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Home My WebLink About99-04981???, . . t'r _Y_ ? ;°ik I:Cf j, :;;e3 va 1 'i i ? ! ?G ?.ll;i?; d.7sfi. '.!G:,4' '?.i' 1+ h ;, v' "ro x ;:: N wt . 5. 4 ,?1? N ? ``" r: ? ? a' Q ?Q ,?. V ??. 'S.; ;, ,,? ? ??? ' T ` 4j ,•k ??. S? . j3 ?^e ?, 5. j^?n . 'N ??y . ..?y. ,. , {S S ', ?e?' 'n • Y . 3' .. ? ` •'Y • ?` i.. ti i i fi s F -5re -5* I IN . Civil. ......... 1 No . ...... 4981 ... .......... < 99 . . DECREE IN I VORCE't 01o?01 AND NOW, 0:4*# ... .... 1.... , 1M., it is ordered and Max A. McCombs decreed that .................................................. plaintiff, and . . . . . . . . . . . Bs.atri. .. . . co.. H.. M.cCamba . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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; ....................r a.. 1..... .. ........................ 5", P• J. honotary j ,we, !w7 rw. ,W. -W1 :t• •W.• 1W 0 •A, •x• :V? {?? Li: {A•?{?: :ir {?7: _.LE ^C W. Qr- - ? tiW• THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF'C? PENNA. ,.., r e i ..•t MAX A. McCOMBS, Plaintiff VS. BEATRICE H. McCOMBS, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 99 - 4981 Civil Term ACTION IN DIVORCE 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(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail restricted delivery. ret,?m re?i?t?attested. delivered on An= 20 1999 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff- August 16 1999, Date of filing and service of the plaintiffs affidavit required by §3301(d) of the Divorce Code on respondent: Filed: . mgust 17. 1999, Served on Defendant: August 20. 1999, 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: September 10. 1999. via certified mail restricted deli_verv. Respectfully Submitted: Date: ?? . tl c7 c/ I e Adams, Esquire .D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 Attorney for Plaintiff MAX A. McCOMBS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 99 - 4981 Civil Term .> 'o BEATRICE H. McCOMBS, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE BY CERTIFIED MAIL AND NOW, this September 14, 1999, I, Jane Adams, Esquire, hereby certify that on or about September 10, 1999, a true and correct copy of the Plaintiff's Notice of Intent to Request Divorce Decree and Counter-Affidavit were served, via certified mail, return receipt requested, addressed to: Beatrice McCombs 9 Richland Lane Apt 105 Camp Hill, Pa. 17011 Respectfully Submitted: an Adams, Esquire o. 79465 11 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF SENDER.- I also wish to receive the Canpl.to Item 1 .nNw x br addtleW eevlme. • C0A1a'u Itmu 3 k end 46• ex W' p services (for an Y«rotyeyywptntfeams and We.N e1 ow reverse of ells e,,, w low lq MINIYIIINI BXIra Ise. •paApe?Mae to er front of fynWlpNoe, oronthabadtaspecedo«mt 1 13 Addreasee'a Address - The W N ReoWR an Me MI 00a below dw W#do number. HOWICUd,DWVa?/., attye? ?t VwAJU to w the ankN was de vemd eq tM due ConauM 3. Aside Addressed to: Postmaster for fee. 4JArtIcIs 33mbet I Q? ?ce {?'Ic CdyyJ?S C? /n? // 4b. Service Type ( RifG47lGtM G/ /b T1 6S ' ? Registered '?Cer9Red,. /D ., rn ?y // 70// ? Ezpreea Mail ? Insured $' l..(? r" ( 13 ReNm Recelpl for Marchendlee ? CCD r _7:n / /L^ n 7. Date of Delivery arM na a dress eOrAgery Q 11, December 1994 } >- L, Ln wu F fi J . r. r r If r ii C U ? U MAX A. McCOMBS, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 9F - .S/ 9P I Out.( l /Ll. BEATRICE H. McCOMBS, ACTION IN DIVORCE Defendant NOTICE TO DEFEND AND AIM 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 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 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 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 MAX A. McCOMBS, Plaintiff VS. BEATRICE H. McCOMBS, Defendant : M THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 99• V ?9 -l eu?-e ?,,? ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Max A. McCombs, an adult individual, who has resided at 8 Richland Lane, Apt TI, Camp Hill, 17011, since 1991. 2. Defendant is Beatrice H. McCombs, an adult individual, who has resided at 9 Richland Lane, Apt 105, Camp Hill, Pa. 17011, since 1991. 3. Plaintiff and 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 April 22, 1954 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and 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 Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests 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. §4904 relating to unworn falsification to authorities. Max A. McCombs, Plaintiff Respectfully submitted, Date: 111 l are Adams, Esquire I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF a PIN Q K r, 43 n, 1 Cn cn 0 X ? - MAX A. McCOMBS, Plaintiff VS. BEATRICE H. MCCOMBS, Defendant M THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 4981 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SEMI CE BY FRTIFI D MAIL AND NOW, this August 24, 1999, 1, Jane Adams, Esquire, hereby certify that on August 20, 1999, a true and correct copy of the Plaintiffs Notice to Defend and Complaint were served, via certified mail, return receipt requested, addressed to: Beatrice McCombs 9 Richland Lane Apt 105 Camp Hill, Pa. 17011 Respectfully Submitted: 01a,(A -- ne Adams, Esquire .D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?- t5 UJ ?; N i l=3 f LL LIn L'1 G ll LL i`](1.. F U ? Iq - MAX A. MCCOMBS, Plaintiff VS. BEATRICE H. MCCOMBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 4981 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED MAIL AND NOW, this September 14, 1999, I, Jane Adams, Esquire, hereby certify that on or about September 10, 1999, a true and correct copy of the Plaintiff's Notice of Intent to Request Divorce Decree and Counter-Affidavit were served, via certified mail, return receipt requested, addressed to: Beatrice McCombs 9 Richland Lane Apt 105 Camp Hill, Pa. 17011 Respectfully Submitted: an Adams, Esquire o. 79465 11 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF f. r ( f; r L r J , ._. ?' 1 f_? G'. It . C ? .? r C>1 ?, MAX A. McCOMBS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. Q 4f^ '</?'!? t_/uc BEATRICE H. MCCOMBS, : ACTION IN DIVORCE Defendant 1. The parties to this action separated in 1961 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 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 are made subject to the penalties of 18 Pa.C.S. ¢4904 relating to unworn falsification to authorities. Date: `6 q5 ?? Q, 7L??' C?? M A. Combs, Plaintiff ?- N U iVE a f5_ F ? ` i ° SENDER: • Compete hems l and/or 2 for additional serAou. I also Wleh to receive the e Comorb hems 3,4a, and 4b. e Print tyoyutplname end address an the Card a Ahem Mp tm t a t t f 10110Win g services for an extra too): n ' m o nd ron o a* mellplAwAMeba 1 b?/ 1. Addressee s Address ' ppaamJ1. e WMe 'Refvm RecW RequaarM'on Me ma e NBnEm Remlpt WIII slaw W vmwn ma a m r, to 2?Restricted Delivery l tl e Consult postmaster for fee. 3. Artlde Atldlress?ed to: / / 4a. Article Number S. f?7Y (iO /? q D / I (J?.?O f?er>7y t HFf ?FSrD) SS. Receive By: (Pont Name) Bigna : (A ressee or '.x M4 e B PS F6ah'J811. December 1994 is 41). Service Type '? Registered Certified ? Express Mail Insured g ? Return Racelpt for Merchandise ? COD 7. Dale of slivery -A0- B. Addressee's Atltlress (Onl 11 requested ' and too 1s paid) 5 05-9seaz2s Domestic Retum Receipt ?H i I r t l r M j MAX A. McCOMBS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 4981 Civil Term 1999 BEATRICE H. McCOMBS, ACTION IN DIVORCE Defendant TS2: Beatrice H. McCombs 9 Richland Lane, Apt 105 Camp Hill, Pa. 17011 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the Plaintiff's Complaint. Therefore, on or after September 30, 1999 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE, 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 MAX A. MCCOMBS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND cot N"I'Y,PI?NNSYI.VANIA vs. No. 4981 ('i\'il'I'crm 1999 BEATRICE H. MCCOMRS• ACTION IN DIVOIZ(11 Defendant COUNTER-AFFIDAVIT UNDER &;;01(d) nF T iF DIVOR F ODF 1. Check either (a) or (b): - (a) I do not oppose the entry ol'a divorce decree. (b) I oppose the entry of a divorce decree because (Cheek 0). 