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Home My WebLink About99-05850 5fj ,i th 74{ *4r". a*n N1j I 1 1 4;y ?t A tisr !:K ltl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF w ^„r PENNA. ? n a William J. Loner If No. 99-5850 CIVIL TERM VERSUS Kelly J. Long DECREE IN DIVORCE AND NOW, do / IT IS ORDERED AND DECREED THAT William J. , PLAINTIFF, AND Kelly J. Long -,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; ??aa? NOTARY rc i /a::c li% L L-?/ A William J. Long IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNA. VS. NO. 99-5850 CIVIL TERM Kelly J. Long CIVIL ACTION - LAW 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 Section (3301(c)) k*R6tkkdkkkk) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: rt-rtifiPd Mail RFstrirtPd nPli Pry n q/24/Q9 and iqP1ixrPrPr1 n 9/27/99 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: by plaintiff 11/2/2000 by defendant 11/6/2000 (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: NA, (2) Date of service of the plaintiff's affidavit upon the defendant; NA 4. Related claims pending: All rP1atPA rla;ma arc QP?f 1cA and satisfied by agrPPmPnt of nartiPs 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i) of the Divorce Code. NA 6. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(c) of the Divorce Code NA , or, date of execution of waiver of Notice of Intent daant an ate of fi >ng o wa ver Attorney fot4 Plaintiff /Defendant e CNJ q Lrn N y y`f-. ? U r 41 G C3 J4 U WILLIAM J. LONG, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA. KELLY J. LONG, VS. Defendant NO. 99- 57 5v &wJ TJi, CIVIL ACTION - LAW IN DIVORCE 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 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 Court House, One Courthouse Square, Carlisle, Pennsylvania 17013. 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. Court Administrator Cumberland County Court House Fourth Floor Carlisle, PA 17013 (717) 240-6222 WILLIAM J. LONG, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA. VS. : NO. KELLY J. LONG, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien set emitida en so contra por cualquier otra queja o compensacion reclamados por el demandant. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotry, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Court Administrator Cumberland County Court House Fourth Floor Carlisle, PA 17013 (717) 240-6222 WILLIAM J. LONG, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PA. : NO. A4- Sb'60 Of T, KELLY J. LONG, CIVIL ACTION - LAW Defendant IN DIVORCE AND CUSTODY COMPLAINT 1ND R SECTION 301(5) OF THE DIVOR COD 'O NT I AND NOW, this day of 1999, comes the Plaintiff, William J. Long, by his attorney, Jan . Alexander, Esquire, and files this Complaint upon a cause of action of which the following is a statement. I. Plaintiff is William J. Long, 24 years of age, who currently resides at 6280 Carlisle Pike, Mechanicsburg, Hampden Township, Cumberland County, Commonwealth of Pennsylvania 17055. 2. Defendant is Kelly J. Long, 27 years of age, who currently resides at 698 Gazda Road, Clarkburg, Indiana County, Commonwealth of Pennsylvania 15725. 3. Plaintiff and Defendant have both resided in the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on October 10, 1998 in New Alexandria, Pennsylvania by a Minister. 5. There was one child born to the parties prior to this marriage: Alisha Marie Long, age 3 years, born July 23, 1996. 6. There were no prior actions in divorce or annulment commenced by the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and property division. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render his condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. 12. The allegations of Paragraph one (1) through nine (9) and Paragraphs ten (10) and eleven (11) are incorporated herein by reference and made a part hereof. 13. Plaintiff and Defendant have acquired property, both real and personal during their marriage. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and wheresoever situate and for such further relief as the Court may deem equitable and just. Respectfully Submitted, Alexa er, Esquire forte Plaintiff I.D. No. 07355 148 S. Baltimore Street Dillsburg, PA 17019 (717) 432-4514 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: 9 a_9 9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK William J. Long ?