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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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j STATE OF PENNA.
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Tracy D. Furry
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Zane D. Furry
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`u. _1999_..._.,. 05.403...... 19
DECREE IN
DIVORCE
AND NOW, ...Te-s7??z.?..Z[....... , tiV.??? o it is ordered and
decreed that . TRACY D.. FURRY .................................. . Plaintiff,
and ....ZANE,D..FURRY ....... ....................... • 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
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is been entered;
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Prothonotary
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Tracy D. Furry, IN THE COURT OF COMMON PLEAS
Plaintiff,
CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL DIVISION
Zane D. Furry, NO. 1999-05403 CIVIL TERM
Defendant,
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 S3301(c)
3130 KMS}m(k of the Divorr.e Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: September 14, 1999
Certified mail, restricted delivery
3. Complete either paragraph (a) or (b).
(a) Date of execution: of the affidavit of consent required
by S3301(c) of the Divorce Code: by plaintiff December 20, 1999
by defendant December 20, 1999
(b)(1) Date of execution of the affidavit required by S3301(d)
of the Divorce Code: _ N/A __; (21 Date of filing and
service of the plaintiff's affidavit upon the respondent: N/A
4. Related claims pending: Resolved through private Agreement
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to
file praecipe to transmit record, a copy of which is attached:
N/A
(b) Date Plaintiff's Waiver of Notice in S3301(c) Divorce was
filed with the Prothonotary: December 22, 1999
Date defendant's Waiver of Notice in S3301(c) Divorce was
filed with the Prothonotary: December 22, 1999
Atto ney for (Plaintiff) (Defendant)
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LAW OFFICES
• WALKER, VANHORN & MACBRIDE, A DIV OF
BARLEY, SNYD8R, SENFT SL COHEN, LLC
217 LINCOLN WAY EAST. CHAMBERSBURO, PENNSYLVANIA 17201
CUMBERLAND COUNTY, PENNSYLVANIA
Tracy D. Furry, 1 Civil Action - Law
Plaintiff, )
1 ?
VS. I No. CC - ) q L"-C Lt L
1
Zane D. Furry, 1
Defendant, 1 In Divorce a v.m.
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 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 Court House, Carlisle, Pennsylvania.
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
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.
8.26.99/M B W /832347.1
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Tracy D. Furry,
VS.
Zane D. Furry,
Plaintiff,
Defendant,
Civil Action - Law
No. Q9. 5"M3 011-( Wr',
In Divorce a v.m.
COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE
1. Plaintiff is Tracy D. Furry, a sui juris adult, who currently resides in
Cumberland County, Pennsylvania, her post office address and residence being, 28
South Washington Street, Shippensburg, Pennsylvania 17257, since March, 1999.
2. Defendant is Zane D. Furry, a sui juris adult, who currently resides in
Cumberland County, Pennsylvania, his post office address and residence being 104
Cleversburg Road, Shippensburg, Pennsylvania 17257, since July, 1998.
3. The Plaintiff and Defendant are husband and wife, they having been married
on May 14, 1994 in Shippensburg, Franklin County, Pennsylvania.
4. Neither the Plaintiff nor Defendant is a minor or incompetent.
5. Plaintiff has lived and resided in the Commonwealth of Pennsylvania for a
period of 28 years, and during the entire 6 months immediately preceding the filing of
the Complaint, she has been a bona fide resident of said Commonwealth continuously
and without interruption.
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. Defendant has lived and resided in the Commonwealth of Pennsylvania for
a period of 33 years, and during the entire 6 months immediately preceding the filing
of the Complaint, he has been a bona fide resident of said Commonwealth
continuously and without interruption.
8.26.991MB W /832347.)
8. There is not now pending nor has there ever been in this or any other state
or jurisdiction any action for divorce or annulment of marriage between the parties
except the action represented by this Complaint.
9. Plaintiff believes and therefore avers that the marriage subsisting between
the parties has been irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a
decree of divorce.
10. The allegations of paragraphs 1 through 8 hereof are incorporated herein
as fully as though set out at large.
11 . In violation of his marriage vows and laws of the Commonwealth, the
Defendant, ZANE D. FURRY, has offered such indignities to the person of the injured
and innocent spouse, the Plaintiff, as to render her condition intolerable and life
burdensome.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a
decree of divorce.
12. The allegations of paragraphs 1 through 8 hereof are incorporated herein
as fully as though set out at large.
13. The parties have been unable to determine and equitably dispose of their
respective rights and interests in the marital property.
14. Plaintiff will, within 60 days after service of this Complaint upon the
Defendant, cause to be filed an inventory and appraisement of all property owned or
possessed at the time this Complaint is filed.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide,
distribute and assign the marital property pursuant to the provisions of Section 3502
of the Divorce Code.
8.26.99/MB W 183 2347.1
15. The allegations of paragraphs 1 through 8 hereof are incorporated herein
as fully as though set out at large.
16. The Plaintiff is without sufficient property to provide for her reasonable
needs, and is unable to adequately support herself.
17. The Plaintiff cannot support and maintain herself in the style she was
maintaining prior to the separation of the Plaintiff and Defendant without continued
financial assistance from the Defendant.
WHEREFORE, pursuant to Section 3701, at seq., of the Divorce Code,
"Alimony", Plaintiff respectfully requests your Honorable Court to order Defendant to
file within 30 days of service of this Complaint upon Defendant, a complete income
and expense statement and to require the scheduling of a hearing to determine
Plaintiff's entitlement to alimony, and if so, the amount.
