HomeMy WebLinkAbout03-3421
ELIZABETH J. PLUM,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
JAMES M. PLUM, JR.
Defendant.
: NOO.J ~ Jt/).! 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, P A 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, TO GET LEGAL HELP SHOULD
CONTACT:
Cumberland County Lawyer Referral Service
32 Bedford Street, Carlisle, Pennsylvania
1-(800)-990-9108
COYNE & COYNE, P.C.
AU~!;~
3901 Market Street
CampHiIl,PA 17011-4227
(717) 737-0464
Pa.. Supreme Ct. No. 59020
Attorney for Plaintiff
ELIZABETH J. PLUM,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
JAMES M. PLUM, JR.
Defendant.
: NO'Oj.. .Jl(.2.I CIVIL TERM
: IN DIVORCE
COMPLAINT IN DIVORCE AND CUSTODY
TO THE HONORABLE, JUDGES OF SAID COURT:
NOW COMES the Plaintiff, ELIZABETH J. PLUM, by her attorney, Austin F. Grogan, Esquire
and files this Complaint ill Divorce and Custody and avers the following in support thereof:
1. The Plaintiff, ELIZABETH J. PLUM, is an adult individual residing at 4816 E. Trindle
Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. The Defendant, JAMES M. PLUM, JR., is an adult individual residing at 10 E. Pfautz
Road, Duncannon, Penry County, Pennsylvania, 17020.
3. The Plaintiff and Defendant are sui juris and have been bona fide residents in the
Commonwealth for at least six months previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 21, 1999 in Cumberland County,
Pennsylvania.
5. The Defendant is not a member of the Armed Services of the United States or any of its
Allies.
6. There have been no prior actions of divorce or for annulment between the parties.
7. 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. Further, Plaintiff waives
his right to request that the parties participate in marriage counseling.
COUNT I-REQUEST FOR A NQ FAULT DIVORCE
8. The prior paragraphs I thru 7 of this Complaint are incorporated by reference.
9. The marriage is irretrievably broken.
10. After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also
file such an affidavit.
II. At the appropriate time, Plaintiff may submit an affidavit alleging that the parties have
lived separate and apart for at least two (2) years.
WHEREFORE, if both parties file affidavits of consent to a divorce after ninety (90) days have
elapsed from the filing of this Complaint, or alternatively if the appropriate time has elapsed since date of
separation, Plaintiff respectfully request the Court enter a Decree in Divorce, pursuant to Section 3301(c)
or Section 3301(d), as may be appropriate.
COUNT III - EQIDTABLE DISTRIBUTION
12. The prior paragraphs I thru II of this Complaint are incorporated by reference.
13. Plaintiff and Defendant have acquired property, both real and personal, and debt during
their marriage.
14. Plaintiff and Defendant have been unable to agree as to the equitable division of said
property and debt.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property
and debt pursuant to the Divorce Code.
COUNT IV - ALIMONY PENDENTE LITE. COUNSEL
FEES, COSTS AND EXPENSES
15. The prior paragraphs 1 thru 14 of this Complaint are incorporated herein by reference.
16. Plaintiff has retained counsel and wiU incur considerable expense in preparation for her
case in the employment of counsel and possible experts and the payment of costs.
17. Plaintiff is without adequate funds to support herself and to meet the costs and expenses
of this litigation and is unable to sustain herself during the pendency of this action.
WHEREFORE, Plaintiff respectfuUy requests this Honorable Court to order Defendant to pay
Plaintiff alimony pendente lite, counsel fees, costs and expenses associated with this divorce action.
COUNT V - CUSTODY
18. The prior paragraphs I thru 14 of this Complaint are incorporated herein by reference.
19. Plaintiff seeks custody of the minor child, Tyler Plum, born November 17, 1997, who
currently resides at 4816 E. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania.
20. The child was not born during wedlock.
21. The child is presently in the custody of the Plaintiff, Elizabeth Plum.
22. During the child's lifetime the child has resided with the foUowing persons and at the
foUowing addresses:
Elizabeth Plum and Sherryl Fair
(plaintiff' s Mother)
Elizabeth Plum and
James M. Plum, Jr.
Elizabeth Plum and
James M. Plum, Jr.
