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HomeMy WebLinkAbout03-3224 MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2003-W!CIVIL TERM DON L. CASEY, Defendant IN DIVORCE NOTICE 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 MARY LYNN CASEY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYL VANIA v. NO. 2003 - 3224 DON L. CASEY Defendant CIVIL ACTION-LAW DEFENDANT'S PETITION FOR JOINDER OF A CLAIM FOR PROPERTY DISTRIBUTION I. This Divorce Action was initiated on July 8, 2003, on the ground that the marriage between the parties is irretrievably broken, 2. On December 22,2003, the Defendant made a motion to the Court for the appointment of a Master with respect to the Distribution of Property, 3, On December 23, 2003, this Court ordered that E, Robert Elicker, Esquire, be appointed Master with respect to the Distribution of Property. 4. Defendant has not as of yet formally joined the claim for Distribution of Property with this action for divorce, 5, Defendant hereby formally joins the claim for Distribution of Property with this action for divorce, WHEREFORE, Defendant requests this Honorable Court to equitably distribute property as is deemed necessary and appropriate. Respe,;tfully submitted, John C. Porter JhS:f~ Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 <:) r: ( ,- :::l'~ -.,.. .~... ~? ..,.. \.D ,- " "" = c.") -""" <- ("- ,:::..,: o ., '-l ~r:- rT1;'J;! -(Irn (-:~9 :::':c; :]-:- -'f; .{'::}{:'~ ~~"fl 0' ~~ AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Defendant 2003- $<;rCIVIL TERM IN DIVORCE DON L. CASEY, COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW comes the Plaintiff, Mary Lynn Casey, by her attorney, Marcus A. McKnight, III, Esquire, and files this Complaint in Divorce against the Defendant, Don L. Casey, representing as follows: I. The Plaintiff is Mary Lynn Casey, an adult individual residing at 1471 Pine Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Don L. Casey, an adult individual residing at 1471 Pine Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on February 14, 1991. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, By: Marcus . McKni Attorney for Plainti West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court LD. No, 25476 Date: July 8, 2003 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Complaint and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ~~k:JN~ Date: July J 2003 MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW 2003- CIVIL TERM DON L. CASEY, Defendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: July 8, 2003 '11&J; !1~A ~ -:'ARY lItJ~.Y Ifjj ~ , '- ~ ~ ~ ~ 1'<:- ~ ~ -c: ~ ~( ~,._, ' '" ~ <:J '^ cj ~ ~ ~ ~ ~. ~ -+-- ~ ,. ~..,- I, ;:. o c-~ . , -( C'::' ~ .......'..j tjc c..> MARY LYNN CASEY PLAINTIFF v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DON L. CASEY DEFENDANT 03-3224 CIVIL ACTION - LAW IN DIVORCE Certificate of Service I, John C. Porter, Counsel for the Defendant, Don L. Casey, hereby certifY that true and correct copies of the Defendant's Request to Plaintiffto Produce Docwnents Pursuant to Pa. R.C.P. 1930.5 and Pa. R.C.P. 4009.11 in the above captioned case was served to the Counsel of Record for the Plaintiff, Mary Lynn Casey in the following manner: First Class Prepaid Postage to Marcus A. McKnight, III, Esquire West Pomfret Professional Building 60 West Pomfret Street Carlisle, PA 17013 on this <J +\,. day of January, 2004. )~l::fJk- Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, P A 17013 717-249-1177 "-> c;,;) .;-,:;) ~- <- :;,.. z o -,-, -l :r: rn:!J r- -.....m -;'9 ~~o f":5~ ~::;r'n ~:~-1 N -"":1 C,,) ,,'- (]j .... MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2003-3224 CIVIL TERM DON L. CASEY, Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: // /;/ , 2004 'i2-;:( C DONL. CAY (., r--.> ) c~ =, 0 ,:..;.~ :, _c.... -n '-::} "L : ::;~: .-1 f', : C" i1~ --r'o ...~: .;~ UI -'.1 ,.7 C ~~"~ (S '.. -,,>~ ~~1 ~~ \ .. .. ~.l (.:.