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Home My WebLink About99-03633T2 S :.,1 O e.:id • ?• ;?, <?? ,e, cam, :?• ce• t?• :r,• ;r• •,r, r? • :?•. •v> .?::? • •:? • t? • •:? • .:e, s::cwr..?a:a>::ce•:>tex t?, cr,• :,ya: •,+?ac? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY a STATE OF PENNA. V , Mark E. Deja, Plaintiff, N 3 6 3 u ... .... 3 .. ..... .... ......... 1999 S ............ .. Verses Holly E. Deja, i Defendant. ` DECREE IN DIVORCE ; 1f AND NOW t , .... . , • • . • , . _ • .. 9 ... it is ordered and ? decreed that M. E Deja ................................................. .plaintiff, ;;• and Holly E. Deja defendant, ..................................... i :; `% 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; 14 None. ...................................................... ......... ....................... ...................... t! By Th rt 'F. .?•. Attest: J. ' 5 (tJ t+ r . 04 Prothonotary j° Y ?i. •?;. <,r..;?..W? .W.. ;X?.W...,y:. <?..;O ..1r..:01? ?:e: W. :c• •a: •v:• ?:e> W. •:e• :a 'A:• <e:• te: ts:• <e: •s:• :a y W. /r/999 Michael S. Travis 1D No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 In the Court of Common Pleas of Cumberland County, MARK E. DEJA, Pennsylvania ) Plaintiff, ) VS. ) No. 99-3633 HOLLY E. DEJA, ) CIVIL TERM Defendant. ) 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: CodeI. Ground for divorce: irretrievable breakdovm under § 3301(c)(1) of the Divorce . 2. Date and manner of service of the complaint: June 18, 1999, Certified U.S. Mail, Restricted Delivery, Affidavit of Service attached. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff on November 10, 1999; by defendant on October 24, 1999. 4. Related claims pending: No economic or related claims were raised. 5. Date plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: / i 2 , 1999. Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: /r1iZ '1999. c ael S. Travis Attorney for Plaintiff ?- -- ? ? ;:- ?,., ?' _ c??- _ - ?_ G ?)(.l _: ?r :V W?•_ JI, _ li x. ?_ Z_ 11. ?_,? ? CJ ?,, ;? In the Court of Common Pleas of Cumberland County, Pennsylvania MARK E. DEJA, ) 9 0 --3 G 33 Plaintiff, ) 7 VS. ) No. of 19 HOLLY E. DEJA, ) 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 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 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 Courthouse 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania MARK E. DEJA, Plaintiff, ) Defendant. ) No. 9y- 3633 of 19 VS. HOLLY E. DEJA, CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in 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 require 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 waiver of your right to request counseling. In the Court of Common Pleas of Cumberland County, Pennsylvania MARK E. DEJA, ) Plaintiff, ) VS. ) No. 9 -'/ 9 6 33 of 19 HOLLY E. DEJA, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by his attorney Michael S. Travis, respectfully represents: 1. The Plaintiff is Mark E. Deja, who resides at 19 Houston Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, since y/)p of 19 / 7 2. The Defendant is Holly E. Deja, who resides at 19 Houston Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, since YA of 19 ?7 3. The Plaintiff and Defendant have been bona fide residents of 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 April 30, 1994, in Cambria County, Pennsylvania. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. The 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. 9. Plaintiff requests the court to enter a decree of divorce. 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. § 4904, relating to unswom falsification to authorities. Date: Ie 4hq Mark E. Deja, Plaintiff i ael S. Travis Attorney for Plaintiff I.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 6 ? a > - _5 Oo 1.1.1• 'I ??-' .I '= V n U In the Court of Common Pleas of Cumberland County, MARK E. DEJA, Pennsylvania ) Plaintiff, ) VS. ) No. 99-3633 HOLLY E. DEJA, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVI10 F CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 15, 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 unworn falsification to authorities. DATED: p eQk* aM E. Deja, aintiff ?=- ". ?' ? -_ - ,_ _ _. -:; ?. ?., LLI ?. i L.. U_ U ? '"1 'J M WE In the Court of Common Pleas of Cumberland County, Pennsylvania MARK E. DEJA, ) Plaintiff, ) VS. ) No. 99-3633 HOLLY E. DEJA, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 15, 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. 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 unswom falsification to authorities. DATED: Q Holly E. Deja, Defendant } C1 Lr. f UC:. i 7.,1 Li_ rTi LI In the Court of Common Pleas of Cumberland County, Pennsylvania MARK E. DEJA, Plaintiff, ) VS. ) No. 99-3633 HOLLY E. DEJA, ) CIVIL TERM Defendant. ) IN DIVORCE 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. 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. § 4904 relating to unworn falsification to authorities. Date: 1444 Ma . Deja, Pla' 'ff } ?. ? ,. "'.: u.iQ ??r_ ?_c. nn7?( T (. ' ?c_ 17 LLJI C C. U m J C1 '? In the Court of Common Pleas of Cumberland County, Pennsylvania MARK E. DEJA, ) Plaintiff, ) VS. ) No. 99-3633 HOLLY E. DEJA, ) CIVIL TERM Defendant. ) IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 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. § 4904 relating to unswom falsification to authorities. Date: - ?7 4k 5?? Holly E. eja, Defendan Lr F u c.. 11.'? C p. _ u In the Court of Common Pleas of Cumberland County, Pennsylvania MARK E. DEJA, ) Plaintiff, ) VS. ) No. 99-3633 HOLLY E. DEJA, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF SERVICE I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. Z 476963452, return receipt requested, by depositing the same in the United States mail on June 16, 1999, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was received by the Defendant on June 18,1999. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Travis O f 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 ? c C) _ Lf: H LLl? _ U'_ ri ?.' C )( ,_ t ? Llc ?? LL1• ?!?' _ ?_ C L'_ U a v SENDER; •COmplalehOnes lanN-12101 addleonal services I also wish to receive tho u w , On' t ms3.4a.and4b. • Prirnl you you r ma and address on the revprsa of INS lo•m so lnai wa can return Rris d l0 f IOWIn services for an Atlacn Ihis 1 m to IM1e IrOnt of Ina maApuca. or on IM1O Oack it space tloes riot ! T p 0 A d e5 M N Tphole Wrile'Re1Receipt Reeuesled' on the mailprece below the article number ill • The Return Rec h i t ?? A I w s e p ow to whom the article was deliverM and the date .. delivered. Consult postmaster for fee. n 0 9. Article Addressetl to: 4a. Article Number u y"16 9c-3 4>'Z E A S «-L F S 4b. Sorvlce Type E 6 gC3vS?N l7 R 1 ? - 61 ? Registered hYC'Milied trAMiMINii,C (SI. ?1G Pq 17U C1 ?E-pE0+s,ylail ? Insured FJR uieflecglptl rMe¢nandise ? COD ? 7/bala i Oelblery' Uf \ o S. Received By: (Print Name) Adgfy,?see's dress (Orrry d requeslad y a e ie qAi? q , 6 Si d ? . gn re: ie a or t1 X _ PS Form 3811, Dec ber 1994 M's9598 8 0229 Domestic Return Receipt .4