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IN THE COURT OF COMMON FLEAS r
` OF CUMBERLAND COUNTY
i
STATE OF .} t PENNA.
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r, JOHN J. NEWMAN, >•
Ni(). 6141•..,,,., .CIVIL 1999
Plaintiff
JOAN G. .NEWMAN,,
Defendant
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DECREE IN
DIVORCE
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v / zooo• it is ordered and ti
AND NOW, ............... ,
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decreed that .........JOHN .J.. NEWMAN ........................ Plaintiff,
p and ............. J.qw r..•.. NEWMAN............................ defendant,
i+ are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have g
p been raised of record in this action for which a final order has not yet
been entered;
NONE
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Attest: J
Prothonotary
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JOHN J. NEWMAN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6141 CIVIL
JOAN G. NEWMAN, CIVIL ACTION - LAW
Defendant IN DIVORCE
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) of the Divorce Code.
2. Date and manner of service of the Complaint: October 81
1999, by acceptance of service.
3. Date of execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code: by Plaintiff on
January 19. 2000 ; by Defendant on January 19, 2000
4. Related claims pending: None
5. Date Plaintiff's Waiver of Notice in Section 3301(c)
Divorce was filed with the Prothonotary: January 24, 2000
Date Defendant's Waiver of Notice in Section 3301(c) Divorce
was filed with the Prothonotary: January 24, 2000.
CLECKNER AND FEAREN
DATE: January 21, 2000 By / A A'l "
Dennis J. Shatto, Esquire
Attorney I.D. No. 25675
111 Locust Street
P.O. Box 11847
Harrisburg, PA 17018-1847
(717) 238-1731
Attorney for Plaintiff
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JOHN J. NEWMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. C
JOAN G. NEWMAN, CIVIL ACTION - LAW
Defendant 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 irretriev-
able breakdown of the marriage, you may request marriage counsel-
ing. A list of marriage counselors is available in the office of
the Prothonotary at:
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 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 Courthouse, 4th Floor
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
CLEC E AND FEAREN
By U`U"
Dennis J. Shatto, Esquire
Attorney I.D. No. 25675
111 Locust Street
P.O. Box 11847
Harrisburg, PA 17108-1847
(717) 238-1731
I-M
JOHN J. NEWMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999
JOAN G. NEWMAN, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT UNDER SECTION
3301(c) OF THE DIVORCE CODE
1. Plaintiff is JOHN J. NEWMAN, who resides at 312 Wertzville
Road, Enola, Cumberland County, Pennsylvania, since May of 1989.
2. Defendant is JOAN G. NEWMAN, who resides at 312 Wertzville
Road, Enola, Cumberland County, Pennsylvania, since May of 1989.
3. Plaintiff and Defendant have both been bona fide residents
in the Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 27, 1982,
in Harrisburg, Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Plaintiff avers that there are no children of the parties.
7. The marriage is irretrievably broken.
J 8. 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.
9. Plaintiff requests the Court to enter a Decree of Divorce.
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. 5 4904, relating to unsworn
falsification to authorities.
JOHN J. NEWMAN - Plaintiff
Dated: 7 .w 1999
CLECKNE AND FEARF.
By
Ddppis J. Shatto, Esquire
Attorney I.D. No. 25675
111 Locust Street
P.O. Box 11847
Harrisburg, PA 17108-1847
(717) 238-1731
(Counsel for Plaintiff)
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JOHN J. NEWMAN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6141 CIVIL
V.
JOAN G. NEWMAN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint.
JOAN G. NEWMAN
Dated: /D leA
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JOHN J. NEWMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6141 CIVIL
JOAN G. NEWMAN, IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the
Divorce Code was filed on October 6, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing 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. 9 4904 relating to unsworn
falsification to authorities.
Date: 2000 --?_/f~'?-??. -
JOHN J. NEWMAN, Plaintiff
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JOHN J. NEWMAN,
Plaintiff
V.
JOAN G. NEI-M4,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6141 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
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.
4. 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 in 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Date: ?/ )(, ,?__.
JOHN J. NEWMAN, Plaintiff
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JOHN J. NEWMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6141 CIVIL
JOAN G. NEWMAN, IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the
Divorce Code was filed on October 6, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing 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. 5 4904 relating to unsworn
falsification to authorities.
Date: .aa) Be"
JO G. NEWMAN, Defendant
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JOHN J. NEWMAN,
Plaintiff
V.
JOAN G. NEWMAN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6141 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
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.
4. 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 in 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Date: c,D e) i; "
JO G.& NEWMAN, Def ndant
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