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HomeMy WebLinkAbout99-04954'?; ;a u ;,,y ;:+r1 sib .. ,,, y? : a •'li ?? '. ` sl,.) . a'. ::c:P,l4 ? ? {;. . ? N , e; ;: a ? qtY . 1 ? ?'. ?.. Lr 'T t??' F ?'a ?? . '' ).h: ,?, sLt ? .. f.ls`v 5 ? ? . ?'?'4 h; _'j'2, `sb uLf ,.:=1. i1 fp' ; !V t :? li?. 1 i?1 IN THE COURT OF COMMON PLEAS JENNIFER M. MARTIN Plaintiff VERSUS JOSHUA C. MARTIN Defendant OF CUMBERLAND COUNTY STATE OF _ PENNA. N O. 99-4954 DECREE IN DIVORCE AND NOW,_.. ho IT IS ORDERED AND DECREED THAT JENNIFER M. MARTIN PLAINTIFF, AND JOSHUA C. MARTIN 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 I BY THE COURT: L? ATTEST: I PROTHONOTARY ? ?? ? .si?? ?? ??, ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER M. MARTIN, Plaintiff V. JOSHUA C. MARTIN, Defendant CIVIL ACTION - DIVORCE DOCKET NO. 99- ?-/9SI-/ l./vt I - ?) 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 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 One Courthouse Square Carlisle, PA 17013 Telephone No. 717-240-6195 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 AFORD ONE, GO TO OR TELEPHONE THE OFFICES SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. If you cannot afford a lawyer, contact: Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 Telephone Nos. 717-766-8475 or 717-243-9400 If You do not have a lawyer, contact: Lawyer Referral Service Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Telephone No. 717-240-6200 Jennifer M. Martin Pro Se 233 Marlette Drive Mechanicsburg, PA 17055 Telephone No. 717-766-1836 1 -2- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER M. MARTIN, Plaintiff V. JOSHUA C. MARTIN, Defendant CIVIL ACTION - DIVORCE DOCKET NO. 99• y9YV e,;d ?«-- COMPLAINT UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. Plaintiff is Jennifer M. Martin, who currently resides at 233 Marlette Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, since July 26, 1999. 2. Defendant is Joshua C. Martin, who currently resides at 186 Holiday Avenue, Cumberland County, Pennsylvania 17055, since August 14, 1999. 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 October 26, 1996, at Shiremanstown, Cumberland County, Pennsylvania 17011. 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 request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of 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. § 4904, relating to unsworn falsification to authorities. ??. n CGS\A? Ott Jen fifer A tin, Plaintiff Pro Se Dated: August U . 1999 -2- ??-- ? J ?? ? nn .?? ? u F- v' ? V U Gj •?-,. u: ?! ? Q u ?i?; N ?? "J '' 8 ?` `° ? ? ?i q' o ?? C? ? ?; ? ? ? F? Q t ? \ O o? ? v? U JENNIFER M. MARTIN, Plaintiff V. JOSHUA C. MARTIN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4954 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary, Sir: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: By personal service, Acceptance of Service signed August 16, 1999, and previously filed with the Office of the Prothonotary. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff, January 22, 2000; by defendant, January 22, 2000. 4. Related claims pending: None. 5. Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: January 20, 2000 ? IFER M. ARTIN, PROSE Dated: ??VSM? 2000 c? u n: rr { , CS AI ? ' Ir ' LL n j ?J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER M. MARTIN, CIVIL ACTION - DIVORCE Plaintiff V. DOCKET NO. 1999-04954 JOSHUA C. MARTIN, Defendant ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce, in which I am the Defendant as set forth in the above caption. &L-C Ak Joshu C. Martin Defendant Dated: ? 1 d C ?? N O Q 4C>, "' ua per,, n? ` 4i ? ( cL2' `?f "' G:7 CT] 6. ?c z F JENNIFER M. MARTIN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JOSHUA C. MARTIN, NO. 99-4954 Defendant IN DIVORCE AFFIDAVIT OF CONSENT L A complaint in divorce under § 3301(c) of the Divorce Code was filed on August 16, 1999. 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 correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S 4904 relating to unswom falsification to authorities. Dated: wrt 4 2000 Y`t\ '- J IFER . MARTIN, PLAINTIFF N JENNIFER M. MARTIN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW JOSHUA C. MARTIN, : NO. 99-4954 Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 3301(C) OF THE DIVORCE CODE 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 individually after it is filed with the prothonotary. I verify that the statements made in this false statements herein are made subject to unworn falsification to authorities. affidavit are true and correct. I understand that the penalties of 18 Pa.C.S. § 4904 relating to Dated: MLU- \ , 2000 ? ''' \?;N?nl Arm J fifer Martin C C, F- Ci? N 1.1 I O" CV .. (ll 1-.• 1 ? 1- may' JENNIFER M. MARTIN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JOSHUA C. MARTIN, NO. 99-4954 Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on August 16, 1999. 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 correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S. § 4904 relating to unworn falsification to authorities. Dated: 2-21-60 2000 l JOSHUA C. MARTIN, DEFENDANT ?::; ?. JENNIFER M. MARTIN, Plaintiff V. JOSHUA C. MARTIN. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIV-1L ACTION - LAW NO. 99-4954 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(C) OF THE DIVORCE CODE 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. 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. § 4904 relating to unsworn falsification to authorities. Dated: 2 -2 2000 aJWr,,- r J HU A C. MARTIN, DEFENDANT - ?:, _ ._ ;. ?._ - JENNIFER M. MARTIN. Plaintiff V. JOSHUA C. MARTIN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4954 IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Jennifer M. Martin, Plaintiff, being duly sworn according to law, deposes and says that she makes this affidavit and that she knows of her own personal knowledge, and therefore avers, that Defendant, Joshua C. Martin is 27years of age; that his place of residence is 625 Thrush Court, Mechanicsburg, Cumberland County, PA 17055, that he is employed by The Boli Factory, as an Assistant Manager, with his place of employment at 50 West Main Street, Mechanicsburg, Pennsylvania 17055; and that he is not in the military service of the United States or its allies, or otherwise subject to provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940, and its amendments, 50 U.S.C. § 501, et seg. I verify that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. By: h.. , ?.?? . Prin ed Name: Jennifer M. Martin Dated: t -0. . a 1 2000 _?` ; _ ? : _.. J A ??\ IN THE COURT OF COMMON PLEAS OFCUMBERLANED COUNTY STATE OF PENNA. it ?,a,.• ti JENNIFER M. MARTIN r4 II p, 99-4954 Plainti ff VERSUS JOSHUA C. MARTIN Defendant DECREE IN DIVORCE AND NOW, DECREED THAT JENNIFER M. MARTIN AND JOSHUA C. MARTIN ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , PLAINTIFF, ,DEFENDANT, 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; BY THE COURT: ATTEST: J. PROTHONOTARY is Martin 233 Marlette Drive Wecbanicsburg, PA 17055 FUSA,, Joshua C Martin 625 Thrush Curt Mechanicsburg, PA 17055 t: 1 .:r i Martin 233 Marlette Drive Mecbanicsburg, PA 17055 *USAH F t?CW?Wn Jennifer M. Martin 233 Marlette Drive Mechanicsburg, PA 17055 t