4816 E. Trindle Road
Mechanicsburg, P A
947 Windy Hill
Shermansdale, P A
125 AltoonaAve.
Enola, PA
March 17, 2003-Present
March 200 I to
March 17, 2003
November 1998 to
March 200 I
23. The relationship of Plaintiff to the child is that of natural mother.
24. The relationship of Defendant to the child is that of natural father.
25. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation
concerning the custody of the child in this or another court.
26. Plaintiff has no information of a custody proceeding concerning the child pending in a
court of this Commonwealth.
27. Plaintiff does not know of a person not a party to the proceedings who has physical custody
of the child or claims to have custody or visitation rights with respect to the child.
28. The PlaintiffiMother seeks primary custody for the following reasons:
a. Defendant has proven himself to be an unfit role model for his son, Tyler Plum.
29. Each parent whose parental rights to the child have not been terminated and the person who
has physical custody of the child have been named as parties to this action.
WHEREFORE, the Plaintiff, ELIZABETH J. PLUM, respectfully requests this Court to grant
primary physical and legal custody of the child to the Plaintiff with the Defendant, JAMES M. PLUM, JR.,
having periods of visitation with the child as the parties may agree and as may be in the best interest of the
child.
Respectfully submitted,
COYNE & COYNE, P.e.
Dated: '7- Ju'O 3
By:
~nt!
3901 Market
Camp Hill, PAIl
(717)737-1956
Supreme Ct. No. 59020
Attorney for Plaintiff
VERIFICATION
I, ELIZABETII J. PLUM, verifY that the statements made in the foregoing Custody Complaint are
true and correct to the best of my knowledge, infonnation, and belief. 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 7-1O-0::':l
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ELIZABETH J. PLUM
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
03-3421
CIVIL ACTION LAW
JAMES M. PLUM, JR.
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, July 24, 2003
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, Anltust 19, 2003 at 2:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will he made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours pl'ior to scheduled hearing.
FOR THE COURT.
By: Isl
Dawn S. Sunda:y. Esq.
Custody Conciliator
~
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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COYNE & COYNE, P.C.
Attorneys at Law
3901 Market Street
Camp HiU, PA 17011-4227
(717) 737-0464
ELIZABETH .1. PLUM,
Plaintiff,
: IN THE COllRT OF COMMON PLEAS OF
: ClIMBERLANn COUNTY, PENNSYLVANIA
VS.
: NO. 03-3421 CIVIL TERM
.lAMES M. PLUM, JR.
Defendant.
: IN DIVORCE
PROOF OF ORIGINAL SERVICE OF COMPLAINT
I, AUSTIN F. GROGAN, ESQUIRE, hereby certify that I have, on July 30, 2003, causcd a true and
correct copies of the attached Complaint !(J[ Divorce to be served upon the Defendant named below by way
of certified tirst class mail, rcstricted delivery, postage prepaid, return receipt requested:
James M. Plum, Jr.
10 E, Pfautz Road
Duncannon, P A 17020
Dated: (1-/--,n
COYNE & COYNE. P.c.
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i)ustin F. Grogan, Esquire
3901 Market Street
CampHill,PA 17011-4227
(717) 737-0464
Pa. Supreme Ct. No. 59020
Attorneyfor Plaintiff
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ELIZABETH J. PLUM
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
03-3421
CIVIL ACTION LAW
JAMES M. PLUM, JR
Defendant
IN CUSTODY
ORDER
AND NOW, this 22nd day of SeDtember. 2003 , the conciliator, having received no
request from counselor either of the parties to reschedule the custody conciliation conference set for
August 19,2003, hereby relinquishes jurisdiction.
FOR THE COURT,
D'wll~
Custody Conciliator
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ELIZABETH J. PLUM,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 03-3421 CIVIL TERM
JAMES M. PLUM, JR.
Defendant.
: IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a counter-
affidavit within twenty (20) days after this affidavit has been served on you or the statements will be
admitted.
AFFIDAVIT UNDER SECTION 3301(d) OF THE DNORCE CODE
1. The parties to this action separated on March 31, 2003 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! 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.A. Section 4904 relating to unsworn
falsifieation to authorities.
Date:
1..1 ('i 10:(
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Eliza Plum, Plaintiff
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ELIZABETH J. PLUM,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 03-3421 CIVIL TERM
JAMES M. PLUM, JR.
Defendant.
