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Home My WebLink About03-3255GREGORY D. FULLER, Plaintiff VI. LETITIA A. FULLER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM 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 w'[thout 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 fights 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 marfiage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 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, PA 17013 (717)249-3166 or (800)990-9108 Xfirl Nl~,edebohm, Esquire / Supreme Cou~ ~ 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 GREGORY D. FULLER, Plaintiff V. LETITIA A. FULLER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0~- 3~5'~' CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiffis Gregory D. Fuller, who currently resides at 879 Hawthorne Avenue, Cumberland County, Mechanicsburg, Pennsylvania 17055-5730. 2. Defendant is Letitia A. Fuller, who currently resides at 879 Hawthorne Avenue, Cumberland County, Mechanicsburg, Pennsylvania 17055-5730. 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 May 3, 1992 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court may require the parties to participate in counseling. Having ~been so advised, Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Res e tu mitt /d{arlflVI(~ Ledebohm, Esquire J Supreme Court ID 59012 PDBox 173 New Cumberland, PA 17070-0173 (717)938-6929 VEI~-i~C.~TION 1, Ore~ory D, Fullor, the Plaintiffin the foregoing pleading, hereby vori£y that the statemmts made in the foregoing pleading ~re true and eorroat to tho boat of' my information knowledge and belief I'understand that ~ls¢ statements are made subject to the penalties of 18 Pa, C.S.A, Section 490~, t~lating to unsworn falsification to authorities. Fuller GREGORY D. FULLER, Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA LETITIA A. FULLER Defendant CIVIL ACTION .- LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Letitia A. Fuller, the defendant in the above captioned matter, hereby accept service of the Complaint in Divorce filed in the above captioned matter this _ iO ~ day of July 2003. tla A. Fuller JENNIFER BRINTON, Plaintiff WILLIAM L. BRINTON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3225 IN CUSTODY ORDER AND NOW, this l ! ~' day of tq?aeo.~ ~.~ ~^"~ in consideration of the attached Stipulation Regarding Custody and Visitation, it .... ' is hereby ordered that: 1. M°ther and Father will share legai custody of the clfild as defined in 23 Pa. C.SA. §5302. Ail decisions affecting the child's growth and including but not limited to medical treatment, education, and religious training, are major decision which Mother and Father shall make jointly after discussion and consultation with each other. 2. As provided in 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the child's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. 3. Mother shall have primary physical custody of child subject to periods of visitation with the Father. 4. Father, during his week off during work, shall have five (5) consecutive days with child a month. Also, Father shall have visitation with child one (1) weekend a month. 5. Father may also have additional time with child, as long as; he provides 48 hours notice to Mother. 6. Mother and Father shall mutually agree upon the holidays. The parties shall have reasonable telephone and e-mail contact with the child while the child is in the other's custody. 7. Neither party shall make any disparaging remarks regarding the other party in the presence of the child. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the child. 8. Any modification or waiver of any of the provisions of this Agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the Agreement of the parties. 9. The parties hereto acknowledge that they have had the opportunity to consult an attorney prior to executing this Agreement. Mother's attorney is Michael J. Whare, Esquire. If Father does not seek the advice of an attorney, he does so knowingly and voluntarily. 10. The parties hereto agree that this Agreement shall be recorded and incorporated into an Order enforceable by the Court. BY THE COURT: Distribution: Jacqueline Vemey, Esquire Michael J. Whare, Esquire William L. Brinton GREGORY D FULLER, Plaintiff V LETITIA A. FULLER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 03-3255 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1 A complaint in divorce under section 3301(c) of the Divorce Code was filed on July 10, 2003. 2. The marriage of the plaintiff and the 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. Section 4904 relating to unsworn falsification to authorities Date: GREGORY D. FULLER, Plaintiff VI. LETITIA A. FULLER Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3255 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301{c) & (d) OF THE DIVORCE CODE ]. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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. Section 4904 relating to unsworn falsification to authorities. Date: Gr~go~ I~. Fuller GREGORY D. FULLER, Plaintiff VS. LETITIA A. FULLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-3255 IN DIVORCE _AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 10 July 2003 and served upon the Defendant on or about 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 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, Date GREGORY D. FULLER, Plaintiff VS, LETITIA A. FULLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-3255 IN DIVORCE _WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE COD! 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date '"I~E.T~'TIA A. FI.~I' ER' ' GREGORY D. FULLER, Plaintiff LETITIA A. FULLER Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-3255 Civil Term : 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: irretrievable breakdown under section 3301(c) of the Divorce Code. Date and manner of service of the complaint: Complaint served upon the defendant on July 10, 2003. Acceptance of service signed July 10, 2003 and filed on August 12, 2003. ' Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: by Plaintiff on 10/24/03 and filed simultaneously herewith; by Defendant 6n 10/24/03 and filed simultaneously herewith. (a) Date Plaintiff's Waiver of Notice was flied with the prothonotary: Waiver of Notice was signed on 10/24/03 and filed simultaneously herewith. (b) Date Defendant's Walver of Notice was filed with the prothonotary: Waiver of Notice was signed on 10/24/03 and flied simultaneously herewith. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 IN THE COURT OF COiVlMON OFCUMBERLANDCOUNTY STATE OF ¢~~ PENNA. GREGORY D. FULLER PLAINTIFF VERSUS LETITIA A. FULLER DEFENDANT NO. I)~-3255 PLEAS DECREE IN DIVORCE AND N OW,~__ DECREED THAT ~n~v D.FULLER , PLAINTIFF, AND LETITIA A. FULLER ,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 BY THE COURT: ***** ............... PROTHONOTARY