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Home My WebLink About99-06183IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF 4 PENNA. '`^ J. HOWARD B McCONNSr•r• No. 99-6183 CIVIL Plaintiff VERSUS CHRISTINA MCCONNBLL Defendant DECREE IN DIVORCE AND NOW,--M!-'"l `S , 2000 , IT IS ORDERED AND PLAINTIFF, n ynnn?nnll , DECREED THAT HOVard Christina McConnell DEFENDANT, AND 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 {1 YET BEEN ENTERED; None {.; E A . l .: /lr C!J Lena' e?r ! -gpv-o , 4 /% 71 A ? e W?e- HOWARD B. McCONNELL, PLAINTIFF V. CHRISTINA MCCONNELL, DEFENDANT To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6183 CIVIL ACTION IN DIVORCE Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Hand delivery by a nonparty, March 21, 2000. 3. (a) (1) Date of execution of the affidavit required by section 3301(d) of the Divorce Code: October 6, 1999; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on October 0, 1999, served March 21, 2000. 4. Related claims pending: Non - 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: hand delivery by a nonparty, April 11, 2000. -ficwl,., D. p6awa Thomas D. Gould Attorney for Plaintiff J :r ll. \ u G fj HOWARD B. MCCONNELL, PLAINTIFF V. MCCONNELL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 4/(3 CIVIL TERM 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 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 HOMM B. MaCONNELL, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v• NO. 99 - 6 140 CIVIL TERM CHRISTINA MaCONNELL, IN DIVORCE DEFENDANT COMPLAINT UNDER SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Howard B. McConnell who resides at 28 W. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Christina McConnell who resides at Res Tamrindo, Apartment 9-2, C.D. Bolivar, Venezuela. 3. The Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on in 5. 15, 1993. The parties have lived separate and apart since December 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. B. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 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. Date: Howard B. McConnell li. 1 ell c:? (J1 ij J 0 ; o oU' 5Qo m ? a o u ? ?a?1j a xz 7 O. Z f F h 5 QQc ? y? UUUU?1111 I` 3: U) m z N, 0 1l?JdlONOH1021d •(13".LVJ.SN1321 111 yid j ............... . U l{(?? HOWARD B. MCCONNELL, PLAINTIFF V. CHRISTINA MaCONNELL, DEFENDANT If you wish to affidavit, you must after this affidavit be admitted. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 99 - J,/CIVIL TERM IN DIVORCE NOTICE TO THE deny any of the statements set forth in this file a counter-affidavit within twenty days has been served on you or the statements will PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on December 15, 1993 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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: 10-6- B. McConnell Howard C n c rh ? °< ?• .s Y c? ? cn r P I Ou4i. 4 vf. to the Court of Common Plana of Cumberland Canty, Paacaylranis. civd. :9 ........................ _.... ---------------- ----- -------- ..................... ---; ----------------•--------------------'---------------------------- -------- ...Ie A i c---re t n r ruFe __ `!-lu _ a?_ ?t c a??==== ? --?IY.RC? ?--t32???. ;? Ig?•z .l /__ A r ---`=4'1a;L 1. ,-1--"T=---- .fr 30 d .521_?c7f----?n?td_»?TP! --------------- --------------------------- To »_-»----- __------- Prothonotary ;L F.wir YNa J7?t t7,? 1, v%cl .1 town, ?Q 1 7o I / 731- 11/it 6S o &t Attcrstty for Plaintiff. Z ?e 4 y ;y 1 J e Q ro til i I i ro ? M {{f i e I I 1 I r> 1. 'u t e y:. M{F k 1 ; i 1 F 1 f i i i .-1 . .. HOWARD B. MaCONNELL, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN V. NO. 99-6183 CIVIL ACTION CHRISTINA McCONNELL, IN DIVORCE DEFENDANT AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce under section 3301(d), with attached Plaintiff's Affidavit, was served upon the Defendant by hand delivery by Richard Corirossi, as evidenced by the attached Affidavit of Service, on March 21, 2000 pursuant to Rule 1930.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. Thomas D. Gould ID H 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 o? r ' X 5i ` a Q -Q j , . 4 HOWARD B. MaCONNELL, PLAINTIFF V. IN THE COURT OF CObMN PLEAS CIMMERLAND COUNTY, PENNSYLVANIA NO. 99 - 6183 CIVIL TERM IN DIVORCE LVoR- IR.ossL I, Richard Ccrri>resci, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by hand delivering the same to her on 321/2 000 DATE '' // at C: //??/ uA/ho AotiL/,40-, VL-'VazV6 .4 LOCATION Richard Geis4-o--4 dvici2 osr/ 6248 N. Wayne Avenue Chicago, IL 60660 Sworn and subscribed to before me this ? day ZooO of A004 - , ?994- OFFICIAL SEAL CHRISTINE A. CORIROSSI NOTARY PUBLIC, STATE OF ILLINOIS YYCOLIUISSION EXPIRES 34.2001 0 0 ? rr ;r A .. e I HOWARD B. MaCONNELL, PLAINTIFF V. CHRISTINA McCONNELL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 99-6183 CIVIL ACTION IN DIVORCE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the plaintiff's Notice of Intention To Request Entry of Divorce decree and Counter-Affidavit was served upon the Defendant by hand delivery by Richard Melville, as evidenced by the attached Affidavit of Service, on April 11, 2000 pursuant to Rule 1930.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 HOWARD B. MCCONNELL, IN THE COURT OF COMMON PLEAS PLAINTIFF CUM3ERLAND COUNTY, PENNSYLVAN V. NO. 99 - 6183 CIVIL TERM CHRISTINA McCONNELL, IN DIVORCE DEFENDANT AFFIDAVIT OF SERVICE I?16'LV/ LLj' I, Richard Corr *Q6a ,, hereby certify that a conformed and certified copy of the plaintiff's Notice Of Intention To Request Entry Of Divorce Decree and Counter-Affidavit was served upon the Defendant by hand delivering the same to her on // 2 c ry D TE at /14bA p AntjV$A. Y6dr,7_iAr_ r-.A LOCATION Sworn and subscribed to before me this / 9day cop e of &,? , 4939- l Aithcz ?s.?d:rosSf 6 ?1chl-a aL.o M??-VILLA 1a lRni lll/ /!? Z& Tr a #l3 Ci AAgP6 8-o&lw4l 4a"uc A) L AL CHRISTINE A. CORIROSSI NOTARY PUBLIC, STATE OF ILLINOIS YYCOYYISSION EXPIRES 71.2001 HOWARD B. MCCONNELL, PLAINTIFF V. CHRISTINA MCCONNELL, IN THE COURT OF COMMON PLEAS CMMERLAND COUNTY, PENNSYLVANIA NO. 99-6183 CIVIL ACTION IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: CHRISTINA MCCONNELL You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit. Therefore, on or after May 1, 2000, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter- affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DG 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 HOWARD B. MCCONNELL, PLAINTIFF V. CHRISTINA MCCONNELL, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 99-6183 CIVIL ACTION IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to request Divorce Decree, the divorce decree may be enterea without further notice to me, and shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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: Christina McConnell E fi 1 , lip ? Yi S f ?. O CZ) s.