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HomeMy WebLinkAbout99-05836I IN THE COURT OF COMMON PLEAS Raymond S. Thompson Plaintiff VERSUS Defendant N 0. 99-5836 DECREE IN DIVORCE AND NOW,F?/.. _2000 , IT IS ORDERED AND DECREED THAT Raymond S. Thompson PLAINTIFF, ANDDebra D. 'Thompson , 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; BY THE OURTT: ATTE OTHONOTARY OFCUMBERLAND COUNTY STATE OF PENNA. ?? I7"? LIL?' C-LQ/Ly /27?-CC../ ?, t2,/? ?CG?Gtrsc.l d n"o? ?/?l?i fha,,/?'s' ? G? 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA RAYMOND S. THOMPSON, : No. 99-5836 Plaintiff VS. Civil Action - Law : In Divorce DEBRA D.THOMPSON, 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; Ground for divorce; irretrievable breakdown under 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on September 23, 1999, and was accepted September 25, 1999. An acceptance of service was filed on October 1, 1999. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff 2/1/00; by Defendant 2/1/00. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice in Section 3301(c) was signed on 2/1/00 and is filed herewith; and Defendant's Waiver of Notice in Section 3301(c) was signed 2/1/00 and is filed herewith. H. Anthony Adam Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 ?- r L' ,? c. _ '? I J ,I• . f_/) _ LJ ;?J c? :i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Raymond S. Thompson, : No. Plaintiff VS. Debra D. Thompson, Defendant : 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 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 the custody or visitation rights 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 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, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA RAYMOND S. THOMPSON, : No. 99 5F 3G Plaintiff VS. DEBRA D. THOMPSON, Defendant Civil Action - Law : In Divorce COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Raymond S. Thompson, who currently resides at SME Lot 25, Shippensburg, Cumberland County, Pennsylvania, since May 15, 1985. 2. Defendant is Debra D. Thompson, who currently resides at 323 East King Street, Apt. 1, Shippensburgt, Cumberland County, Pennsylvania, since March 1, 1999. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on April 10, 1987 in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted. H. Anthony Adam , Esquire Attorney for Plaint 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 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: Ray and S. Thompson t c/. rl? 7 Z ? D Q UI a m F N Q ; ? n N Q W a F W P O ? r-I Z ) O F R tf m L4 IV y _ Z Q ? W d Z Z W H Z ¢ r..7 W W O N o? E- P W U Q Q < a U W ) C4 u O Q O UI L £ ? H o cq C pZ..i O Q Q Z U H IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Raymond S. Thompson, Plaintiff VS. Debra D. Thompson, Defendant AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Debra D. Thompson of 323 E. King Street, Apt. 1, Shippensburg, Pennsylvania 17257, certified mail, return receipt requested, on September 23, 1999 and was accepted on delivery by Debra D. Thompson on September 25, 1999 as shown by the attached receipt. Sworn to and subscribed this " dayy oyf,?Slre-ptember, 1999. ILI l/ ? t /L - Notary Public _NDER: No. x-5836 : Civil Action - Law In Divorce H. Anthony Adams,, squire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 J Complete ilems I andfor Y for aOMional services. My Commission Expires: Com1,1e19 eems3,4a,andeb. - o Pdnl your name, and address on Iha revane of ,his form to Thal we n e da I also wish to receive the follow. -- ing sendces (for an extra fee): w re um s ea to you. D Anson INa loran to the (rent of the meilpace. or on the Deck if apace does net 1. 11 Addressee's Address gene a Write 'Return e n th d' Z xl Restricted Delivery C o e the a titlitle e a slow the erects number. will 1e 07he Return elum Receipt ipl will show to wlam the article was delivered and and the dale ' p delivered. 3. Article Addressed to: 4a. Article Numbef DEBRA D. THOMPSON P 547 536 122 323 EAST KING STREET 4b. Service Type APT. #1 s O Registered X3 Certified y ?•?p SHIPPENSBURG, PARCd =as Mail Olnsured IIi?6? Receipt for Merchandise OCOD I DELIVER Y ate of Delivery ad ((Prt B. Addressee's Address (Onlylf requested end li feyyya r ?,la) )9 rt R ISSlone ure (Addressee orA q t ? ??? 71 / / PS Form 3811, December 1994 IC2995•eis-ow Dorneetle Retum Recelot [?p° I?E? ? r H G t'. ? '` __ -c,J ?? ?-% G J:? u C] ? ? ? j J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA RAYMOND S. THOMPSON, wrrM 99-5836 Plaintiff VS. : Civil Action - Law In Divorce DEBRA D. THOMPSON, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 22, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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 fal 'fication to autho ' ies. Date: 2/ ``- Raymond S. Thompson Plaintiff u M r , i' '.i ?. ? r?l .7 .. .1- ??? ?..'] _ iJ L ?.` :? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA RAYMOND S. THOMPSON, : No. 99-5836 Plaintiff Civil Action - Law VS. DEBRA D. THOMPSON, Defendant : In Divorce 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 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 falsi ation to autho Date: y ' Ra and S. Thompso Plaintiff Cam' ?- (' :; . 1 1:J 1• 'q l; ' .. C... .: J . i ?t1 U .) -' l? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA RAYMOND S. THOMPSON, : No. 99-5836 Plaintiff Civil Action - Law VS. DEBRA D. THOMPSON, Defendant In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 22, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made it 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: , Oa 1 7 pn?i Debra D. Thompson Defendant ?- ?, ? : ?? ,. ..._ ?r J ... ,?u i `-' J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA RAYMOND S. THOMPSON, : No. 99-5836 Plaintiff VS. DEBRA D. THOMPSON, Defendant Civil Action - Law : In Divorce 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 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: o() I ) w('?? l 1 1 t?? (J 5? Debra D. Thompson Defendant i .. Cj_ " c, c?