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IN THE COURT OF COMMON PLEAS
e
OF CUMBERLAND COUNTY
STATE OF PENNA.
WILLIAM A. O'DONNELL,
• __ t)...99 b433..... C Y 1........ 19
Plaintiff „ p
j Versus
ti T. JOYCE O'DONNELL,
J Defendant __. .,...... R
DECREE IN
DIVORCE
AND NOW, .......... f?'?!u ...... , it is ordered and
7.. OA
decreed that . WILLIAM A. O'.DONNELL • • • • • • • • . • • • • • • • • • • • • • • • • • • , plaintiff,
and ........... T..JOYCE.O!DONNELL• • • • • • .... I ............. • • • • , defendant
$ are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
it been raised of record in this action for which a final order has not yet
been entered; r
None
.................................................
t
By Th Court:
Attest: J.
!y / Prothonotary
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WILLIAM A. O'DONNELL,
Plaintiff
VS.
T. JOYCE O'DONNELL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. 99-6433 CIVILTERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to Ilse court for entry of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under §3301(c)
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(Strike out inapplicable section).
2. Dale and manner of service of the complaint: _United States Mail, Certified, return
receipt requested, addressed to Defendant and received by her on October 23, 1999.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code:
by plaintiff 1-24-2000 ; by defendant
(b) (1) Date of execution of the affidavit required by §3301(d)
of the Divorce Code: NA
1-24-2000
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
N/A
4. Rotated claims pending: NONE
5. Complete either (a) or (b).
(a) Date and manner of service of tile notice of intention to file praecipe to transmit record, a
copy of which is attached:
(b) Dale of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary:_ Filed contemporaneously with the Praecipe to Transmit Record.
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: Filed contemporaneously with the Praecipe to Transmit Record.
I
Altorney lof Plalnlill / Dolandant
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WILLIAM A. O'DONNELL,
Plaintiff
V.
T. JOYCE O'DONNELL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.QQ-4'133 99 CIVIL TERM
IN- DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
1-800-990-9108
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 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, 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.
WILLIAM A, O'DONNELL,
Plaintiff
V.
T. JOYCE O'DONNELL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 64 33 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301 (c)
1. The Plaintiff, WILLIAM A. O'DONNELL, currently resides at 500 Kevin Court,
Wormleysburg, Cumberland County, Pennsylvania, since 1998. (Camp Hill, PA 17011)
2. The Defendant, T. JOYCE O'DONNELL, currently resides at 500 Kevin Court,
Wormleysburg, Cumberland County, Pennsylvania, since August of 1998. (Camp Hill, PA 17011)
3. The Plaintiff has been a bona fide resident 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 August 17, 1996 in Upper Allen Township
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
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.
8. 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. §4904, relating to unsworn
falsification to authorities.
Date:` 061 6PL l$, JI-4)I
Plaintiff
?-
Attorney for Plainti
-2-
WILLIAM A. O'DONNELL,
Plaintiff
V.
T. JOYCE O'DONNELL
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6433
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A complaint in divorce under Section 3301 (c) of the Divorce Code was filed
on October 21, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of 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 Use statements herein are made subject to the penalties of 18 Pa. C.S. §4909 relating to
unswom falsification to authorities.
Date: t / z I / ou
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WILLIAM A. O'DONNELL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6433
T. JOYCE O'DONNELL : CIVIL ACTION -LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed
on October 21, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
days have clapscd'from the date of filing and service of Complaint.
3. 1 consent to the entry or a final decree of divorce affer 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. §4909 relating to
unswom falsification to authorities.
L'
Date: - Q-- O C3
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cn
WILLIAM A. O'DONNELL,
Plaintiff
V.
T. JOYCE O'DONNELL
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6433
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
63301 (c) OF THE DIVORCE CODE
1. I consent to the entry or a final decree of 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 alter 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.§4909 relating to
unsworn falsification to authorities.
Date; 6jzC.-., c •
Plaintiff/
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WILLIAM A. O'DONNELL,
Plaintiff
V.
T. JOYCE O'DONNELL
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6433
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
43 301 c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of 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 affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.§4909 relating to
unsworn falsification to authorities.
Date:'' ?-._ d (--)
U-
WILLIAM A. O'DONNELL,
Plaintiff
V.
T. JOYCE O'DONNELL,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5433
CIVIL ACTION-LAW
IN DIVORCE
I, WILLIAM A. YOCUM, attorney for the Plaintiff, do hereby certify to the
service of a true and correct copy of the Plaintiff's Complaint in Divorce
which was deposited in the United States Mail, Certified, return receipt
requested, addressed to T. JOYCE O'DONNELL on October 21, 1999 and received
by the Defendant on October 23, 1999.
William A. Yticu
2 324 S21 L48
Receipt for
Certified Mail
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T. JOYCE DO
Kevin Court
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T. JOYCE O'DONNELL
500 Kevin Court
Camp Hill, PA 17011
PS Form 1. DIcar'hber 1994
2 324 521 148
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WILLIAM A. O'DONNELL, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6433
T. JOYCE O'DONNELL, CIVIL ACTION - LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
1, WILLIAM A. YOCUM, attorney for the Plaintiff, do hereby certify to the
service of an Affidavit of Consent, a Waiver of Notice of Intention to Request Entry of a Divorce
Decree under §3301(c) and a Counter-Affidavit, which were deposited in the United States mail
on January 24, 2000 and received by the Defendant on XX*KMM
.Tnnnnry 24, 2000 Defendant verified receipt on this date to
Plaintiff and affixed January 24,2000 to her Consent and Waiver.
January 28, 2000 h,4
William A. Yocum, mey
Z 324 521 L65
Receipt for
Certified Mail
No Insurance Coverage Provided
,o Do not use for International Mail
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Sent In
T. Joyce O'Don
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Street e I Na
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P 0. Slele ens 71P rip
Cam Hill PA 17011
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500 Kevin Court eglstered Grulied t
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