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IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
STATE OF
LEAHANN M. THOMAS
.......-Plaintiff
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PLEAS
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U..........9. 77.0199.......... .......
JEFFREY E. THOMASF
Defendant
DECREE IN
VORCE
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AND NOW,... .. • .. • . • ,A47M .... it is ordered and
..............
decreed that .. . .. . ... LEAHAM. M.. MOMAS ......................... Plaintiff,
......
and .......... ....... JEFFREY.E. ,T1.iOMAS....................... 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:
...........................................................................
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LEAHANN M. THOMAS,
Plaintiff
V.
JEFFREY E. THOMAS,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6199
CIVIL ACTION - LAW
IN DIVORCE
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 (X)3301(cl. L 201(d)(1), of the
Divorce Code. (Check applicable section).
2. Date and manner of service of the Complaint:
October I 1 1999 by certified mail
3. (Complete either paragraph (a) or (b)).
(a) Date of execution of the Affidavit of Consent required by Section 202 (c) of the Divorce
Code: by Plaintiff March 81000 by Defendant
March 1 2000
(b) (1)Datc of execution of the Plaintiffs Affidavit required by Section 201(d) of the
Divorce Code: ; (2)datc of service of the Plaintiff's Affidavit
upon the Defendant:
4. Related claims pending: None -
(Attom ()Plaintiff ( )Defendant
Joseph J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
(717) 236-8515
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LEAHANN M. THOMAS, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. ICI
CIVIL ACTION-LAW
JEFFREY E. THOMAS,
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 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.
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
Courthouse Square - Fourth Floor
Carlisle, PA 17013-3387
(717)240-6200
Dated: October 7, 1999
By:
Jos 1. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
(717)236.8515
Attorney for Plaintiff
LEAHANN M. THOMAS, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
JEFFREY E. THOMAS,
NO. 99. 6- 199 LeAl Tt4-
CIVIL ACTION-LAW
Defendant IN DIVORCE
AND NOW this T" day of October, 1999, comes the Plaintiff, Leahann M. Thomas, by
and through her attorney, Joseph J. Dixon, Esquire, who respectfully avers as follows:
The Plaintiff is Leahann M. Thomas, an adult individual who resides at 212
Creek Road, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. The Defendant is Jeffrey E. Thomas, an adult individual who resides at 800
Wood Street, Steelton, Dauphin County, Pennsylvania, 17113.
Both the Plaintiff and Defendant have been bona fide residents for at least six (6)
months immediately previous to the filing of this Complaint.
The Plaintiff and Defendant were married on May 27, 1989.
5. There have been no prior actions of divorce or annulment between the parties.
6. The Plaintiff and Defendant are both citizens of the United States of America.
7. Plaintiff has been advised of her right to seek marriage counseling in this divorce
action, but waives the right to do so.
8. Both the Plaintiff and Defendant are not members of the Armed Services of the
United States or any of its allies.
9. The Plaintiff and Defendant have been separated since September 4, 1998.
10. The Plaintiff avers that the ground on which this action is based is that the
marriage is irretrievably broken.
WHEREFORE, The Plaintiff prays this Honorable Court enter a Decree in Divorce in
accordance with Section 3301(c) of the Divorce Code.
Respectfully submitted,
13r, Joseph J. Dixon, Esquire
Attorney ID No. 28290
126 State Street
Harrisburg, PA 17101
(717) 236-8515
Attorney for Plaintiff
VERIFICATION
i verify that the statements made in this Divorce Complaint
are true and correct. I understand that false
statements herein are made subject to the penalty of 18 Pa. C.S.
54904, relating to unsworn falsification to authorities.
DATED: October 7, 1999 /?? InOMti ?1rn O1MCtZ
V°.
LEAHANN M. THOMAS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6199
CIVIL ACTION - LAW
JEFFREY E. THOMAS,
Defendant IN DIVORCE
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
Personally appeared before me, a Notary Public, in and for the aforesaid Commonwealth
and County, JOSEPH J. DIXON, ESQUIRE, who first being duly sworn according to law, does
depose and say that he made service of the Complaint in Divorce upon the Defendant by placing
a true and correct certified copy with a Notice to Defend and Claim Rights in the United States
Mail at Harrisburg, Pennsylvania.
Certified Number: Z 227 572 779
The same was received and acknowledged on behalf of the Defendant, JEFFREY E.
THOMAS, on the 12" day of October, 1999, as the addressee.
Receipt for mailing is attached hereto.
on, Esquire
Plaintiff
Swom to and subscribed before me
this -A day of /M"A 2000.
C-------A-?-
NOTARV PUBLIC
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LEAHANN M. THOMAS, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 99-6199
V.
CIVIL ACTION-LAW
JEFFREY E. THOMAS,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301 (C) OF THE DIVORCE CODE
(1) A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
October 7, 1999.
(2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
(3) I consent to the entry of a ftnal decree of divorce without formal notice of the intention to
request entry of a divorce decree.
(4) I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses, if 1 do not claim them before a divorce is granted.
(5) 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 IR Pa. C. S. Section 4904 relating to
unsworn falsificatt?iion) to authorities. ( 1 N, 'PA DATE 1 -1 AHANN M. THOMAS
LEAHANN M. THOMAS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. No. 99-6199
CIVIL ACTION - LAN
JEFFREY E. THOMAS,
Defendant IN DIVORCE.
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301 (C) OF THE DIVORCE CODE
(1) A Complaint in Divorce under Section 3301 (C) of the Divorce Code %%,a s filed on
October 7, 1999.
(2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
(3) I consent to the entry of a final decree of divorce without formal notice of the intention to
request entry of a divorce decree.
(4) 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.
(5) 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 in 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. Sec. 4904 relating to unsworn
falsification to authorities.
.?ll /2 &&o X Z7 q C-* DATED THOMAS
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CUIMS K. LONG
Pndhonolary
Cumberland Cuunly
One Cour1lamse Square
Carlisle. PA 17013
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Jeffrey ?r Thomas
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In The Court Of Common Pleas Of Cumberland County Prothonotary's Office
COURTHOUSE
Carlisle, Pa 17013
Civil Action No.: 1999-06199
THOMAS JEFFREY E
800 WOOD STREET
STEELTON PA 17113
THOMAS LEAHANN M
Plaintiff
** VERSUS **
THOMAS JEFFREY E
Defendant
You are hereby notified that a Decree in Divorce was entered
in the above captioned case on March 22, 2000. This letter should
not be used in place of the actual Decree. If you desire a certified
copy of this Decree, you can obtain the same by coming into our
office. Please bring this letter with you. The fee is $9.00. 0 of mm,4dMj
If request is made by mail, please enclose $9.00 for the U
certified copy of Decree. Also, do not forget to indicate Civil
Action No. on your request.
Sincer yours
Proth notar
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA. t+
...........
LEAHANN.. M..,.THOMAS,
Ij N( . ........"77.0199 .................
.... Plaintiff ......... . ..
Versus
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JEFFREY E. THOMAS,
Defendant
DECREE IN
DIV0RCE
a.
AND NOW'... rnb,,?,.,?• • ?'.. ........ it is ordered and
plaintiff,
I.E7111ANN M. THOMAS ..................
decreed that .........
JEFFREY •E; Tt10M7? ............... . ...... .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 yet
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Attest:
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