The URL can be used to link to this page

Home My WebLink About99-02841xw xc IN THE COURT OF COMMON PLEAS OF CUMBERLAND STATE OF COUNTY PENNSYLVANIA No. 9.9-2.9.41.... Civil ..Team.. 19 DECREE IN DIVORCE AND NOW,... • • . • ......,_]A--'... , it is ordered and decreed that .... r1arc s. Rp 4n i g ........................... . plaintiff, and .. Cathy dohen,Spaulding .................................. 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; 416. none ........ ..........................................\a. 1................ i? d. QY T e Co 4 Atte ................... d : ... s /j4G?lL? r J" J. Prothonolsry r' o a1o- 4F a1o- a1o. 41D 416 41D 4G ao ac ac• ,?u •:w rw:• •?c ?x? fw^.:•x• ?x• as .x'?' ,? '"""'"` F ?a ac• •,K: j/. jam.. ?d ?„? ??? izz???/ f ?G7, 5'?a-?: 4, t. i MARC S. SPAULDING, Plaintiff V. CATHY COHEN SPAULDING, Defendant TO THE PROTHONOTARY: IN THE COURT OF CONMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 99 1b // Ctv?y ?? PRAECIPE TO TRANSMIT RECORD Please transmit the record, together with the following information, to the Court for the entry of a Decree of Divorce. 1. Ground for divorce: irretrievable breakdown of the marriage under Section 3 3 0 1 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Cathy Cohen Spaulding, on Marc S. Spaulding, by 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on 11/ 3 /bb 2000; by defendant on 03100 2000. 4 Related claims pending: none. 5. Date of execution of the waiver of notice of intention to request entry of a divorce decree under Section 3301(c) of the Divorce Code: by plaintiff on / I /3 2000; by defendant on i 1 (3 2000. DATED: 11 l -sl oo Respectfully submitted, Thomas A. Hutton Attorney for Plaintiff N C' I LU '; _ ?J U x 'I MARC S. SPAULDING, Plaintiff V. CATHY COHEN SPAULDING, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - DIVORCE :NO. 99 - a'f?'y / e u t t [ k ?'1 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. You are warned that if you fail to do so, the case may be entered against you by the Court. A judgment may also be entered 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, Dauphin County Courthouse, Front and Market Streets, Harrisburg, 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 r 4 MARC S. SPAULDING, Plaintiff V. CATHY COHEN SPAULDING, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - DIVORCE :NO. 99- a Pv/ T COMPLAINT AND NOW comes the Plaintiff, Marc S. Spaulding, who, by and through his attorney, Thomas A. Hutton, Esquire, files this Complaint, in which he avers that: 1. Plaintiff, Marc S. Spaulding, is an adult individual residing at 1759 Kings Arms Court, Cumberland County, Pennsylvania 17070. 2. Defendant, Cathy Cohen Spaulding, is an adult individual residing at 308A South Enola Drive, Cumberland County, Pennsylvania 17025. 3. Both parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 17, 1989, in Hershey, Dauphin County, Pennsylvania. 5. The parties have lived separate and apart since December 1, 1997. 6. There have been no prior actions in divorce or for annulment between the parties. I I( 7. Neither Plaintiff nor Defendant is in the Military or Naval Service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNTI Request for a No-Fault Divorce Under Section 3301(c) or (d) of the Divorce Code 10. The averments contained in Paragraphs I through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiffs marriage to Defendant is irretrievably broken. 12. Plaintiff has been advised that counseling is available and that he may have the right to request that the Court require the parties to participate in counseling. 40 (t WHEREFORE, pursuant to 23 Pa.C.S.A. Section 3301(c) or (d), Plaintiff, Marc S. Spaulding, respectfully requests the Court to enter a Decree of Divorce. DATED: Respectfully submitted, Thomas A. Hutton, Esquire 2137 Canterbury Drive Mechanicsburg, PA 17055 (717) 783-2353 Attorney for Plaintiff L rY t ?:I LL. `.l :J ? CC ?_?c ?:1W U, cU V N MARC S. SPAULDING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE CATHY COHEN SPAULDING, Defendant : NO. 9? . } y (;tp T^ AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on 1 / I C 1999. 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. 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. Dated: hl-110v :??r K _ Marc S. Spaulding '? r ? Li n: _7 A :_? ?_? i\ ?' O_ ?? ?:J ???1 1:. ? ?_? ' ??? CU MARC S. SPAULDING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE CATHY COHEN SPAULDING, Defendant : NO. 9 J S '// ??u • '?' / n 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on S /lo ,1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninely 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. 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 unworn falsification to authorities. Dated: 0/3/00 Cathy Coh 11 Spaulding an- C-i `?J -- C, ?> MARC S. SPAULDING, Plaintiff V. CATHY COHEN SPAULDING, Defendant JN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW JN DIVORCE :NO. !e(- 2Stn C?v I -T4:w WAIVER OF NOTICE OF INTENTION TO REOLIFST ENTRY OF A DIVORCE DECREE UNDER SF TION 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. 1 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. Dated: Marc S. Spaulding cr. ?' ?' ?= - = ?: ::>= : %_??? (.J'. ?'J ', i:? ' ? ? _ . - ? a ?? I ?.. ??i .i. T](? _ ?' . (=i J 1 :_) ?',? MARC S. SPAULDING, Plaintiff V. CATHY COHEN SPAULDING, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE :NO. `M - Zls`I I e'- I -T ? r> 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 wnderstand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unswom falsification to authorities. Dated: 111-3/00 CathAC?L•. t sz?) Cath n Spauld g >- Lr r- ? ?- ?r v. ?_; -1 _' fJC ( ? , n ? _7 ' _ r_'L .. . C'? . ?ilL LO IL ? '-' . ?3 ? MARC S. SPAULDING, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - DIVORCE CATHY COHEN SPAULDING, Defendant :NO. ACCEPTANCE OF SERVICE I do hereby accept service of the Complaint for Divorce filed in the above-captioned matter. DATED: 51 1 1 1 99 C C® ?-S Cathy ohe Spaulding c?•r. r? L L; 7- - `-r LU C1 G rn c? U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARC S. SPAULDING, Plaintiff ; V. CATHY CONEN SPAULDING Defendant NO. 99-2841 C T V T L 19 ACTION IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of «C matrimony on the ]?"? day of ,-}9-(? hereby. elects to retake and hereafter use her previous name of CATHY L. COHEN (Sij t - married ::r' (Si - to be kr;rwm as) COMMONWEALTH OF PENNSYLVANIA COUNTY OF 1RUHBEttLAKND ss. On the c' )`S day of 1-9 before, a Notary Public, personally appeared r `cs r_4 „ •, , k&o n 1 to me to be the person whose name is subscribed to then'thin docu- ment, and acknowledged that she executed the foregoing for the pur- pose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. NOTARIAL. SEAL NotaryJPublic PATTY L. STROHECKER, Nolay PubCc City of Harrisburg, Dauphin CDuntp My Commission Expires Jan. 6, 2007 5 a Mt I o c?> Qe ?„ cJ