: IN DIVORCE
PROOF OF SERVICE
I, AUSTIN F. GROGAN, ESQUIRE, hereby certifY that I have, on April 8, 2005, caused a true and
correct copies of the attached Notice and Notice oflntention to Request Entry of 93301 (d) Divorce Decree
to be served upon the Defendant named below by way of certified first class mail, restricted delivery,
postage prepaid, return receipt requested and first class mail:
James M. Plum, Jr.
10 E. Pfautz Road
Duncannon, P A 17020
I
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James M. Plum # 604079
Valusa Beach County Jail
Daytona Beach FL 32120
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COYNE & COYNE, P.c.
ILLJJ
Austin F. Grogan, Esqui
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. Supreme Ct. No. 59020
Attorney for Plaintiff
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ELIZABETH J. PLUM,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLA.ND COUNTY, PENNSYLVANIA
VS.
: NO. 03-3421 CIVIL TERM
JAMES M. PLUM, JR
Defendant.
: IN DIVORCE
NOTICE OF INTENTION TO REOUEST ENTRY OF Ii 3301(d) DIVORCE DECREE
TO: JAMES M. PLUM, JR
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the 9 330l(d) affidavit. Therefore, on or after April 28, 2005, the other
party 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. A counter-affidavit which you may file with the prothonotary of the court is attached to
this notice.
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 wi.ll lose forever the
right to ask for economic relief. The filing of the form counter-affidavit alone does not protect
your economic claims.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HI:Rm'G A LAWYER. IF
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Lawyer Referral Service
32 Bedford Street, Carlisle, Pennsylvania
1-(800)-990-9108
Dated:
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By:
Austin F. Gro , Es
3901 Market Street
Camp Hill, PA 170
(717) 737-0464
Attorney/or Plaintiff
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ELIZABETH J. PLUM,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V AA'IA
vs.
: NO. 03-3421 CIVIL TERM
JAMES M. PLUM, JR.
Defendant.
: IN DIVORCE
COUNTER-AFFIDA VII UNDER 6 330 I (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 "~sh 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 lntention to Request Divorce Decree, the divorce decree may
be entered without further notice to me, and I shall be unable thereafter to file any economic
claims.
I verifY that the statements made in this counter-affida\~t are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.CS. S 4904,
relating to unsworn falsification to authorities.
Date:
JAMES M. PLUM, JR
NOTICE: IT YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE
AND YOU DO NOT V,'ISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU
SHOULD NOT FJlE TillS COUNTER-AFFIDA VII.
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ELIZABETH J. PLUM,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 03-3421 CIVIL TERM
JAMES M. PLUM, JR.
Defendant.
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the foJlowing information, to the Court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(d)(I) of the Divorce
! Code. The parties have been separated since March 31, 2003.
2. Date and manner of service of the complaint: July 20, 2003, certified restricted mail.
3. Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
April 8, 2005;
Date of filing and service of the Plaintiffs affidavit upon the Defendant, as weJl as, a
counter-affidavit as required by Pa. R.C.P. 1920.42(c)(2): Defendant waS served Plaintiff's aflidavit
and counter-affidavit bv first class mail and certified mail/restricted to the address of record of 10
East Pfaute Road Duncannon. PA 17020 and the last know address of Val usIa Beach County. Jail
Davtona Beach FL. 32120and the Plaintiff's aflidavit was mailed to the Prothonotary on April 8,
2005 and docketed of record Anrilll, 2005
4. Related claims pending: NONE
5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a
K:OPY of which is attached: First class mail and certified mail/restricted delivery April 8, 2005.
bated:
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By:
COYNE & COYNE, P.C.
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Austin F. Grogan, Esq.
Pa. Supreme Ct. No.5809
3901 Market Street
CampHill,PA 170\1-4227
(717) 737-0464
Attorney For Plaintiff
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. . .
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
ELIZABETH J.
PLUM
Plaintiff
VERSUS
JAMES M.
PLUM,
JR.
Defendant
AND NOW,
DECREED THAT
AND
JAMES M.
PENNA.
No.
#03-3421
DECREE IN
DIVORCE
41141'
"{"
, ..zd41" _, IT tS ORDERED AND
ELIZABETH J.
PLUM
PLUM, JR.
ARE DIVORCED FROM THE BONDS OF MATRtMONY.
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
YET BEEN ENTERED;
BEEN RAISED OF RECORD tN THIS ACTION F.OR WHtCH A FINAL ORDER HAS NOT
.
NONE
. .
PROTHONOTARY
++ ++ + + ++ + :+: + ++++++++ ++++++++
..
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