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Home My WebLink About03-3340LISA EVANS, Plaintiff VS. DANIEL A. EVANS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVILTERM : CIVIL ACTiON--LAW . : 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 proceed without you and a decree in 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 the 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 at the Cumberland County Courthouse, High and Hanover Streets, 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 TIlE 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 LISA EVANS, Plaintiff VS. DANIEL A. EVANS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~..~- ,.~,.~t4~ CIVIL TERM CIVIL ACTION--LAW IN DIVORCE COMPLAINT IN DIVORCE t. Plaintiff is Lisa Evans, who currently resides at 446 W. Main Street, Walnut Bottom, Cumberland County, PA 17266. 2. Defendant is Daniel A. Evans, who currently resides at 57 Austin Drive, Grantville, Dauphin County, PA 17028. 3. Plaintiff and defendant have been bona fide residents in the Coramonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on September 6, 2002 at Carlisle, Cumberland County, PA. There have been no prior actions of divorce or f:)r annulment between the parties. 6. 7. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that plaintiff may have the right to require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Law Office of James K. Jones, Esquire D~re ~ Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities, LISA EVANS, Plaintiff VS. DANIEL A. EVANS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. CIVIL TERM : : CIVIL ACTION--LAW : : : IN DIVORCE CERTIFICATE OF SERVICE I, Dirk E. Berry, Esquire, do hereby certify that on this day Plaintiff's Complaint in Divorce was served by Certified Mail, return receipt requested, and First Class Mail upon the following persons: Daniel A. Evans 57 Austin Drive Grantville, PA 17028 Date: 7- [( - 0 ~ // ( ~'~-~"~' /'Y~ '~ Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 LISA EVANS, Plaintiff DANIEL A. EVANS, Defendant : IN THE COURT OF COMMONPLEAS OF i CUMBERLAND COUNTY,PENNSYLVANiA : NO. 03-3340 CIVIL TERM : : CIVIL ACTION--LAW .' : : IN DIVORCE PROOF OF SERVICE · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt your name and address on the reveme 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. A~ticle Addressed to: PS Form 3811, Mamh 2001 ~mestic Return R~eipt A. Received by (P/ease Print ~ C. Signature r-i Agent [] Addressee s de~h'e~ eddress different from item 1 ? []Yes f YES, enter delivery address below: I-I No LISA EVANS Plaintiff VS. DANIEL A. EVANS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNT~, PENNSYLVANIA CIVIL DIVISION NO. 03-3340 CIVIL TERM 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 §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mail, restricted delivery served on July 14, 2003. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: byplaintiffNovember 13, 2003 ; by defendant October 31, 2003 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention '~o file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with theProthonotary: /[/~,,'~.,-,5,,.,- ,2/: ,~ oo ~ Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: /]/~ v'~,,., 5~-t,-- ,~ l~ ~ O ~3 IN THE COURT OF COMMON PLEAS LISA EVANS Plaintiff OFCUMBERLANDCOUNTY STATE OF ~ PENNA. VERSUS DANIEL A. ~VAN~ Defendant N O. 03-3340 DECREE IN DIVORCE aNd NOW, ~5~,~,~,_~ DECREED THAT Lisa Evans AND Daniel A. ARE DIVORCED FROM THE BONDS OF MATRIMONY. ~ ~--O~.~ It IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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