HomeMy WebLinkAbout99-02968L
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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STATE OF oc.
PENNA.
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MARY ANN QUIGLEY, • Plaintiff 99-2968 CIVIL TERM s
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Versus
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FRANK H. QUIGLEY, $
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.__ Defendant...
DECREE IN
DIVORCE
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AND NOW, ..... ..... Ja r! . ? ?, 199.3... , it is ordered and
decreed
that .......
.......... MARY
......
ANN QUIGLEY plaintiff,
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and :......................... FRANK H. QUIGLEY
..................... . 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;
NONE
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By T1 Court
Attest: . ?•
Pr honotary ;
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MARY ANN QUIGLEY,
Plaintiff
VS.
FRANK H. QUIGLEY,
Defendant
1 IN THE COURT OF COMMON
1 PLEAS OF CUMBERLAND COUNTY,
1 PENNSYLVANIA
I
1 CIVIL ACTION - LAW
1
1 NO. 99-2968 CIVIL TERM
1
1 IN DIVORCE
PRAECIPE TO TRANSi I RFrnan
)THEPROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a divorce
1. Ground for Divorce: Irretrievable breakdown under Section 3301(c).
2. Date and manner of service of the Complaint: Acceotan of Service filed by Plaintiff's
I indirntinn ean,irn nn n.., 1...... . n ....... .. _.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce
by Plaintiff: 13 December 1U99 by Defendant: 13 Decpmb r 1999
(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce
rln (2) Date of filing and service of the Plaintiff's Affidavit upon the
nt•
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,
copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
notary: Dated 13 Decemb r 1 g filed ont mporane sl herewith, Date Defendant's
of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 13 De .mb r
filed contemooraneously herewith.
194q Bv-S
Samue .Andes
Attorney for Plaintiff
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MARY ANN QUIGLEY, 1 IN THE COURT OF COMMON
Plaintiff ? PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
)
VS. ? CIVIL ACTION - LAW
FRANK H. QUIGLEY, ? NO. 99-.)9bf CIVIL TERM
Defendant ? 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
foregoing pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree in divorce or annulment maybe 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:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
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, Pennsylvania 17013
Telephone: (717) 249-3166
MARY ANN QUIGLEY,
Plaintiff
VS.
FRANK H. QUIGLEY,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
1 PENNSYLVANIA
1 CIVIL ACTION - LAW
1
1 NO. 99- ?? 9G Y CIVIL TERM
1 IN DIVORCE
NOTICE OF AVAILABILITY-01E COUNSELIN
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court
Irequire you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list. All necessary arrangements and the cost of counseling sessions are to be borne by you
and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
of your right to request counseling.
I
MARY ANN QUIGLEY, 1 IN THE COURT OF COMMON
Plaintiff 1 PLEAS OF CUMBERLAND COUNTY,
1 PENNSYLVANIA
1
VS. 1 CIVIL ACTION - LAW
1 NO. 99- o796P CIVIL TERM
FRANK H. QUIGLEY, )
Defendant ) IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, MARY ANN QUIGLEY, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is MARY ANN QUIGLEY, an adult individual who currently resides at
1470 Maplewood Drive, New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant is FRANK H. QUIGLEY, an adult individual who currently resides at
4245 E. Williamsburg Drive, Harrisburg, Dauphin County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 13 June 1959 in Mechanicsburg,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
DATE:
MAR ANN QUIGLEY
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Sa a L. An es
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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MARY ANN QUIGLEY,
Plaintiff
VS.
FRANK H. QUIGLEY,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99- ??qbp CIVIL TERM
IN DIVORCE
The undersigned, Frank H. Quigley, does hereby accept service of the Divorce
Complaint filed against him in this matter and acknowledges receipt of a certified copy of
that Complaint.
DATED: / 8 9 J
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MARY ANN QUIGLEY,
Plaintiff ) IN THE COURT OF COMMON
1 PLEAS OF CUMBERLAND COUNTY, !
1 PENNSYLVANIA
VS. 1
1 CIVIL ACTION - LAW
FRANK H. QUIGLEY, I NO. 99-2968 CIVIL TERM
Defendant 1
) IN DIVORCE
AFFIDAVIT OF ONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
17 May 1999 and was served upon the Defendant on or about 18 May 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. 1 consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. 1 have been advised of the availability of marriage counseling and understand that !!
the Court maintains a list of marriage counselors and that I may request the Court to require j.'
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming I
final. j .
I verify that the statements made in this Affidavit are true and correct and 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.
2/13
DATE
? MA Y ANN QUIGLEY
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MARY ANN QUIGLEY,
Plaintiff
vs.
FRANK H. QUIGLEY,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-2968 CIVIL TERM'S
IN DIVORCE
QF A DIVORCE DECREE I INUEa SECTION 33Q1 (g1 OF THE DIVOR .E CODE
1. I consent to the entry of a final decree in 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. 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.
12- /3 `l9
Dated: Lk: 4 MA Y 4ANN QUIGLEY
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MARY ANN QUIGLEY,
Plaintiff
VS.
FRANK H. QUIGLEY,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-2968 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
17 May 1999 and was served upon the Defendant on or about 18 May.1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. 1 consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. 1 have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and 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.
"DATE
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MARY ANN QUIGLEY,
Plaintiff
VS.
FRANK H. QUIGLEY,
Defendant
1 IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
)
CIVIL ACTION - LAW
NO. 99-2968 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF IN LENTIION TO R_ EQi Ig ENTRY
1. I consent to the entry of a final decree in 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. 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.
/2/.39 -
Dated:
K H. QUIGLEY
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