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Home My WebLink About99-03029 :•: •ii.;•:i:?. :?•,>:6i_{i;:':iX :i} •r•.. •:O:• •:i: ,i7 •:i:• :i:• q'. -.W. :e:•':<: X'.. X:.. IN THE COURT OF COMMON FLEAS 171. CUMBERLAND COUNTY OF c 0 i 0 r f f ENNA. P STATE OF W??W? ......Crys tal. Ann..Chris ty ................... _.................... N c x.....3029 ........... ... 99.......... Plaintiff ..................................................................................... Versus I Rus.s.eU. Henry. Christy,. Jr.• ............................ .............Defendant............. __ __.. .__....._ ...._ _ li DECREE IN DIVORCE AND NOW, ?r . • P • • • . 19.99• • • . it is ordered and decreed that Chris ty.Ann.Chris ty ............................... plaintiff, and . - Russell. Henry. Christy,- Jr. ............................. . 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; ....... ................................................. .. . . . . . . N....one ...., ................................................... By The J url'. ` J. Attest: Prothonotary {?i {?i {e:• ?i:•. :? •l {i:• {1} • ?•,. eAri yi ??i •ai ?A;• :? • •y;• •a} <i} •SY. ??:^ {?i •:f: •:e:• {ii..:i:....:e:• LK• •:? • W. S° 0 i i •., „. x'//99 ?'? ??? ""?..?.o'' 7!i ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Crystal Ann Christy, : No. 99-3029 Plaintiff VS. Russell Henry Christy, Jr., Defendant : Civil Action - Law : In Divorce PRAECIPE TO TRANSMIT RECORD 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on May 21, 1999 and was accepted May 24, 1999. An acceptance of service was filed on May 28, 1999. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff 8/31/99; by Defendant 9/2/99. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice in Section 3301(c) dated 8/31/99 is filed herewith and the Defendant's Waiver of Notice in Section 3301(c) dated 9/2/99 is filed herewith. H. Anthony Adam Esquire Attorney for Plainti 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 []; 1` CJ __ l1 t. i ??: -7 .+ )ly _ rt - CJ .J : i 1' ?, tici ' ? - r.^, =j y U''? t? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Crystal Ann Christy, : No. Plaintiff : Civil Action - Law VS. Russell Henry Christy, Jr. 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 following 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 may be 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 the custody or visitation rights of your children. When the ground for 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 Courthouse, Carlisle, 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)-244-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Crystal Ann Christy, No. `I 9. 3?0 z 9 (_',,;?f Plaintiff Civil Action - Law VS. In Divorce Russell Henry Christy, Jr., Defendant COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Crystal Ann Christy, who currently resides at 154 Timber Lane, Shippensburg, Cumberland County, Pennsylvania, since March 26, 1999. 2. Defendant is Russell Henry Christy, Jr., who currently resides at 217 Neil Road, Shippensburg, Cumberland County, Pennsylvania, since October 15, 1997. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on June 22, 1991, in Mainsville, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. Respectfully submitted. H. Anthony Adams, d?ire Attorney for Plaint'ii 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 I verify that the statements made in this Complaint 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. Date: 9 1 0 ?l! k (C? rYysttal Ann Christy ltl r.? -.7 ."j r_,- -- ; . J V v m O IL. H N z a n ZZ a ? 3 ? n W Z Q m Q w Qg wCL H x ti }} N 7 Q ? - Z Y W Z W W Z F N d Z W Q o w Q Q w a 2 Z U 1 -1 V r4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Crystal Ann Christy, : No. 99-3029 Plaintiff Civil Action - Law VS. In Divorce Russell Henry Christy, Jr., Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 19, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. Section 4904 relating to unsworn falsification to authorities. Ql Ann Christy ?- Plaintiff ?r l') C Ll V: l ?. G1 U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Crystal Ann Christy, Plaintiff VS. Russell Henry Christy, Jr., Defendant No. 99-3029 Civil Action - Law 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 4904 relating to unsworn falsification to authorities. Date:S Crystal Ann Christy Plaintiff ?Y ..l _t U C: cr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Crystal Ann Christy, Plaintiff : No. 99-3029 Civil Action - Law VS. Russell Henry Christy, Jr., Defendant In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 19, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. Section 4904 relating to unsworn falsification to authorities. Date: ?r/? Q Russell Henry C?ty, ]r. Defendant r r ,. ?-•- ? P? o }_ L- !'?' ILL-t C: -?.rr ? L..Y• • ??• Y ? 1:.-? ' 1?.; v: ;?2 - I' ?- c:n c,? J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Crystal Ann Christy, : No. 99-3029 Plaintiff Civil Action - Law VS. In Divorce Russell Henry Christy, Jr., Defendant 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 4904 relating to unsworn falsification to authorities. Dater Russell Henry Chris , Jr. Defendant '5 IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Crystal Ann Christy, Plaintiff VS. Russell Henry Christy, Defendant : No. 99-3029 Civil Civil Action - Law In Divorce AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Russell Henry Christy of 217 Neil Road, Shippensburg, Pennsylvania 17257, certified mail, return receipt requested, on May 21, 1999 and was accepted on delivery by Russell Henry Christy on May 24, 1999 as shown by the attached receipt. H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this C tthdayof May, 19 9. AA/It?l _.... _...? _... Notary Public My Commission Expires: g SENDER: w a Complete items l crWo, Y for additional cervices. Q Complete Items 3, /e, and /b. r O r'IIM,oUr hemp and addfeSS on the Monte of this form to that we Cen ratum ims L p Card to you. L O Atlatlt this form to the 1=1 of the matlPiaca, or on tat back it apace does nod O rr. Parma. 13 Wide'Remm ReoeiPt ROQuested' on the madloace below this adide number. C O The Relum Receipt wia show to whom the aNde was delwared and the dale O derrvared: _ NOTARIAL SEAL DAWN MARIE SHOOP, NOTARY PUBLIC Shippensburg, Cumberland County, PA !My Commission Expires February 5, 20(N1I Form , Deowbar 1994 I also wish to receive the follow. Ing services (for an extra fee): 1. O Add ssee's Address 2• estricted Delivery - n 4 oa. Amme Nu nDer rvlce Type / g istered Ifl? 0 ass mail 13 Insured A` Receipt forMetchshane OODD fee is paid) 117ee3M4111= Ra ?Sipnetur?rassee or A9enf/? a. M ?N.uuuu,:pu\J'.(;utu{iW{J?t{?UiluM •,y uwoui vivulE eliuuli ouiv k bilul is Y1f?1VFJlVf' 2EVf fig N • u' i .