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Home My WebLink About99-03658;e cr, t?• ;e• 4r, M. M. V :yn •:e• M X, W? :?• :?• a: <?• tc• xx?:x?x:•??s^te,:, < e% ;? :•?x IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. • Christopher D. Havens No. 99-3658 It) Plaintiff "" "" Versus Tami A. Havens ! Defendant 0J J DECREE IN Dl VORCE AND NOW, ...... Nny.c."..Ua ..I...... 19.57.. , it is ordered and r, decreed that .........ChzistQRher.D..Havens ................... . plaintiff, i! and • ................. Tami. A.. Havens......................... , defendant, are divorced from the bonds of matrimony. is 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; s The. Parties' • Marital, Property, and, 9ettiemen,t• A eemeat• dated. J,u] y .1.7.,• .L9.9.9, is incor orated herein and the Court has p..• jurisdiction over no other claims.. R A By The Cpyrt: ' Attest: J. r r. 14 S rothonolary ?'• y ? • rI?. {Ni rs. ? r •.f • :? • :t • :Y, :Y,• •:ei :ei :?:• •:e:• :e:• :ei •Y:. {e7 •:e:• •.e: •:e:• SO:• .Y.:. {?: ;t; {e:• <r• <?} 1r-3 ?? CHRISTOPHER D. HAVENS, Plaintiff V. TAMI A. HAVENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : CIVIL ACTION : NO. 99-3658 : 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. Grounds for divorce: irretrievable breakdown under Section 3301(c), 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Affidavit of Service, return receipt Muested, restricted delivery made on Tune 19, 1999. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by sec. 3301(c) of the Divorce Code: by plaintiff October 7,1999; by defendant September 30 1999. (b) (1) Date of execution of the affidavit required by sec. 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the defendant 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, a copy of which is attached _ f l? Date plaintiff's Waiver of Notice in sec. 3301 (c) Divorce was filed with the Prothonotary: October 25, 1999. Date defendant's Waiver of Notice in sec. 3301(c) Divorce was filed with the Prothonotary: October 25, 1999. ttorney for Plaintiff Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 (717) 243.9190 0 i If) Ia:L n: ? G v` U CHRISTOPHER D. HAVENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, ENNSYLVANIA VS. : CIVIL ACTION -LAW TAMI A. HAVENS, : NO' 99" 345Y 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 will proceed without you and a decree in divorce or annulment may 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 or 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 (717) 249-3166 CHRISTOPHER D. HAVENS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 99- 36 S 8 CIVIL TAMI A. HAVENS, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Christopher D. Havens, plaintiff herein, by and through his attorney, Jacqueline M. Verney, Esquire, and represents the following: 1. Plaintiff is Christopher D. Havens, an adult individual, currently residing at 534 Springfield Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Tami A. Havens, an adult individual, currently residing at 38 Maryland Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on April 11, 1997 in Winchester, Virginia. 5. There have been no prior actions for divorce or annulment between the parties. 6. The 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. Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, cqu ' e M. Verney, Es uitr Supreme Ct. ID. 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff YERWICATION 1 verify that the statements made in the within Complaint are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S.A. ¢ 4904 relating to unsworn falsification to authorities. Dated: 4,114I'i CL c. Christopher D. Havens c 1 y d tj rl) <> „. V a' CHRISTOPHER D. HAVENS, : IN THE COURT OF CO,ryrMnN oI,'AS C?r. Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW : NO.99- 3658 CIVIL TERM TAMI A. HAVENS, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE BY MALI PURSUANT TO Pa R.C P 1930,4(c l COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND I, Jacqueline M. Verney, Esquire, being duly swom according to law, deposes and says that she is the attorney for plaintifX Christopher D. Havens, and that she did serve a true and correct copy of the divorce Complaint that was filed in the above matter, by U.S. mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the defendant, Tami A. Havens, on June 19, 1999. The receipt form is attached hereto as EXHMIT "A„ '/ .V in q line M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Swom to and subscll before me this C` AA. day of 1999. I `? V v?^Ct?tp'Y?V2 olary Public NOTARIAL SEAL DENISE PINAMONTI. Notary Public Carlisle Borough. Cumberland County M Commisslon Ex res Nov. 20. 2 _ VrNutm: I elw wish to receive do e arow = t WWW x wr.ddd" wnkw. 9,4•, end 46. Iolb?Nrp services (for an • wive •?f?yurwl wd•ddrsuw ed. extra fee): ¦M ch.m-bmberhwlWvwf? n???e•? I •••rl mt 1.0 Addressee's Address wwolum Also Mow 10 T fa dds w' M p Rwap we CaneuM pwdnwtsr for tee & Anide Addresw to: M. ANde Number t 2 y5a qyc 5? T ?h /?+ . N? ' ?' 4p. Service Type -- // O EEvf Registered O red ? 3 ? RetnRntgbrhleldrMw 0 COD 7. Detedlt D4Wery Pad) A 102505484 = EXHIBIT "A" ` J, ?i ZZ ?=' -- UQ c. ," :' .'i ?? ,' it Z ww •- =ji COd _? 2 m ? .. ;+ U CHRISTOPHER D. HAVENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v CIVIL ACTION -LAW TAMI A. HAVENS, : NO. 99-3658 CI%rM TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 16, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. section 4904, relating to unworn falsification to authorities. Date: /b- 7-P Christopher D. Havens, Plaintiff _, ?. ?.; ,:, CHRISTOPHER D. HAVENS, Plaintiff V. TAMI A. HAVENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : CIVIL ACTION -LAW : NO. 99-3658 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 4904 relating to unswom falsification to authorities. /tea Date: /D ,- Christopher D. Havens, Plaintiff CHRISTOPHER D. HAVENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. CIVIL ACTION -LAW TAMI A. HAVENS, : NO. 99-3658 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 16, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. section 4904, relating to unswom falsification to authorities. Date: Ta Wave ndant C??. :pry u lV I l :. en CHRISTOPHER D. HAVENS, Plaintiff V. TAMI A. HAVENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99-3658 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 19 Pa.C.S. section 4904 relating to unswom falsification to authorities. ?? I-? Date CID CTa A. Haven , e ndant cli ILI i C- Cn t-: J: CJ