, 1999. 2. The Defendant is Korey R. Young, who currently resides at 18 Carlisle Road, Cumberland County, Newville, Pennsylvania, where he has resided since October, 1997. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 21, 1995, at Cumberland County, New Kingston, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: / C rol J. U dsay, Esquire ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 14-0 Date: lr VERIFICATION I, the undersigned, hereby verify that the statements made herein 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: Z/ a6Z99 7, C7" ? ` E_: 1 ? - .' • .) , -? ? _ ?. ? ? . (_I. )?. ? . f?-?- L: ::??..; ??- c? - ?-? c?+ ?.:I-- - ? -'r "-'_ 1 - (? .iii? : r,_ ? C? t JN (.7 ?. , r JENNIFER L. YOUNG, KOREY R. YOUNG, VS. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 2824 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND now, this day of 1999, I, CAROL J. LINDSAY, Esquire, of the law firm of FLOWER, FLOWER & LINDSAY, Attorneys, hereby certify that I served the Defendant, KOREY R. YOUNG, on May 17, 1999 with the Complaint in Divorce by Certified Mail, Return Receipt Requested, Restricted Delivery, Addressee Only, addressed to: Korey R. Young 18 Carlisle Road Newville, PA 17241 and proof thereof, the signed Return Receipt Card, is attached hereto. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff Ely r q - arol J. Lindsay, Esquire # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 JENNIFER L. YOUNG, Plaintiff VS. KOREY R. YOUNG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 2824 CIVIL TERM IN DIVORCE PROOF OF SERVICE 4 SENDER: •COmpata ROM I andfor 2 for addltlond servkos. I also Wan to receive the .Compete Henn s. 486 arid eb. following services (for an •Pdm yom name and address on the reverse of this form so that we can retum We extra fee): card to WWu. h Nis form to du from of the mdlpece, or on the back If space does not a N l w 1. 13 Addressee's Address N rn p pa •WAU lietum Rsoelpt Requested' on the malipece below this article number. oThe Retum Receipt vAl show to whom the artkde wee delvemd and the date 2. El Restricted D ry V delivered e BB ???((( . . 3. Article Addressed to: g NN11 4e. Z dg 1 s '.i@r31 684 Mr. Korgy R. Young 18 Carlisle Road ab.Service Type Newville, PA 17241 ? Registered [2 Certified ? Express Mall ? Insured Q Return Receipt for Merchandise ? COD 7. Date of Delivery S /7- `I 5. Recel vo By: (Prlnt N J B. Addressee's Address (Only It requested lv 1 Ob a e. Ut2 and lee /s paid) tt F ture: ee w e. signs X G Ps Form 3811 , Docamber 1994 Domestic Return Re08 pt P: r: I JENNIFER L. YOUNG : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : CIVIL ACTION - DIVORCE NO. 99-2824 CIVIL TERM KOREY R. YOUNG, Defendant, : IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this 17 day of May, 1999, I, Korey R. Young, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. /7-yf KOREY R-IYOUNG L^ <`D I_, C? 1!)<- f ? 1, !, ;?? t L . ... ' ('. U l,": C1: ?J JENNIFER L. YOUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 99-2824 CIVIL TERM KOREY R. YOUNG, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on . 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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 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 authorities. ?UbnniferL.i!#11g, PWtiff Date: ?17 ' 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. 2. 1 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. 1 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. verify that the statements made in this Affidavit 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 authorities. Jennif r . Yo . Plain i Date: /&/ ?..2 /Cr f 6661 E Z 100 11 JENNIFER L. YOUNG, Plaintiff VS. KOREY R. YOUNG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 99-2824 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on . 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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 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 authorities. y R.. You efendant Date: 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. 2. 1 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. 1 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 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 authorities. ey R. ng, Defendant Date: _?? I,