HomeMy WebLinkAbout99-05149
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF .? PENNA.
PHYL IS MARIAN LONG,
N O. 1999-05149
Plaintiff
VERSUS
ELWOOD HURLEY LONG
Defendant
DECREE IN
PROTHONOTARY
DIVORCE 5: 2?
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PHYLLIS T(1NC PLAINTIFF,
AND FLWOOD ""`Y LONG DEFENDANT,
AND NOW, IT IS ORDERED AND
DECREED THAT
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;
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PHYLLIS MARIAN LONG,
Plaintiff
VS.
ELWOOD HURLEY LONG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-05149
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the Record, together with the following information, to the Court
for entry of a divorce decree:
1. Ground for divorce: Irretrievably broken under Section (X) 3301(c) or
( ) 3301 (d) of the Divorce Code. (Check applicable section)
2. Date and manner of service of the Complaint in Divorce: By certified
mail on September 13, 1999.
3. [Complete either Paragraph (a) or (b).]
(a) Date of execution of Affidavit of Consent required by Section
3301(c) of the Divorce Code by Plaintiff, January 5, 2002; by
Defendant, January 5, 2002.
(b) Date of execution of Plaintiff's affidavit required by Section 3301
(d) of the Divorce Code: N/A; Date of service of Plaintiff's
affidavit upon Defendant: N/A.
4. Date of service of Notice of Intent to Finalize under Section 3301(d) of
the Divorce Code: N/A; Date of filing of Waiver of Notice of Intent to
Finalize by Plaintiff: Simultaneously herewith; by Defendant:
Simultaneously herewith.
5. Related Claims Pending: None
BY:
Diane M. Rupich, s4uire
1017 North F t Street
Harrisburg, PA 17102
(717) 232-9724
Attorney for (x) Plaintiff
( ) Defendant
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PHYLLIS MARIAN LONG, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. g, 1999 - -j /'/ if
ELWOOD HERLEY LONG, CIVIL ACTION - LAW
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 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.
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
1-800-990-9108
PHYLLIS MARIAN LONG,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 1999 - 5/9'9 ee. ?-c""'
ELWOOD HERLEY LONG,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPI AINI IN DIVORCE UNDER SFCTION 3301 (g) F THE
DIVORCE OD
L The Plaintiff is Phyllis Marian Long, an adult individual, who currently resides
at 402 Beaver Avenue, Enola, Cumberland County, Pennsylvania and whose social
security number is 198-22-8954.
2.
3.
The Defendant, Elwood Herley Long, is an adult individual, who currently
resides at 402 Beaver Avenue, Enola, Cumberland County, Pennsylvania
17025, and whose social security number is 166-20-4960.
Plaintiff and Defendant were married on January 11, 1948 in Sunbury,
Pennsylvania.
4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for
a period of at least six (6) months prior to this filing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
6. Plaintiff and Defendant are both citizens of the United State.
7. There has been no prior action for divorce filed in any jurisdiction.
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There are four adult children born of this marriage.
-2-
10. Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable
Court to grant a Decree in Divorce.
Respectfully submitted,
BY:
1017 North Froi
Harrisburg, PA
(717) 232-9724
I.D. No. 71873
Street
17102
-3-
DILS & RUPICH
VERIF 1.AT ION
verify that the statements made in this COMPLAINT IN DIVORCE
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.
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DATE: MARIAN LONG
AucusT 20. 1999 s
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PHYLLIS MARIAN LONG,
Plaintiff
VS.
ELWOOD HURLEY LONG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-05149
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public, in and for said
Commonwealth and County, Diane M. Rupich, Esquire, who being duly sworn
deposes and says that a true and correct copy of the Complaint in Divorce under
Section 3301(c) of the Divorce Code has been served upon the Defendant, Elwood
Hurley Long, 402 Beaver Avenue, Enola, Cumberland County, Pennsylvania
16925, by First Class, United States Mail, Certified No. Z 569 114 155.
Attached hereto is the return receipt card executed by Elwood Herley Long,
dated September 13, 1999, evidencing receipt of the same.
Swom and subscribed to
before me this _7y-l-_ day
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of2002.
Notarv Public
NOTARW-SM
DORA A FIKE, No',ary I%: Io
G8 of rcuphin county
Mry omm!uicn Expires Oct 24, 2005
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SENDER:
• •C pMe seen 3.?W b. des.
•Pdrd your name and address on the mvele9 of twe form ec Mat wo can relun
and to Wu.
Alison We form to the front of the mellgea, Of on to beck a Spam dose not
e evJdb Relum Receipt Requested' on the mallgea below tM adkM wNw..
-S slhe Relum Recall will 1111000 to whom the erode was delivered and the dale
delivered.
3. ANcle Atdreesed to:
. Received By: pff, J
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e B. N19 M)(AWrong a orAge tJ
S PS Form 3811, December 1994
I also wish to receive the
following services (for an
extra tee):
1. ? Addressee's Address
2.19 Restricted Delivery
Consult postmaster for fee.
Registered
Express Mal
Return Receipt
18-0111
and fag Is paid)
? Insured
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PHYLLIS MARIAN LONG, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 1999-05149
ELWOOD HERLEY LONG, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on August 24, 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. I consent to the entry of a final Decree in 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 made herein are made subject to the penalties of
18 Pa. C.S. §4904, relating to unsworn falsification to authorities.
Date: .E'?c;799. c,
Phyllil4Marian Long, aintiff
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PHYLLIS MARIAN LONG,
Plaintiff
vs.
ELWOOD HERLEY I.ONG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-05149
CIVIL ACTION - LAW
IN DIVORCE
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 in 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.
1 verify that the statements made in this Vl'aiver 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: / - -5-- C,1-
Phy is Marian Long, laintiff
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PHYLLIS MARIAN LONG, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 1999-05149
ELWOOD HERLEY LONG, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on August 24, 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. I consent to the entry of a final Decree in 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 made herein are made subject to the penalties of
18 Pa. C.S. §4904, relating to unsworn falsification to authorities.
Date: /o L (a &= Ccr' x r t
Elwood Herley Long, Defend
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PHYLLIS MARIAN LONG,
Plaintiff
vs.
ELWOOD HERLEY LONG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-05149
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301(e) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree in 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 Waiver 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:
Elwood Herley Long, Defe t