/ Q S.S Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared William J. Long who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. William J. Long, Sworn to and subscribed before me 's )day of 1999. Notary Public Notarial Seal Natxatd E. Alexander, Notary Public p ap Soro, York Courair MYeg lssfonExpiresApril 29,2001 em er. anon hqm rmnc atlon of Notaries 4N ", to ?i?n ^J -7 r rte- i '?ci QN U a w w H 4 O 7 a s z z u z N H w a w ow Fa O z 3 U 0 W ° w> Ell p n v o 0 4 ? O > i z Ei N v? a Z O a O O a E w h E+ O h w £ C U a a F U N a n > • a a £o x 0 m HOUz 3 U r i WILLIAM J. LONG, Plaintiff VS. KELLY J. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. NO. 99-5850 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from 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 the 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: 1? WILLIAM J. LONG, Plaintiff VS. KELLY J. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. NO. 99-5850 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from 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 the 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: ?Mj CO, 02Dod Kelly J. Long !f) ti L': {__ '-) -? .J ,•?? lJ ?it.l ?? r:r? •? .'_? U i 1 WILLIAM J. LONG, Plaintiff VS. KELLY J. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. NO. 99-5850 CIVIL TERM : CIVIL ACTION - LAW : IN 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. 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: William J. Long J ? 1. 'lLI r ` .G } J l J I WILLIAM J. LONG, Plaintiff VS. KELLY J. LONG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. NO. 99-5850 CIVIL TERM CIVIL ACTION - LAW IN 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. 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. l Date: / ?(?(J CO //.? I / Kelly J. Lon :) I f, _J _.1 ?) .. ''J i ? I:' _? ... ?J 1 r X J. LONG, . IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNA. VS. NO. 99-5850 CIVIL TERM J. LONG, CIVIL ACTION - LAW Defendant IN CUSTODY AND DIVORCE AFFIDAVIT OF SERVICE AND NOW, this _/S/ day of 1999 personally red Jane M. Alexander, Esquire, who swears according to law, a true and correct copy of a COMPLAINT IN CUSTODY AND was caused to be served by certified mail with return eipt requested upon the said, Kelly J. Long 698 Gazda Road Clarkburg, PA 15725 September 24. 1999, by leaving the same at the Dillsburg Post ice with postage pre-paid thereon as evidenced by the mailing and return receipt hereto attached and made a part ne M.- Ale naer, ?squ torney I. #07355 48 S. Balt'more Street illsburg, PA 17019 717) 432-4514 rn and subscribed before this . day of ')«c{?_111e: . 1999. Notarial Seal HaNerd E. Alexander, Notary Public DIIIBIwT Boro, York County My Commission Expires April 23, 2001 Mem0er, Pennsylvania Associatlon of Notaries WILLIAM J. LONG, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNA. VS. NO. 99-5850 CIVIL TERM KELLY J. LONG, CIVIL ACTION - LAW Defendant IN CUSTODY AND DIVORCE ° SENDE Complai tcomplen ¦Print you. i card toyN • Albch to ppee mn. Ratu a W • The e Ratu .. delWerad 3. Article ?1 also wish to receive the l l amvor 2 for additional services. lollowin services (for an 1 3,4a, and 4b. and address on the reverse of this form so that we can mtum Ilay. e e,lre feel: i to the front of the meilplece, or on the back if space does not I ,VCAddressee's Address j Kelly J. Lovt9 m6. $ (oa 6 Gu.c?dk Road. ClarlelciKrgp PA 15125 5. Received By: (Pdnt Name) 6. Sign tur dd see or ntJ ffi PS Form 3811. Dee er 7694 number. 2.X Restricted Delivery the dale Consult postmaster for fee. t1 I 4a. Article N umber I 2 44F(o 828 X35 M, 4b. Service Type 33E ? Registered Certified e? ? Express Mail ? Insured ? Return Receipt for Merchandise ? COD ., 7. Date of Deliveryr ?a1 A9 l ° B. Addressee's Address (Only i/requested a and fee is paid) ) m 10259S99-0 Mn Receipt PROOF OF SERVICE Z 446 828 135 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. C^ If) co? l. f _ 1 ? lL' C CJ r`? f l ------- U3 ---- --- --- Q PC W Z Ww H z W £ [ti a 0 ?a E z z w z F 8914 `? W w W H N wU>? G W N in u Ez 0 Z p o 1n Df7H W ; O O wo 8MWEFU InUa W I ?O h 14 h F > [p? 5 H ? i4 Ch 1-] HU Ho H aH a H w > HOHH a 3 a 9 w 4 SOCIAI,SECUlil'I'1' INFORMATION S11EE'I' I'l IRS14W I' TO ; I'a.l'.5.;1. SE(' I ION 4?Ud.l w)(.9 :\I.1 111\' )It( p, \11 ti I INC'I.UI)F T111'; PAR FITS SOCIAL SIY'l [RI I'Y NUMiiI{R 1'LEASIi PII,I. IN'I'l lli AI'I'ROI'R1A'17i INPt)R1tilA77t)N ANU Rl l JWN l u I III 11ROTHONOTARY'S uf1'1CF 1)A'H:: UOC'RI:I' Nl ItiIISIiR: _24_Sg50 MjL TERM ... PLAIN'I'IPP/I'li'fl'I';ONIiR SSII 168-62-5700 NAME: William J. Long 1)1"1'1:NI)AN'171I !:SPONI)I:N'I' SS 11 1 87-54-4182 NAME: _ Kelly J. Long