HomeMy WebLinkAbout03-3318
BROCK A. LASHER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. (?J J:3/ t5
ACTION IN DIVORCE
Civil Term
JAMI M.. LASHER,
Defendant
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.
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
32 South Bedford St.
Carlisle, Pa. 17013
(717) 249-3166
BROCK A. LASHER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 0:3 - .3 3 I t? Civil Term
ACTION IN DIVORCE
JAMI M. LASHER,
Defendant
COMPLAINT IN DIVORCE
1. Plaintiff is Brock A. Lasher, a competent adult individual, who has resided at 110
Meadowbrook Road, Carlisle, Pa. 17013, since 1998.
2. Defendant is Jami M. Lasher, a competent adult individual, who has resided at 110
Meadowbrook Road, since 2002.
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 in August 2002 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 one child together, namely, Zach D. Lasher, date of birth,
2-11-2002.
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.
Respectfully submitted,
Date: -; I (
65
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e Adams, Esquire
. No. 79465
3 South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
VERIFICATION
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 unsworn
falsification to authorities.
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Brock A. Lasher, Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
; No. 0 -~ -"3 ~ \ 8'" Civil Term
BROCK A. LASHER,
Plaintiff
JAMI M. LASHER,
: ACTION IN DIVORCE
Defendant
AFFIDAVIT OF SERVICE
AND NOW, this July 2 I, 2003, I, Jane Adams, Esquire, hereby certify that
on or about July 17, 2003, a certified true copy of the NOTICE TO DEFEND and CUSTODY
COMPLAINT was served, via certified mail, return receipt requested, addressed to:
Jami Lasher
58 Garden Parkway
Carlisle, Pa. 17013
DEFENDANT
Respectfully Submitted:
an dams, Esquire
l.D No. 79465
36 outh Pitt Street
lisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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SENDER" COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
JOV\'\- '[ L__ct'S l.er-
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TION ON DELIVERY
'ill.
o Agent
Addressee
C. Date of Delivery
s delivery adtlress different from item 1? 0 Yes
If YES, enter defivmy address below: 0 No
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3. Service Type
Cortifjod Moil
RegIote<ed
o Insured Mail
CI Express Mail
o Return Receipt for Merchandise
o C.O.D.
Jilt.'
4. Restricted Delivery? (Extra Fee)
2. Article Number
(Transfer from service label)
PS Form 3811. August 2001
7002 2410 OD07 8500 9797
102595-D2-M.0835
......
Domestic Return Receipt
UNITED STATES POSTAL SER
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JANE ADAMS
ATTORNEY AT LAW
,.~~ S. PITT STREET
.....LISLE. PA 17013
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BROCK A. LASHER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 3318
Civil Term
JAMI M. LASHER,
ACTION IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
l. A complaint in divorce under section 330I(c) of the Divorce Cod,~ was filed on July 11,2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the 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 also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date: I [-, r ~ g-. 0 (,/
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER 63301(c) AND 63301(d) OF THE DIVORCE CODE
1. ] consent to 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: (b' ~ g- . 0 1
. yn. ~(~
ami M. Lasher, Defendant
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BROCK A. LASHER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 3318
Civil Tenn
JAMI M. LASHER,
ACTION IN DIVORCE
Defendant
AFFIDA VI'LPXCQNS.ENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on July 11,2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed fro the
date ofthe 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 en ry of
the decree.
1 verifY that the statements made in this affidavit a,e true and correct. I also understand that false
statements herein are made subject to the penalties of 1 g Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date: It' . ~ ~. O~!
.i~
J m i M. Lasher, Defendant
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER 63301(<) AND 63301(d) OF THE DIVORCE CODE
1. ] consent to 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 expe ses
if I do not claim them before a divorce is granted.
3. I understand that 1 will not be divorced until a divorce decree is entered by the Court and that a co 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. ] understand that false statemen s
herein are made subject to the penalties of 1 g Pa.C.S. 94904 relating to unsworn falsification to authorities.
Date: I (} . 9'l f) , 0 '1
. . ,:{(;f1~
am i M. Lasher. Defendant
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BROCK A. LASHER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 3318
Civil Term
JAMI M. LASHER,
ACTION IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 330J(c) of the Divorce Code was filed on July 11, 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed fro the
date of the 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 ent of
the decree.
I verify that the statements made in this affidavit are true and correct. I aiso understand that false
statements herein are made subject to the penalties of] 8 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date:
, i -;)d -U(
Br~~0C-
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER &330I(c) AND &330I(d) OF THE DIVORCE CODE
J. I consent to 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 expens s
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 f
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. [understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities.
Date:
\1- dd-OY
4~~~ ~
Bro(;-A. Lasher, Plamtiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
D3 - 3)IP
: No. 04 3795 Civil Term
BROCK A. LASHER
Plaintiff
JAMI M. LASHER,
: ACTION IN DIVORCE
Defendant
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information to the Court for entry of
divorce decree:
l. Ground for divorce: irretrievable breakdown under &3301(c) of the Divorce Code.
2. Date and manner of the service of the Complaint: Delivered by certified mail.
restricted deliverv. return receipt requested on: July 17,2003.
3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Co e:
By Plaintiff:
November 22, 2004.
By Defendant:
October 28, 2004.
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: November I, 2004
Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: December 1,2004.
Date: f ~-- {-- 0'1
J e Adams, Esquire
.D. No. 79465
36 S. Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEA
OF CUMBERLAND COUNTY
PENNA.
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STATE OF
Brock A. Lasher, Plaintiff
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No. 03 - 3318
Civil Ie
NO.
VERSUS
Jami M. Lasher, Defendant
DECREE IN
DIVORCE
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~()~, IT IS ORDERE
AND NOW,
Brock A. Lasher
DECREED THAT
. PLAINTIFF,
Jami M. Lasher
AND
, DEFENDAN
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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AND
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA
YET BEEN ENTERED;
None.
By THE COU:? ~
Am. ~
~(p.~
PROTHONOT
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NOT
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