HomeMy WebLinkAbout99-04569
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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WHITTEN 11
ELLY M._
?1u.,99-,,4.569„•,CIVIL..TERM
...........Plaintiff... ?
Versus
PAUL D. WHITTEN
... ....Defendant
DECREE IN
DI VORCE
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.............
AND NOW .. . . . . . . . . . . . t9 ....... it is ordered and
decreed that ........ Kelly. ,M.. Whitten ....................... plaintiff,
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an ..... Pau•1 .D,. Whitten ................................... defendant,
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are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
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been raised of record in this action for which a final order has not yet
been entered;
None
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By T e _ Ct
Attest: ? J
Prothonotary ? °•'
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KELLY M. WHITTEN,
Plaintiff
vs.
PAUL D. WHITTEN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 99-4569 CIVILTERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
Ground for divorce:
Irretrievable breakdown under §3301(c)
)MIOCIVIX"abMO im
(Strike out inapplicable section).
2. Date and manner of service of the complaint: Acceptance of service a Ftnahy
Defendant's attorney on July 30, 1999.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code:
by plaintiff 10/12/00 ; bydefendant 10/14/00
(b) (1) Date of execution of the affidavit required by §3301(d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
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:
(b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: 10/13/00
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: 10/18/00
itorney for Plaintiff ift
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James K. Jones, Esquire
7 Irvine Row
Carlisle, PA 17013-3019
(717) 240-0296
KELLY M. WHITTEN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 9?-y,56e CIVIL TERM
vs.
CIVILACTION--LAW
PAUL D. WHITTEN,
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 in 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 Prothonatary at the Cumberland County Courthouse, High
and Hanover 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
KELLY M. WHITTEN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL TERM
VS.
CIVIL ACTION--LAW
PAUL D. WHITTEN,
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is KELLY M. WHITTEN, who currently resides at 37 Regency South,
Carlisle, Cumberland County, Pennsylvania.
2. Defendant is PAUL D. WHITTEN, who currently resides at 621 Willow Grove
Road, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and defendant have been bona fide residents in the Commonwealth for
at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on June 03, 1989 at Carlisle,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that plaintiff may
have the right to require the parties to participate in counseling.
8. Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
e
Jai}Jbs'K. Jones, Wire
Attorney for Plaintiff
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
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.
'KELLY 'M. WHITTEN
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.i '.Y M. WHITTEN, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V.
NO. 99-4569 CIVIL TERM
CIVIL ACTION--LAW
?:JL D. WHIT-TEN,
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301 (c) of the Divorce Code was filed on July 28,
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
CO'tRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
."L BJECT TO PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
KELLY W. WHITTEN
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KELLY M. WHITTEN, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V.
NO. 99-4569 CIVIL TERM
CIVIL ACTION--LAW
i t.tJL D. WHITTEN,
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
:s 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
.irid 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.
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KELLY WHITTEN
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KELLY M. WHITTEN, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
NO. 99-4569 CIVIL TERM
V.
CIVIL ACTION--LAW
PAUL D. WHITTEN,
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on July 28,
1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
:lapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree in divorce after service of notice of intention to
r:grest 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 UNSWORN
FALSIFICATION TO AUTHORITIES.
nATE:
P UL D. WHITTEN
KELLY M. WHITTEN, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
NO. 99-4569 CIVIL TERM
V.
CIVIL ACTION--LAW
PAUL D. WHITTEN,
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 UNSWORN
FALSIFICATION TO AUTHORITIES.
DATE: ID'i?/'a? ?• `1-?
P L D. WHITTEN
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KELLY M. WHITTEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO. T9- y5-69CIVIL TERM
Vs.
CIVIL ACTION- - LAW
PAUL D. WHITTEN ,
Defendant : IN DIVORCE
I accept service of the Complaint in Divorce on behalf of Defendant and certify
that I am authorized to do so.
L30
Date Matthew E e , Esquire
Law Offices of Pa t& F. Lauer, Jr.
2108 Market St.
Camp Hill, PA 17011
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®'RI(IIINAL
i:ELLY M. WHITTEN, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
NO. 99-4569 CIVIL TERM
V.
CIVIL ACTION--LAW
"AUL D. WHITTEN,
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on July 28,
1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
:lapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree in divorce after service of notice of intention to
r:grest 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 UNSWORN
FALSIFICATION TO AUTHORITIES.
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KELLY M. WHITTEN, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V.
NO. 99-4569 CIVIL TERM
CIVIL ACTION--LAW
PAUL D. WHITTEN,
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
:utd 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: /!t ?- &(
P L D. WHITTEN
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KELLY M. WHITTEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO. Tq- ys6?cIVIL TERM
vs.
CIVIL ACTION- - LAW
PAUL D. WHITTEN,
Defendant : IN DIVORCE
I accept service of the Complaint in Divorce on behalf of Defendant and certify
that I am authorized to do so.
-7 L30 99
Date *Officees Esquire
k F. Lauer, Jr.
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Camp Hill, PA 17011
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