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Home My WebLink About99-04340^-r--• _? i 1 I r .? ;` ?5 ?5 ?. ?.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OOLLEEN W. THOMAS , Plaintiff VERSUS CEMMES J. THCMA,S JR Defendant No. 99-4340 Civil Term DECREE IN DIVORCE A 7: S0/& AM 9 AND NOW, IT IS ORDERED AND DECREED THAT COLLEEN W. THOMAS PLAINTIFF, AND CHARLES J. THOMAS, JR. DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OFTHE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE BY U T: ZATT?Er PROTHONOTARY STATE OF - PEN NA. ?/afoi I"r/ eel ?..?,a,? -,o-t 4 f'.al, //. 7/o ee ,moo & lill COLLEEN W. THOMAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - DIVORCE CHARLES J. THOMAS, JR., NO. 99-4340 Civil Term Defendant PRAECIPE TO TRANSMIT RECORD 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: certified mail, restricted delivery, received on July 22, 1999; 3. Complete either (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff on March 14, 2001; by the Defendant on March 1, 2001. (b) (1) Date of Execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: n/a (b) (2) Date of service of the Plaintiff's affidavit upon the Defendant: n/a 4. Related claims pending: All related matters have been settled pursuant to agreement of parties dated 3/01/01. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: n/a 6. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached if decree is to be entered under section 3301(c) of the Divorce Code: n/a OR, date of execution of Waiver of Notice of Intent: Plaintiff executed waiver on March 14, 2001; Defendant executed waiver on March 1, 2001; AND date of filing of Waiver: Plaintiff's waiver filed contemporaneously herewith. Defendant's waiver filed March 6, 2001. Atto ey for Plaintiff IN COLLEEN W. THOMAS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL DIVISION - LAW CHARLES J. THOMAS, JR., : NO. 99 - 4I3yD 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 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 Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 COLLEEN W. THOMAS, Plaintiff V. CHARLES 1 THOMAS, JR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99 -oy3NO CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, Colleen W. Thomas, is an adult individual currently residing at 715 F. Mt. Airy Road, Lewisberry, York County, Pennsylvania. 2. Defendant, Charles J. Thomas, Jr., is an adult individual currently residing at 227 Putter's Circle, Dillsburg, York County, Pennsylvania. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been for at least six months prior to the commencement of this action. Furthermore, Defendant has resided in Cumberland County continuously for at least six months prior to the commencement of this action. 4. The Parties were married on June 11, 1988, in Camp Hill, Cumberland County, Pennsylvania. 5. The parties are citizens of the United States of America. 6. In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7. There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 8. 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. Knowing this, Plaintiff does not desire the Court to require the parties to participate in counseling. 9. Plaintiff desires a divorce and it is believed that Defendant will after ninety (90) days from the date of service of this Complaint consent to this divorce. WHEREFORE, the Plaintiff requests your Honorable Court to enter a Decree in Divorce under Section 3301(c) of the Domestic Relations Code. DATED: 4 Respectfully submitted, Thomas S. Diehl, Esquire Attorney for the Plaintiff 401 E. Louther Street, Suite 103 Carlisle PA, 17013 (717) 240-0833 (717) 249-2407 - FAX VERIFICATION I verify that the statements made in this Divorce 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. COLLEEN W. TH AS ' n 2 nt vi "J COLLEEN W. THOMAS, Plaintiff VS. CHARLES J. THOMAS, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL DIVISION - LAW IN DIVORCE NO. 99-4340 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 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. 1 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 unsworn falsification to authorities. Dated: 3-141-fi/??2?0?, ad COLLEEN W.THOMAS WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to Lne entry of a final decree of divorce without notice. 2. 1 understand that i may lose rights concerning alimony, division of property, lay^ yers 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 unsworn falsification to aut orities. Dated: 94-6/ C LLEEN W. THOMAS, Plaintiff I COLLEEN W. THOMAS, Plaintiff VS. CHARLES J. THOMAS, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL DIVISION - LAW IN DIVORCE NO. 99-4340 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 16, 1999. 2. The marriage of Plaintiff and (90) days have elapsed from the date of filing and service of the and ninety Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice o 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 unsworn fal ific Tonto uth 'ties. Dated: /?,fC HARLES J. 11 HOMAS, o . 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. 1 understand that I may lose rights concerning alimony, division ( property, lawyers 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. Section 4904 relating to unsworn falsification to ho it' s. Dated: /'1G ch ?00? ARLES J. T OMAS, JR., efendant -jwIC1 v V, 100Z I? 833 93AI3031?. COLLEEN W. THOMAS, Plaintiff V. CHARLES J. THOMAS, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99-4340 CIVIL TERM IN DIVORCE AND NOW, this 26s day of July, 1999, comes Thomas S. Diehl, Esquire, Attomey for Plaintiff, Colleen W. Thomas, and states that he perspnally mailed a certified copy of the Divorce Complaint to the Defendant, Charles J. Thomas, Jr., at 227 Putter's Circle, Dillsburg, York County, Pennsylvania by certified mail, return receipt requested. A copy of said receipt i hereto indicating service was made on July 22, 1999. 1 Attorney for Plaintiff 401 East Louther Street Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249- 2407 - FAX a v °c. c mp? t7 a Z A19 067 239 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mall (See inverse nt to Es J THOMAS JR SIme18 Nu mber 227 PUTTER'S CIRCLE Post arcs, Swe, a nP code D Postage $ .55 Cenined Fee 1.40 Special Delivery Fee Restricted Deyve."' 75 Return Re' pl whom 9Het live .?15 ReMn to Dale, e? TOTA P a &F Poe o BENDER: ¦ Comports aeme i andfor2 or eddtlo" aerviota . C0010taa lame 3. w, and 4b, I also wish to receive the following o services (for an P r name and edaeea on f ,,,= of set form wow we an return a" extra f»): e ogym I yo uu ¦A aa d r C6m to the front of tN mallpiece, or on are bark a space does not 1.13 Addresses's Address p m y ? : ? •ReN Rm Raeelpf Requestmeon awmatu Iwe below an aNde number. 5. ?'Rtelr(ded DelYerJr'? ?:e ecelpr win aww o whom Ige ankle was deiverod and to date deUnred. consult postmaster for fee. 6 9. ANde Addressed to: 4a Article Number CHARLES J THOMAS JR Z 339 067 239 227 PUTTER'S CIRCLE 4b. Service Type ? Registered 8$Cedflled DILLSBURG PA 17019 ? Express Mall ? Insured $e ? Return A 1forMe ? COD ?" RjY I rl(vtR`) 7.0efesr, / By, do e. Atldre se's Address Only If requested = and lee Is paid) k0. affe (Address or enf) A PS Form 3811. December 1994 Imes."aa o Domestic Return Receipt ?, ?: r: .. ? ??;,. ?? ?,; ?T - ?- , f- q C` ._ , - ?J . ` ;l •- Gl U COLLEEN W. THOMAS, Plaintiff VS. CHARLES J. THOMAS, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4340 IN DIVORCE PRAECIPE TO WITHDRAW AND ENTER APPEARANCE TO: PROTHONOTARY Please withdraw my appearance as counsel for Colleen W. Thomas in the above-captioned matter/ DATE: omas S. Diehl, Esquire 401 East Louther Street Suite 103 Carlisle, PA 17013 (717) 240-0833 Please enter my appearance as counsel for Colleen W. Thomas in the above-captioned matter. DATE : 12L?.G.t9 5 _ Step en K. Portko, Esquire Supreme Court I.D. #34538 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 r• :c.,? ,. ? : ? .i