00 or both): (i)The parties to this action have not lived separate and apan Im- a period ol'at least nvo years. 00 The marriage is not irretrievably broken. 2. Check either (a) or (h): __ (a) I do not wish to make any claims tin economic relief. I understand that I may lose rights concerning alimony, division of property, la%tver's lies or expenses if 1 do not claim them before a divorce is granted. (b) I wish to claim economic relief %vhich ntay include alimony. division of property, latsyer'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. 111 I fail to do so belbre Utc date set firnh on the Notice of Intention to Request Divorce Decree, the divorce decree may be emered without further delay. I verify that the statements made in this counter-aliidavit are true and correct. I understand that false statements herein are made subject it, the penalt authorities ies of 18 I'a.C.S. X4904 relating to unsworn I-alsifcalion to . Date: Rcatr ice I I. McCombs, Defendant IF YOU DO NOT W ISH TO OPPOSE, THE ENTRY OF A DIVORCE DECREE, AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RF.LII?F, YOtI SIIOIII.D NOT FILE: THIS COUNTER- .AFFInA)'19'. MAX A. McCOMBS, Plaintiff VS. BEATRICE H. McCOMBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 4981 Civil Term : ACTION IN DIVORCE fA n 11? 1 l I AND NOW, this September 14,1999, 1, Jane Adams, Esquire, hereby certify that on or about September 10, 1999, a true and correct copy of the P:aintiff's Notice of intent to Request Divorce Decree and Counter Affidavit were served, via certified mail, return receipt requested, addressed to: Beatrice McCombs 9 Richland Lane Apt 105 Camp Hill, Pa. 17011 Respectfully Submitted: an Adams, Esquire o. 79465 11 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF SENDER: • C•eWbN e,m, r endor for xedauarw„rNOe,, I also wish to receive the ??? s,rn, ?' ~• .Fm? .E2 2• following sentlcss (for an ..r name UiOG.u on tlw nvxwaeb lam utlW w?nn return nY a dbyyoouu pr h . s%be fee): ed,)am to er front or .p dw msOplm, a on the bak e.p.o, doe, not 1 13 Add reee9B'e AddKle w RM R - ea R :The d cR"".dm "' Dl ,w ", t. WW e,.?.n. wu dd$Uv w.?nd m.? w' "?Heetrlaed DwNeN 3. ANGe Addressed to: Consult postmaster for lee. , -- ??e // ¢c2 ?cComIS, Arti33mbe01 r ' 06 Ep /Q? - , Ct? 4 ?Yl c/ /'V / ?'t;?') " ? l P?/ 4b. Service Type ? Registered Certified / /pp ?? / ? / v1 . l.Ee/Yl IIJ?? P/7 ??D// 13 Express Mall 13 Insured ?' , •• O Radun Realpt for Merchandise ? CCD AI 1_ j n 1-- 1) 7. Date of Delivery end /as Is paid) PS ro 11, December 1994 rouso-psaozxs w o r; Cc l4 ` rl MAX A. McCOMBS, Plaintiff vs. BEATRICE H. MCCOMBS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 4981 Civil Term. ACTION IN DIVORCE AFFIDAVIT OF NON-MILITA N-MILITARV SERVICE Plaintiff, Max McCombs, hereby deposes and says that he is the Plaintiff in the above. captioned matter; that she personally knows that Beatrice McCombs, Defendant, is over the age of 18 years; and that she currently lives in Camp Hill, Pennsylvania. Plaintiff further avers that Defendant is not in the Military Service or in any branch of the Armed Forces of the United States or its Allies or otherwise within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress of 1940 and its Amendment. Plaintiff verifies that the statements made in this Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unworn falsification to authorities. Max McCombs, Plaintiff cv? W S co ? S ? 4 O m ON U