~ :.~:. "") ._..1 .. :::1 -( ..::- :~J <..n -< MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2003-3224 CIVIL TERM DON L. CASEY, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 8, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: 1/ //; , 2004 7J~;;:: ~ DON~ :t:~ ~;~ :~ ~""....... I" .I ~:; l"'..) e,::::. C':::) ".;" - C=l -~ <..J1 -0 1") .r.;- <II o 'T1 :~ n:iff~ -':1 ell ::)1. ') ()/, ":'\"~ ~i'~ ~'n () , )rn . ~;.\ .I:-" ::9 MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2003-3224 CIVIL TERM DON L. CASEY, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1/ ~I , 2004 'D---?! ~ DON L. CASEY ./ Defendant .. :;2 ",~ ~~..., q ':'"::".? , -,- ~ x- l I , ~,. ::::1 ...'..... " (;'::') ~" ! - "'-If,,:: r; 'I ::n I"'" .. ~(J frl Ul ,'J CJ ,- qcL, " " :r"], " :' ......::-.'.. U r"-) , .c- 0; MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2003-32:24 CIVIL TERM DON L. CASEY, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OFiCONSENT 1. A Complaint in Divorce under Section 3301(c) of the: Divorce Code was filed on July 8, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 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 made are subject to the penalties of ~8 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. , 2004 /.1'"., V Date: November 30 0 "'-> c:::> 0 C = .on ~:~ .r- ''''Jr~,1 I:::' -I 111 r:' f"T'l III Z .~~:.J ('"'? rnp XI. I -om (f) }, :00 _.?- It. 01 r;:: C', --\0 ""t.~ ,,"-, > ~r: :n o~~ (~) :t: 0-- .,.0 .)-" c.~ 'D 1') rn ~::t Z ~ =<! N N -< MARY LYNN CASEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2003-32:24 CIVIL TERM DON L. CASEY, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECRE~ lUNDER SECTION 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 grant1ed. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: November 30 , 2004 0 "" c:::::> ~ C <::::) ~~ ..r:- ""D i"r'i 0 :Ti L1J i:';"~ P.l -- "T1 ..... ('") rnp''' ~::;; I -a? U) :JJ. -<. 0 ~C 'iQ ~~~~,; J':'lOo {5~~ ~: ;""=I'n \..0 ,j "-- "1~ :.:< N :I.J N -< MARY LYNN CASEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 03 - 3224 CIV~L DON L. CASEY, Defendant IN DIVORCE ORDER OF COURT AND NOW, this I /4f- day of 2005, the economic claims raised in the proceed ngs having been resolved in accordance with a marriage settleme t agreement dated October 28, 2004, the appointment of the aster is vacated and counsel can file a praecipe transmi ting the record to the Court requesting a final decree in divor e. BY THE COUR , Geo cc: Marcus A. McKnight, III Attorney for Plaintiff (I~J L{> L/'eJ r L John C. Porter Attorney for Defendant \')\ l~\\ ' y.1, '.)' .' ~ ;,\~;\i " ", ll)':Il \.... 1....<.\',,; ,.\ j...J , ' - ?~~~~~~~~+~~~~~~ ~+~~~~~~~~~+~+~+~+~+~+~+~+~+~+~+~+~+~+~+~~~~~~~~+~~~~~~~~~~~~ , , , , . . . . . . . . . . . . . . . , . , , , . . . . . . . . . . . . . . . . . , , , . . . , . . , . , , . , . . , . , . , . . , , , , , , , , , , , , , , , , . . . . . . . . . . . . . . . . . . . . . . :+'+ ~ ~ ~ . . , . . . . . . . . , . . . . . . . . . . . . . . , . . , . . , . . , . . , . . . . . . , , . . , , . , , , , , . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , , ,., 't'''' 't' 'to; 't' + '+',., + '+' ++ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MARY LYNN CASEY, No. 2003-3224 CIVIL TERM Plaintiff CIVIL ACTION - LAW VERSUS DON L. CASEY, IN DIVORCE Defendant DECREE IN DIVORCE ~ /3 -~.;l.' ~7/.M. ~s , IT IS ORDERED AND AND NOW, MARY LYNN CASEY DECREED THAT , PLAINTIFF, DON L. CASEY AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURfSDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The Marriage Settlement Agreement dated October 28, 2004 and signed by the arties is hereb incor orat to t is Divorce but not mer ed. PROTHONOTARY T: ATTEST: ~+~ + ~ ~ ,., ,.,+,., ,., "''t'''' ,., ++,., ,.,++ + ++++++ J. _"I ~,c 1. i~)1_ ijL l' 'l'/f"YJ' ""'f> \it" .~ rr-; />J)"1f. ,r"'" IV It".c1 I'7r"' n({' . i"{' qJO( If I' -' ",..' , , ..