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HomeMy WebLinkAbout99-03674 0 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. i i i i i i THERESA YVONNE MORRILL, Plaintiff ve15U5 EDWIN THEODORE MORRILL, Defendant N t ?. 99-3674 CIVIL Icy DECREE IN D?I VORCE AND NOW, ... .J . , • • • , 19!%9 .... it is ordered and decreed that Theresa Yvonne Morrill plaintiff, Edwin TheodoreMorrill and ........................................................ . 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 .................................................. ....................... . .......................... .. J/................. is i? ? y i• $ Attest: J. j Prothonotary I ??. err. +a• •x• :?• •a?• c?• ca te• :?• •w• :a te:• •:?. •:e:• <e:• <e: ?:e:• •:e:• <eh..,s:• <e• •s:• te:?•:e• •:e• tr.• .;c• .y; ,; zo THERESA YVONNE MORRILL, PLAINTIFF V. EDWIN THEODORE MORRILL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMSERIAND COUNTY, PENNSYLVANIA NO. 99 - 3674 CIVIL TERM IN DIVORCE To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complain': On June 16, 1999, by United States Mail. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, September 25, 1999; By Defendant, September 25, 1999. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary on September 30, 1999. Date Defendant's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary on September 30, 1999. Thomas D. Gould, Esquire Attorney For Plaintiff r r• Z- r' N '•f , -, ?-' cn U THERESA YVONNE MORRILL, PLAINTIFF V. EDWIN THEODORE MORRILL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 CIVIL TERM 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 THERESA YVONNE MORRILL, PLAINTIFF V. EDWIN THEODORE MORRILL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 36 ZY CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Theresa Yvonne Morrill who resides at 415 W. Keller Street, Apartment 2-F, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is Edwin Theodore Morrill who resides at 3041 Liverpool Court, Chambersburg, Franklin County, Pennsylvania 17201. 3. The Plaintiff and Defendant have been bonafide 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 June 27, 1997 in Franklin County, Pennsylvania. 5. 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. 7. The Defendant is not. a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff has been advised of the availability of counseling 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. ID. >C1? Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 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 unsworn falsification to authorities. 1 Date: Theresa onne Morrill c! r. J ci i 1.11 Q V i I I tti S t j_ www • I o1 • I? d l 0 3 ty id E ?E to 1 V ato items t anNOr 2 for additional services. I also Wish tc . eceive the ate items 3, 4a, and 4b. following seaAces (for an our name and address on the reverse of this form so that we can return this ou. extra fee): t is loam to the trend of the mailpieca, or on the back if space does not 1.13 Addressee's Address R0turn Receipt RWuesfed'on the mailuece Imlow the onRle number. turn Receipt will show 10 whom the admle was d li d 2. [R Restricted Delivery e vere and the date >a. Consult postmaster for fee. e Addressed to: 4a. Anlcle N umber U6V11*1 T. /fln?r, 1 3o y 1 COLA,,r C66A6-f t U e- PA 1720 t 5. Received By: g Cft in s. Sig atur o a PS Form 3811, O7 Z SLY W 7 Service Ty To. pe 5 ? Registered Certified w ? Express Mail ? Insured M c Lg-lalurn Receipt for Merchandise 1111 COD 7. Date I D five s. Addr asses S Address (Only it requested T and lee is paid) Y c w I' 1 t I i THERESA YVONNE MORRILL, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 3674 CIVIL TERM EDWIN THEODORE MORRILL, IN DIVORCE DEFENDANT AFFIDAVIT 0 RVS F I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on June 17, 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 postal return receipt attached hereto, the Complaint was received by the Defendant on June 19, 1999. -Aow-w D. d Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 Y Y l_ l :l V7 IJ Vi c _I cn U THERESA YVONNE MORRILL, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 3674 CIVIL TERM EDWIN THEODORE MORRILL, IN DIVORCE DEFENDANT AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 17, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. 4. 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. 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. Section 4904 relating to unsworn falsification to authorities. DATED: ?f C c r I -_I CL ?! U U THERESA YVONNE MORRILL, PLAINTIFF V. EDWIN THEODORE MORRILL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLMD COUNTY, PENNSYLVANIA NO. 99 - 3674 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE Cnnv 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: S t r, t, 1 LL. n V: ?' cn J THERESA YVONNE MORRILL, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 3674 CIVIL TERM EDWIN THEODORE MORRILL, IN DIVORCE DEFENDANT AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 17, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. 4. 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. 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. Section 4904 relating to unsworn falsification to authorities. DATED: LLUM?I?J73 o-,,u C.1 Edwin Theodore Morrill ?, - r, `. c U THERESA YVONNE MORRILL, PLAINTIFF V. EDWIN THEODORE MORRILL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 3674 CIVIL TERM IN DIVORCE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Z Z-5 Edwin Theodore Morrill r E- ?r ?? i` Gam: `.:f. "7 _;: t Jy r ?? J ?? i _ ? L ? C ._ U t 1/ I t J =_ ?i ?_, : i i t?C_ ii'. ? IJ U3 I=- r` U CJ U'