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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ? PENNA.
p m u
KATHLEEN L. RUSSELL.
PLAINTIFF
VERSUS
DAVID H. RUSSELL,
DEFENDANP
N O. 99-6336 CIVIL TERN
DECREE IN
DIVORCE
AND NOW, 2000 IT IS ORDERED AND
DECREED THAT KATHLEEN L. RUSSELL PLAINTIFF,
AND DAVID H. RUSSELL 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;
NONE
BY THE\COU
ATTEST:
J.
PFfbTHONOTARY
-; 'f
KATHLEEN L. RUSSELL 1168.36.6378),
Plaintiff
VS.
DAVID H. RUSSELL 1283.38.0850),
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACT[
?J3J LAW
99?V ?r
NO. 99-6331rCIVIL TERM
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 33011c).
2. Date and manner of service of the Complaint: Acceptance of Service filed by Plaintiff's
counsel indicating service on or about 28 July 2000.
3. Complete either Paragraph la) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: by Plaintiff: 10 November 2000 by Defendant: 9 November 2000
(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce
Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the
Respondent:
4. Related claims pending: None
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached:
Ib) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: Dated 10 November 2000. filed contemporaneously herewith. Date Defendant's
Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 9 November
2000. filed contemporaneously herewith.
Date: iq MOO 00 By(??
Samuel L. Andes
Attorney for Plaintiff
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Y
KATHLEEN L. RUSSELL,
Plaintiff
VS.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 99- W3,. CIVIL TERM
DAVID H. RUSSELL,
Defendant
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 foregoing 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. A list of marriage counselors is
available in the Office of the Prothonotary at:
Office of the Prothonotary
1 Courthouse Square
Cumberland County Court House
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 NOTI!
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, Fourth Floor
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200
KATHLEEN L. RUSSELL,
Plaintiff
VS.
DAVID H. RUSSELL,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99- t. 3J6 CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding
filed in the Court of Common Pleas of Cumberland County. This notice is to advise you
that in accordance with Section 3302(d) of the Divorce Code, you may request that the
court require you and your spouse to attend marriage counseling prior to a divorce
being handed down by the court. A list of professional marriage counselors is available
at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You
are advised that this list is kept as a convenience to you and you are not bound to
choose a counselor from this list. All necessary arrangements and the cost of counseling
sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
_' .
KATHLEEN L. RUSSELL,
Plaintiff
VS.
DAVID H. RUSSELL,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. c? 1. G 336 CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, KATHLEEN L. RUSSELL, by her
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is KATHLEEN L. RUSSELL, an adult individual who currently
resides at 58 Biddle Road in Carlisle, Cumberland County, Pennsylvania.
2. The Defendant is DAVID H. RUSSELL, an adult individual who currently
resides at 58 Biddle Road in Carlisle, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the
filing of this Complaint. I
4. The Plaintiff and Defendant were married on 9 October 1985 in Kennebunk,
Maine.
5. There have been no prior actions of divorce or annulment between the parties.'
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate
in counseling.
COUNT I - IRRETREIVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant
to the Divorce Code of Pennsylvania.
COUNT II - EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items
of property, both real and personal, which are held in joint names and in the individual
names of each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure
by the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as marital property.
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of
18 Pa. C.S. 4904 (unsworn falsification to authorities).
DATE:
iik HLEEN L.
ucl L. An es
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
KATHLEEN L. RUSSELL,
Plaintiff
VS.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6336 CIVIL TERM
DAVID H. RUSSELL,
Defendant
IN DIVORCE
AEEIDAVIT_OECONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
18 October 1999 and served upon the Defendant on or about 28 October 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. 1 consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. 1 have been advised of the availability of marriage counseling and understand that
the Court riaintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and 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
ATHLEEN L. RUSSELL
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KATHLEEN L. RUSSELL,
Plaintiff
VS.
DAVID H. RUSSELL,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6336 CIVIL TERM
IN DIVORCE
WAIVER OF NOSICE_OEINTEUTLON1O-REQUF$LENTRY OF
A DIVORCE-DECREESlNDE"ECTION?3U11C1_OF_THE DIVORCE COD
1. 1 consent to the entry of a final decree in divorce without notice.
2. 1 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. 1 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 Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
in`?2u?3oo?
Date
L. RUSSELL
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KATHLEEN L. RUSSELL,
Plaintiff
VS.
DAVID H. RUSSELL,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6336 CIVIL TERM
IN DIVORCE
AEEIDAVLLOEC_ONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
18 October 1999 and served upon the Defendant on or about 28 October 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. 1 consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. 1 have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and 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.
_// o?cUv
Date
16"'1' x -9, "
DAVID H. RUSSELL I/
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KATHLEEN L. RUSSELL,
Plaintiff
VS.
DAVID H. RUSSELL,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6336 CIVIL TERM
IN DIVORCE
WALVEELOLUOTIC"f-INIENn ONJ_O-BEQUEST-ENTITY-OE
A DIVORCE-DECHEESINDER-SECTION-330-UCI OF THE-DIVORCE CODE
1. 1 consent to the entry of a final decree in divorce without notice.
2. 1 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. 1 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 Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
ao? a
DatA '/ DAVID H. U LL
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06336 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
RUSSELL KATHLEEN L
VS.
RUSSELL DAVID H
SHAWN HARRISON , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - DIVORCE was served
upon RUSSELL DAVID H the
defendant, at 9:00 HOURS, on the 28th day of October ,
1999 at 58 BIDDLE ROAD
CARLISLE PA 17013 CUMBERLAND
County, Pennsylvania, by handing to DAVID RUSSELL
a true and attested copy of the COMPLAINT - DIVORCE ,
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answer
18.00 y
3.72 s
8.00
_11/01199
by
Sworn and subscribed to before me
this a? day of 1??...,
192 A.D.
d. . - s