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Home My WebLink About99-03608,I w.i O 1V V Y )' o a' d? ^^7 v 1 I h i 1 PENNY S. YOUNGBLOOD, Plaintiff Vs. DONALD B. YOUNGBLOOD, 111, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3608 CIVIL ACTION-LAW IN DIVORCE PRAECIPE The Social Security Number of the Plaintiff is 208-54-9235, and the Social Security Number of the Defendant is 277-78-9874. Respectfully submitted, PURCELL,KRUG & HALLER BY Jr. M9 North Front Street Harrisburg, PA 17102 Attorney for the Plaintiff i i i ? DECREE IN DI VORCE AND NOW, .... M 4^` .. g........... , 0 2001• . , it is ordered and decreed that ...... zenny..S...Younghl.ood. ........................ plaintiff, and . ............Donald B. Youngblood, III, .... , • • • , 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; i? AO 0 E'::6 <?:. _?•.. ??,.. :V, .-,V, F,..tr, ;r,• •-a r, :6• {t• ;N :?• :?• a::?• CE•'?:;:15•:i ?IIiS3W,,t•:> •:::e•t IN THE COURT OF COMMON PLEAS OF CUMBERLAND STATE OF COUNTY PENNA. PENNY S. YOUNGBLOOD, _ N l )...361V ............ ................. 1999 Plaintiff Versus DONALD B. YOUNGBLOOD, III, Defendant i ftly. A o <. , By T r ; iR Attest: ? J. ?t.AL4 Prothonotary l? 3 nod/ lu^rri au//?wt?c?I" w PENNY S. YOUNGBL.OOD, Plaintiff vs. DONALD B. YOUNGBLOOD, Ill, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3608 CIVIL CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD THEPROTHONOTARY: 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 (X) 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: June 18, 1999 by Certified Mail 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: March 17, 1999 by Defendant: February 21, 2001 (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: No economic claims have been raised. 5. (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 of Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: March 29, 2000 Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Filed contemporaneously herewith ??, ;L JOH1N-W. URC L, JR. ESQ. ?'_i ^1 PENNY S. YOUNGBLOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. DONALD B. YOUNGBLOOD, III, : CIVIL ACTION-LAW 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 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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 PENNY S. YOUNGBLOOD, Plaintiff VS. DONALD B. YOUNGBLOOD, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99. 34ni ? Te CIVIL ACTION-LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with 93302(c) or (d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of professional marriage counselors is available at the Cumberland County Court House, Carlisle, Cumberland County, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the 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 waiver of your right to request counseling. PROTHONOTARY Dated: PENNY S. YOUNGBLOOD, Plaintiff VS. DONALD B. YOUNGBLOOD, III, Defendant IN THE COURT OF COMMON PLEAS : C"TM3ERLAND COUNTY, PENNSYLVANIA NO. 790 p CtP T CIVIL ACTION-LAW IN DIVORCE COMPLAINT 1. The Plaintiff Penny S. Youngblood, is an adult individual whose residence is 1332 South 13`n Street, Harrisburg, Dauphin County, Pennsylvania 17104. 2. The Defendant Donald B. Youngblood, III, is an adult individual whose residence is 7073 Carlflse Pike, Lot 72, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff has been a bonafide resident 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 February 18, 1989, in Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff avers that there is one child of the parties under the age of 18: Donald B. Youngblood, IV, born November 1, 1989. 7. The Plaintiff in this action is not a member of the Armed Forces. 8. The Plaintiff and the Defendant are both citizens of the United States. 9. The Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to a divorce decree being handed down by the court. 10. The Plaintiff avers the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, & HALLER BY ,o w. Purcell, Jr., Esquire r. . #29955 719 North Front Street Harrisburg, PA 17102 (717) 234-4178 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. June 10, 1999 Dated: f:! - Penny S. Y ungblo d J Vs U V ./O W d U ? 3 3 3 3 ???"? D 0 0 0 .. 0 y z z y z w C A °? s a a m V O G H O G W Z 3 faA .%1 m Z 7 m 0 0 z a a _- - 0 z H a o - O q O E Z O N 6 H ? z O 0 ?+. evuv.o sma nas uv leas,av m .01 DJ lleen5 n031 j1313 1W PENNY S. YOUNGBLOOD, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. ggqq NO..06-3608 CIVIL DONALD B. YOUNGBLOOD, III, : CIVIL ACTION-LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF DAUPHIN I, Carol Masich, secretary to John W. Purcell, Jr., Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 15th day of June, 1999, I sent, by certified mail, return receipt requested, deliver to addressee only, a certified copy of the Complaint in Divorce, containing Notice to Defend and Claim Rights to Donald B. Youngblood, III, the Defendant in the above action. The return receipt, duly signed by the Defendant is attached hereto and made a part hereof as Exhibit "A". Carol Masich Secretary to John W. Purcell, Jr. Sworn and subscribed to before thi/?lay Notarial Seal public '?nita E. Lombard Notary ,risburg, Dauphin countyy nission Expires Sept. 24. 2001 $ SENDER: • COrrlplete Items I eml F for adtlalnnnl svrve:es •Complete hems 1 as and AD • Print your name and address on the mvnrse at Ihis form sh that wa can mtum Ilno p cartl to uu • Anaeh IK s form Io the (runt of the mndpicce, or on me `:v:k it eyecu does not ponml • "Relum Recepl R rdbn the teMphies below the mb hump,. • The e Rehm Roceipl well show show 1 (o whom the angle gle was dalwer,o rntl the dale Oalrveretl. 0 3. Article Addressed (0V n 1? ? cJ ?P1'? <S \ t V C'_oy?w slc 1 A • I Rem c i ed By: int Nam J o. Slgnatur (Addie ee or Ager ' ° X a . ° PS Form 3811, December 1994 11L6e598?11-0229 Z 533 P08 399 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Dn nnl use in, Intornminnnl kAa it /Cnu muamal m m Q O M E li N a 4a. I a1SO wish to receive the following s (for an exira I Sty r9S5 A re55 R?,tt \dcled D live C \ l v l?? 4b. Service Type '-' ? ? Registered j$CeTied li ? Express Mail 0 Insured f 0 Return Receipt for Merchandise 0 COD 7 D t f D li 0 . a e o e very e. Addressee's Address (Only i/ requested T m and lee is paid) c IO \ ? 1 .r Irp@I, )4y. ),%, ?) V l I OIIiEe, Slat aZIPC ^ \^O ? \5 (-} )0 Postage $ Certified Fee Special Delivery Fee Resinmed Delivery Fee Return Receipl Showing to Whom 8 Dale Delivered Return Recap! Showng to Whwn, Dale, 6 Addressee's Address TOTAL Passage A Fees $ Postmark or Date Return Exhibit "A" ti i` C) 1: C': ! l ( ? J. ? t\1 I' l?. 1. ?.? . ;: _ I.•.. -? Cn Ul , PENNY S. YOUNGBLOOD, Plaintiff VS. DONALD B. YOUNGBLOOD, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 99-3608 CIVIL : CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1 . A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on June 14, 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. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 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. 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 unsworn falsification to authorities. Date: Penny S. ood • -? :?: '"7 f it 'J."? .1'J _? ? ? cwt -: iCu i? :i _ -? <J PENNY S. YOUNGBLOOD, Plaintiff VS. DONALD B. YOUNGBLOOD, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3608 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on June 14, 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. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 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. 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: )lad DONALD B. YOUNQBLOOD, III