18. The allegations of paragraphs 1 through 8 hereof are incorporated herein
as fully as though set out at large.
19. The resolution of the issues raised by this Complaint will require Plaintiff
to incur considerable additional expenses and costs.
20. The Plaintiff is without sufficient means to adequately support herself and
to meet the costs and expenses of this litigation and is unable to maintain herself
during the pendency of this action.
21. The Defendant is presently employed at Central Pennsylvania Drywall.
Defendant's exact income is unknown to Plaintiff.
22. The Plaintiff is presently employed at Pharo's Restaurant with a net weekly
income of approximately $300.00.
WHEREFORE, pursuant to Section 3702, at. seq., of the Divorce Code,
"Alimony Pendente Lite, Counsel Fees and Expenses", Plaintiff respectfully requests
your Honorable Court to order Defendant to file within 30 days of service of this
8.26.99/M BW/832347.1
Complaint upon Defendant, a complete income and expense statement, and to require
the scheduling of a hearing to determine Plaintiff's entitlement to alimony pendente
lite, counsel fees and expenses, and if so, the amount.
WALKER, VAN HORN & MACBRIDE,
a division of Barley, Snyder, Senft & Cohen, LLC
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Ma ha B. Walkef, Esquire
At orney for Plaintiff
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. Section 4904 relating to unsworn falsification to authorities.
Date: 7 S
Tracy D. Furr , Plaintiff
8.26.99/M BW/832 347.1
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LAW OFFICES
WALKER, VANHORN & MACBRI DE, A DIV OF
fiBARLEY, SNYDAR, 9ENFT & COHEN, LLC
247 LINCOLN WAY EAST; CNAMBERSBURO, PENNSYLVANIA 17101
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Tracy D. Furry, ) Civil Action - Law
Plaintiff, )
VS. ) No. 1999-05403
Zane D. Furry, )
Defendant, ) In Divorce a v.m.
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF FRANKLIN )
Martha B. Walker, Esquire, being duly sworn according to law, deposes and says
that she is the attorney for the Plaintiff, Tracy D. Furry, in the above-captioned matter; that
she did serve a true and attested copy of the Complaint Under Section 3301(c) or 3301(d)
of the Divorce Code by mailing the same to Zane D. Furry, Defendant, by certified mail,
restricted delivery, article number Z 284 176 307 on September 3, 1999, to his mailing
address of 104 Cleversburg Road, Shippensburg, Pennsylvania 17257; that said certified
mail article was delivered to Defendant, Zane D. Furry, on September 14, 1999, all as
appears from the receipt for certified mail and the return receipt attached hereto.
WALKER, VAN HORN & MACBRIDE,
a division of Barley, Snyder, Senft & Cohen, LLC
By:
Marta B. Walker, Es uire
Atto ney for Plaintiff
Sworn and subscrib d to before me
this G day of )thf , 1999.
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Notary Public
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LAW OFFICES
WALKER, VANH9RN St MACBRIDE,ADIV OF
BARLEY, SNYU7 1%1 SENFT & COHENI LLC ....;
247 LINCOLN WAY EAST, CHAMBEBSBURO. PENNSYLVANIA 17201 r
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Tracy D. Fury, ) Civil Action- Law
Plaintiff, )
vs. ) No. 1999-05403
Zane D. Furry, )
Defendant, ) In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on September 2, 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. Section 4904 relating to unswom
falsification to authorities.
Date: / ? a C)Tracy D. Furry, aintiff
12.14.99IMB W/859953.1
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LAW OFFICES
WALKER. VANHORN & MACBRIDE, A DIV OF
BARLEY, SNYDER, SENFT & COHEN, LLC
24711' o EAST.CHADIEERSBURO.EENNSYLVANIA17201
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Tracy D. Fury, ) Civil Action- Law
Plaintiff, )
VS. ) No. 1999-05403
Zane D. Furry, )
Defendant, ) In Divorce a v.m.
i
M
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 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 immediately after it is filed with the Prothonotary.
I verify that the statements made in this Waiver are true and correct. 1 understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom
falsification to authorities.
Date: I J 91 /
Tracy D. Furry, aintiff
12.14.99/MB W/859953.1
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LAW OFFICES
WALKER,Vf' _.?n7&MACBRtDE.ADIVOF - -
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BARLEY, SNYDER, SENFT (SL COHEN, LLC
717 LINCOLN WAY EAST CHAMBERSBURO. PENNSYLVANIA 17201
CUMBERLAND COUNTY, PENNSYLVANIA
Tracy D. Furry, ) Civil Action - Law
Plaintiff, )
VS. ) No. 1999-05403
Zane D. Furry, )
Defendant, ) 111 Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on September 2, 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. 1 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. 1 understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom
falsification to authorities.
Date: /2 - za - //
Za a D. Furry, De ndant
12.14, 99/M B W /859953.1
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CUMBERLAND COUNTY, PENNSYLVANIA
Tracy D. Furry, ) Civil Action - Law
Plaintiff, )
VS. ) No. 1999-05403
Zane D. Furry, )
Defendant, ) In Divorce a v.m.
s
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WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 330I(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 1 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. Section 4904 relating to unworn
falsification to authorities.
Date:/ 2 -),a - ?Y
LAW OFFICES
' • • WALKER, VANHORN & MACBRIDE, A DIV OF
BARLEY, SNYLER, SENFT & COHEN, LLC
247 LINCOLN WAY EAST, CHAMBERSBURO, PENNSYLVANIA 17201
Z D. Furry, Defendant
12.14.99/M B W/859953.1
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