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HomeMy WebLinkAbout03-3133KENT G. PALMER, Plaintiff VS. LORETTA A. PALMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ~)~' 3~3 Civil Term ACTION 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. Where thc ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 KENT G. PALMER, Plaintiff VS. LORETTA A. PALMER, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ~51~ ' '~]~'~ Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Kent G. Palmer, a competent adult individual, who has resided at 55 South Bedford St., Carlisle, Cumberland County, Pennsylvania, since 1996. 2. Defendant is Loretta A, Palmer, a competent adult individual, who has resided in Loysville, Perry County, Pennsylvania, since 1989. 3. Plaintiffand Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 13, 1976 in Blain, Perry County, Pennsylvania. 5. There have been no prior actions ofdivome or for annulment between the parties. 6. Plaintiffhas 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. 7. Plaintiffand Defendant have two children together. 8, Plaintiffand Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiffavers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to enter a decree in 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. 84904 relating to unswom falsification to authorities. Kent G. Palmer, Plaintiff Date: Respectfully submitted, 2Ilffie Adams, Esquire .~I.D. No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF KENT G. PALMER, Plaintiff VS. LORETTA A. PALMER, Defendant : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. t~3- ~1~3 CivilTerm : ACTION IN DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated in January 1991 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Kent G. Palmer, Plaintiff KENT G. PALMER, Plaintiff VS. LORETTA A. PALMER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03-3133 Civil Term : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE REGARDING THE COMPLAINT IN DIVORCE AND AFFIDAVIT OF SEPARATION AND NOW, this July 15, 2003, I, Jane Adams, Esquire, hereby certify that on June 13, 2003, a certified tree copy of the NOTICE TO DEFEND, COMPLAINT iN DIVORCE, and AFFIDAVIT OF SEPARATION were served, via certified mail, return receipt requested, addressed to: Loretta A. Palmer Rt 1 Box 156A Loysville, Pa. 17047 DEFENDANT Respectfully Submitted: J~dams, Esquire //I.D. ~qo. 79465 ( 369$6uth Pitt Street "-L~arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF I I ,LL L,~ .-I Postage& Fe~s Paid I ADAMS ATTOR~ AT ~W · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Ar[icle Addressed to: A. S' ature 3. Received by(Printed~.Name) I C, Date of De~iv~ If YES, enter delive~ address below: ~ No 3. Service Type ~[)Certified MAil [] Express Mail [] R~ [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) ~ 2. Article Number (Transfer from service label) PS Form 3811, August 2001 7002 2410 0007 8500 9780 Domestic Return Receipt 102595-02-M-0835 KENT G. PALMER, Plaintiff VS. LORETTA A. PALMER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 03o3133 Civil Term ACTION 1N DIVORCE AMENDED AFFIDAVIT OF SERVICE REGARDING THE COMPLAINT IN DIVORCE AND AFFIDAVIT OF SEPARATION AND NOW, this July 21, 2003, I, Jane Adams, Esquire, hereby certi~ that on July 14, 2003, a certified true copy of the NOTICE TO DEFEND, COMPLAINT IN DIVORCE, and AFFIDAVIT OF SEPARATION were served, via certified mail, return receipt requested, addressed to: Loretta A. Palmer Rt 1 Box 156A Loysville, Pa. 17047 DEFENDANT Respectfully Submitted: (717) 245-8508 ATTORNEY FOR PLAINTIFF · Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. · Print your name and address on the mveme so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. [] Agent [~A~ld ressee D. Is delivery address different from Item 17 ~ If YES, enter delivery address below: [] No POGo 3. Service Type ,~i~ertlfled Mail [] Express MaLl [] R~ [] Return Receipt for Merchandise [] Insured Mall [] C.O.D. 4. Restricted Delivery? (Extra F~e) ~'es ~r~,~?er?romse,~cel~bel) 7002 2410 0007 8500 9760 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-0835 KENT G. PALMER, VS. Plaintiff LORETTA A. PALMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COI~ITy, PENNSYLVANIA No. 03-3133 CivilTerm ACTION IN DIVORCE _PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Carol J. Lindsay, Esquire, Esquire as Attorney of record for Defendant, Loretta A. Palmer. Date: Respectfully Submitted: Carol J. Lihd~ay,flEsquire ] ID. No. ~ - d 26 W. High St. Carlisle, Pa. 17013 (717) 243-6:!22 ATTORNEY FOR DEFENDANT KENT G. PALMER, vs. Plaintiff LORETTA A. PALMER, Defendant : IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : No. 03-3133 CivilTerrn : : ACTION IN DIVORCE : COUNTER-AFFIDAViT UNDER §3301[d) OF H~E DIVORCE CODE. 1. Check either (a) or (b): ~(a) l do not o ose the -- PP entry of a divorce decree. __ (b) 1 oppose the entry ora divorce decree because (Check (i), (ii) or both): __ (i) The parties to this action have not lived separate and apart for a period of at least two years. __ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ~(a) 1 do not wish to m -- a~e any c aims for economic relief. I understand that I may lose rights concerning alimony, division of property, l ' . is granted, awyer s fees or expenses :rf I do not claim them before a divorce __ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so befbre the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are tree 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. '-~ ~oretta A. Palmer,~efendan~'~~ IF YOU DO NOT WISII TO OPPOSE TIlE ENTRY OF A DIVORCE i) WISH TO MAKE ANY CLAIM FO ~c,c~,t~,~ ........ ECREE, AND YOU DO NOT COUNTER-AFFIDAVIT· ' '-',-, orlL~ULD NOT FILE THIS KENT G. PALMER, Plaintiff VS. LORETTA A. PALMER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03-3133 Civil Term : : ACTION 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO RI~QUEST E~Ry OF A DIVORCE DECREE UNDER §330I(c) AND §3301~1'~) OF THENCE CODF, 1. I consent to 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 ifI 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 unsworn faisification to authorities. Date: /O '/' ~._..~ Loretta A. Palmer, Defendant KENT G. PALMER, Plaintiff VS. LORETTA A. PALMER, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 03-3133 Civil Term : : ACTION IN DIVORCE : .WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE ~JNDER §3301(c) AND §3301(d) OF THE DIVORCE CODE 1. I consent to 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 ifI 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 unsworn falsification to authorities. Date: //9 '~, 0 f Kent G. Palmer, Defendant KENT G. PALMER, Plaintiff : IN THE COURT OF 'COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. LORETTA A. PALMER, Defendant No. 03-3133 CivilTerm ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORB TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery, return receipt requested, delivered on: July 14, 2003. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff: July 1,2003. Date of filing and service of the plaintiffs affidavit of separation required by §330 l(d) of the Divorce Code on respondent: Filed: July 2, 2003. Served on Defendant: July 14, 2003, certified, restricted, with complaint. Affidavit of Service filed: July 21, 2003. 4. Related claims pending: No claims raised. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: .Waivers of Notice and a Counter-Affidavit are attached to this Praecipe. Date: s..~pect fullyt~-[k~mitt e d: /J~ X~lam~:, ~squire / [.q. No. 79465 k 36 Pi. st. ~lisle, Pa. 17013 (717) 245-8508 ARomey for Plaintiff KENT 0. PALMER, Plaintiff VS. LORETT,4. A. PALMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-3133 CivilTerm : : ACTION IN DIVORCE _.WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE _UNDER §3301(c) AND §3301(d) OF THE DIVORCE COD]~; 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning aiimony, division of property, lawyer's fees or expenses ifI 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 concect. 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: Kent G. Paimer, Defendant KENT G. PALMER, VS. Plaintiff LORETTA A. PALMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03 - 3133 CivilTerm ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION _TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(e) AND §3301(d) OF THE IHVORCE CODE 1. I consent to entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 afl:er 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 F'a.C.S. §4904 relating to unswom falsification to authorities. Date: /() ./. ~._.~ KENT G. PALMER, Plaintiff 1N THE COURT OF COMMON PLEAS CUMBERLAND COIINTY, PENNSYLVANIA vs. : No. 03-3133 CivilTerm : LORETTA A. PALMER, : ACTION IN DIVORCE Defendant : COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE ( ) (b) 1. Check either a or : --- ' __ I do not oppose the entry of a divorce decree. __ (b) I oppose the ent*y of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. __ (ii) The marriage is not irrethevably broken. 2. Check either (a) or (b): ~((a) I do not wish to make any claims for economic relief. 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. __ (b) I wish to claim economic relinf which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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. '~--~Loret/a A. Palmer, Defendant IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE, AND YOU DO NOT WISH TO MAKE ANY CLAIi~I FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~~ PENNA. Kent G. Palmer, Plaintiff No. 03 - 3133 Civil Term NO. VERSUS Loretta A. Palmer, Defendant DECREE IN DIVORCE AND NOW, Kent G. Palmer DECREED THAT Loretta A. Palmer AND ,¢?~, E)O~, IT IS ORDERED AND , PLAINTIFF, , 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. BY THE COURT: ~/~ /~ ~TARY