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Home My WebLink About99-02947,?- 3..? ,,, ,. a y. IN s1 a! *I THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY STATE OF PENNA. N c ?...?.9.-.x.99.7... ..C..v? .. 19 DECREE IN DI V 0 R C E 0 e F F Y .fXr AND NOW . ...............u,r+, , .??n, • , K. zooq, it is ordered and decreed that .... Barbara.z... Myers .......................... . plaintiff, and ..... ?RhR. ?•..MYers,. Jr; .............................. . defendant, f are divorced from the bonds of matrimony. i 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; None ......................................................................... .. ................................................. By The Court Attest: r Prothonotary /J6..? •Y:• ?A•} .». .•??•. .SR• •Y:• :?• •'A} {?:• :?. .N .o: •s. .t. Y:• .?. .O.• :r. .?... d:• .o. .o. •:1. .!. Y}, .o. .o.• f BARBARA L. MYERS, Plaintiff V. JOHN V. MYERS, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2947 CIVIL IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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) of the Divorce Code. 2. Date and manner of service of the Complaint: On May 18, 1999 by U.S. Certified Mail. A Certificate of Service has been filed with the Prothonotary's Office. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on May 6, 2000; by Defendant on May 6, 2000. 4. Related claims pending: None. Page 1 of 2 i 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 5, 2000. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 5, 2000. Rent H. Patterson Attorney for the Plaintiff 221 Pine Street Harrisburg, PA 17101 (717)238-4100 11 Dated: a(?rl J Page 2 of 2 .L BARBARA L. MYERS, Plaintiff V. JOHN V. MYERS, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- a9v7 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 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 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, Dauphin County Courthouse, Front & Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE AR 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 Lawyer Referral Service Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6200 BARBARA L. MYERS, Plaintiff V. JOHN V. MYERS, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 191'! CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Barbara L. Myers, by her attorney, Kent H. Patterson, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, Barbara L. Myers, is an adult individual who resides at 140 Frost Road, Gardners, PA South Middleton Township, Cumberland County, PA 17324. 2. Defendant, John V. Myers, Jr., is an adult individual residing at 36 East 36`h Avenue, Hobart, Indiana, 46342 and having a mailing address at P.O. Box 662, Hobart, Indiana 46342. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 17, 1990 in Cumberland, Maryland. 5. There have been no prior actions for divorce or annulment between the parties. I 6. Plaintiff and Defendant are both citizens of the United t States of America. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is. based are that the marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties participate in counseling. 10. Plaintiff asks the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. i 'Kent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 -2- VERIFICATION I, Barbara L. Myers, verify that the statements in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Barbara L. Myers I?r Date: 6-4 % 2 a w L U- CLJ L u.,5 w `.i J r : c5 u ; ? t. . ? J r_ t (> cn S C.? BARBARA L. MYERS, Plaintiff V. JOHN V. MYERS, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2947 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Section 4909 relating to unsworn falsification to authorities. .5' /e, /m &Yala X4.2d,12 Date Barbara L. Myers Vlf 4 _ D Z El' - r]LLL3.1. L1 ? U BARBARA L. MYERS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-2947 CIVIL TERM JOHN V. MYERS, JR., Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on May 14, 1999. 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 in divorce after service of Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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. U ? i. ,r O 5`c' , If 0 o u BARBARA L. MYERS, Plaintiff V. JOHN V. MYERS, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2947 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 1 them before a divorce is granted. s 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. Section 4909 relating to unsworn falsification to authorities. 6X. /mar Date ?J V MX JR. -s, G H 7 JILL ll. ?. c Q2 - BARBARA L. MYERS, Plaintiff V. JOHN V. MYERS, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2947 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on May 14, 1999. 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 in divorce after service of Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. Being so advised, I do not recuest that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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. 54904 relating to unsworn falsification to authorities. r Date -J V. MYER?, LT f CLC ul... `-J 4 n' C- J L7 ? iq ^_ ]LIi7 .a u U BARBARA L. MYERS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-2947 CIVIL JOHN V. MYERS, JR., Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Kent H. Patterson, attorney for Plaintiff in the case captioned above, hereby certify that on May 15, 1999, I served Defendant with the Complaint in Divorce by mailing copy of same by V.S. Certified Mail No. P 149 800 518, postage paid, at Harrisburg, Pennsylvania, addressed to Defendant, as follows: John V. Myers, Jr. P.Q. Box 662 Hobart, IN 46342 Attached hereto is the sender's receipt and the return receipt card which is signed by John V. Myers, Jr. and indicates a date of delivery of May 18, 1999. fi 1 ent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 P 149 800 518 US Postal ServrL.,, --- Receipt for Certified Mail No Insurance Coverage Provided, N- --. . . /I- I resr voice. Slate, ZIP Code A 1 V Postage § - S _3? Cedired Fee Special Delivery Fee Resbicled Delvery Fee N Return Receipt shoNSp to _ Whom 8 Date Delivered Return ReceptS)MV to Whom, _ kid us Fees $ Pas to l S '6 ? z i d :2 SENDER: . C nn;,ieto hems 1 end'or: for additional services I also wish to receive the W a I . Complem hems 3.4a, and ab, i Print your Game and 8dtlre6a on the reve,ee UI this farm, 60 th following services (for an at we can felam this extra too): ? T > ` card to card you. . Attach Iftls torn to the front of the nailpinrn, or on the bark d " apace does not 1. ? Addressee's Address ti -° L Z e40 e Nd 'Return callo w Requested' an WhOr the 1was the sands . 2.,®, Restricted Delivery number • Thp Return flaceipt will chew 10 whom Ihp 111111 was tlalmorotl and the he data derv ?r detivnreM. Consult postmaster for tee. g; 0 3. Artltle Addressetl to: M 4a. Article umb _ a OhN ye?RS, - C E , V /' f " ' 00- tea 4b. Service Type ? N 1 o u 13AI 7 T7N 4-634t;L Registered Certified ? E.press Mail ? Insured 2. ° ? Relurc Receipt for lderchandlso ? COD 71" 5 Received B : (Pant Name) 7. Dale of D vory`o ?. 0 ' . y - 8. Addressee s Address (Only if requested and too is paid) a c . ? 6. _ Po r A9ent1 0 T " PS Form 3811, Decemb s4 b,-h r,'.e o: n Domestic Return Receipt '1% G ?- G? rr 1 i ?., Lj ?. _. ;_? "fir; •]. - lJ _ - __ ':;, r ?- ;?c? ? t ?::_ ` ?? -.? ! .,-? _-. ...., BARBARA L. MYERS, Plaintiff V. JOHN V. MYERS, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2947 CIVIL c IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME. PRIOR SURNAME Barbara L. Myers, being duly sworn according to law, deposes and says that she is the Plaintiff in the above-captioned divorce action in which a final decree from the bonds of matrimony was entered and she hereby elects to resume her prior surname of YEDINAK and, therefore, she gives this written notice avowing said intention, in accordance with Section 2 of the Act of December 16, 1982, P.L. 1309, No. 295, 54 Pa. C.S.A. 704. ",a z ?U arbara L. Myers To be known as: 0 Barbara L. Yedin Sworn and subscribed before me this 25thday of July 2000 Nc ary ublic My commission expires: Notarial Seal 1limberly 0. Brown, 1Jotary Public Ifarrisourg, pauMin Coumy My COMM,mon a ,r_ Fro. 1R, 2002 0 r oC