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HomeMy WebLinkAbout99-05479 Fi ye j, r ? lla u x N L My u, n h' r s„ x VI ? t yp! lFi'1y H > tt, ,F d .J . J s r _ a r.? IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF PENNA. No. 99-5479 FRANK J. WREN, III VERSUS SHARI WREN DECREE IN DIVORCE AND NOW, P*A,:,t ds-, 11 IT IS ORDERED AND DECREED THAT Frank J. Wren, III , PLAINTIFF, AND Shari Wren 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; ARY has-? ? C,4 11 FRANK J. WREN III., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-5479 SHARI WREN, CIVIL ACTION-LAW Defendant DIVORCE 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. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on September 17, 1999 by accepting personal service. 3. (a) Date of execution of the Plaintiff's Affidavit of Consent: 2/24/2000; Defendant's Affidavit of Consent: 1/28/2000. 4. Related claims pending: None. 5. Date of filing of Plaintiffs Waiver of Notice: 3/10/00. Date of filing of Defendant's Waiver of Notice: 2/23/00. Refectfully submitted, Emily Long Hoffman, Esquire Sup. Ct. ID # 66307 105 North Front Street Harrisburg, PA 17108 (717)233-1112 Date: 4/20/00 I ' C? '?C 1 ./ ` .J lJ FRANK J. WREN III., Plaintiff SHARI WREN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. No. q9 -5479 Cjt oTerM CIVIL ACTION-LAW DIVORCE You have been sued in Court. If you wish to defend against 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 the Court may enter a Decree of Divorce or annulment against you. 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. When the ground for divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, 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, Pennsylvania 17013 (717) 240-6200 Le han demandado a usted en Is torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de lag fecha de la demands y ]a notificacion. Usted debe presenter una apariencia escrita o en persona o por abagado y archival en la cone en fora escrita sus defenses o sus objections a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o ostros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABAGADO INMEDIATAMENTE. SI NO TIENE ABAGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCURENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 240-6200 FRANK J. WREN III., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99- 5479 C,;,j Tern, SHARI WREN, CIVIL ACTION-LAW Defendant DIVORCE 1. Plaintiff is Frank J. Wren III., who has resided at 1670 Cranbury Road, York Springs, PA 17372 since February, 1996. 2. Defendant is Shari Wren, who has resided at 1195 Lindham Court, Mechanicsburg, PA 17055 since April 2, 1999. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 23, 1998. 5. There have been no prior actions of divorce or annulment between the parties. Forces. 6. Neither of the parties in this action is presently a member of the Armed The Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. There are no children born of the marriage. 10. The Plaintiff avers as the grounds on which the action is based that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court: Enter a decree of divorce; Grant such further relief as the Court may deem equitable and just. R ctfully submitted, By: EMILY LO OFFMAN, ESQUIRE Sup. Ct. I.D. # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108-1475 (717) 233-1112 Date: 9?4(ti s. {,z .5M Aug-26-99 12:11P EMILY LONG HOFFMAN 717 234 2234 P.01 AFFIDAVIT Frank .I. Wreu, III, being duly sworn according to law• deposes and says that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of the below referenced party's kuowledFc, information and belirf. Frank 1. Wren, lTl? r ? Date: 91-11o O i a -0 c? 00 0 r Ln o? jag :T+ 3 t FRANK J. WREN III., : IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA No. 99-5479 SHARI WREN, CIVIL ACTION-LAW Defendant DIVORCE A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 8, 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 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: 000 FRANK J. W RIK , III C a ul? i? ?-. .' W Ch Q Fy Cl C. IC: CD - N LL ?!' C iJW F: _ ?J2 U O V FRANK J. WREN III., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 99-5479 SHARI WREN, CIVIL ACTION-LAW Defendant DIVORCE A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 8, 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 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 unworn falsification to authorities. Date: SHARI WREN C C\; '- C\j r"- 4, !:L r-? r_ FRANK J. WREN III., Plaintiff SHARI WREN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 99-5479 CIVIL ACTION-LAW DIVORCE 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. 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. §4904 relating to unworn falsification to authorities. Date: aa)o FRANK J. WIffN, III cS tri U) C7 '] -^ c ? c- ' J c) g ; j C t: C J Z%l LL, O v a4,Q C7 ?O j U FRANK J. WREN III., Plaintiff V. SHARI WREN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-5479 CIVIL ACTION-LAW DIVORCE WAIVER O F NOME OF INTENTION TO ?.FOUFST ENTR 53 Y OF A DIVORCE DECREE UNDER 301(c) OF THE DIVORCE OD 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 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 unsworn falsification to authorities. Date: 7? ZCCD V-W, SHARI WREN r aJ r. cam.. C: J J N ._ ?? LL W :? o FRANK J. WREN III., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-5479 SHARI WREN, CIVIL ACTION-LAW Defendant DIVORCE I, Shari Wren, affirm that I accepted service of the divorce complaint on September, 1117, 1999. ari Wren Date: h-? / N ?i.t I ( -: . ? ..f 1 ' ? ? : . ?, a ?1 i:? ?._ LJ i LAS (3a ?s ss (?9 La 3 sZ vi ,pe s Ss +--z Ivy -UO-FV1 o. i i? c"