The URL can be used to link to this page

Home My WebLink About99-06725 ? I ??> •............. .....................................,......... IN THE COURT OF COMMON PLEAS OF CUMBERL-ANDCOUNTY c;. STATE OF r` PENNA. VALERIE MARTE-_NORTON____ N O. 6725 1999 Plaintiff VERSUS ALAN ROY NORTON Defendant DECREE IN DIVORCE AND NOW, 2000 , IT IS ORDERED AND DECREED THAT VALERIE MARIE-NORTON PLAINTIFF, AND ALAN ROY NORTON ARE DIVORCED FROM THE BONDS OF MATRPIONY. DEFENDANT, 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: BY T H c C,)U RT: ATT E S, 1: PROTHONOTARY i?: l h VALERIE MARIE NORTON, Plaintiff VS. ALAN ROY NORTON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 99-6725 CIVILTERM PRAECIPETO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under §3301(c) 33fl 1(dj H } ef-FFie Divoree-6ede: (Strike out inapplicable section). 2. Date and manner of service of the complaint: 11-5-99, u.s. Mail certified 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 2-15-00 ; by defendant 2-28-00 (b) (1) Date of execution of the affidavit required by §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: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: J- /- Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: VALERIE MARIE NORTON Plaintiff V. ALAN ROY NORTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-L7;:? 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 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 Court House, 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. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 VALERIE MARIE NORTON Plaintiff V. ALAN ROY NORTON Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - - "J17' CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through her attorney Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 5000 Ritter Road, Mechanicsburg, Pennsylvania 17055 and is a citizen of the United States. 2. Defendant is an adult individual residing at 917 Audabon Pare Drive, Wake, North Carolina 27511 and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 1 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a resident of the Commonwealth of Pennsylvania for 2 years and had resided continuously therein for at least six months prior to filing of this Complaint. a. 5. Plaintiff and Defendant were married on May 27, 1998, in Blair. Maryland. 6. There are no children of the parties under the age of eighteen (18). COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. 8. There has been no prior action for divorce by either party against the other. 9. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. 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, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, Valerie Marie Norton, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. gesp ctfull mated Peter J. Russo (y- Date: J\._ , ? ? 1?? I I 7171249+4014 P. ?J4 1 VERIFICATION I, Valerie Norton, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 1a Pa.C.S. §4904 relating to unsworn falsification to aulhorities. Date: t l 1 `1 -1( Valerie Norton NOV O1 :9==, 14:52 C J ?=C n? U Lz VALERIE MARIE NORTON Plaintiff v ALAN ROY NORTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 6725 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 5, 1999. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a Final Decree of Divorce without further notice. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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's Office. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, VALERIE MARIE NORTON, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. 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. ? /IGS ?f,i?G o ???c vC?2•!<.u (//Fi,Ltx? DATE VALERIE MARIE NORTON Y f U _) VALERIE MARIE NORTON Plaintiff V. ALAN ROY NORTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 6725 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 5, 1999. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a Final Decree of Divorce without further notice. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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's Office. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, ALAN ROY NORTON, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. 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 ALAN ROY NORTON _ , - CIO I-U ?? J PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 VALERIE MARIE NORTON Plaintiff V. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ALAN ROY NORTON : NO. 99 - 6725 CIVIL TERM Defendant : IN DIVORCE PROOF OF SERVICE OF PLAINTIFF'S AFFIDAVIT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, VALERIE MARIE NORTON, and certifies that on February 22, 2000, he did serve the Defendant, ALAN ROY NORTON with the Affidavit of Defendant Under Section 3301(c) of the Divorce Code requesting his signature thereon by placing same in an envelope addressed to ALAN ROY NORTON, Carillon Assisted Living, 4901 Waters Edge Drive, Suite 200, Ralleigh, NC 27606, and deposited same in the U.S. Mail receptacle for transmittal by first class mail. Respectfully ubmitt d, Peter J. Russo 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Date: February 22, 2000 } LNG i v ?? PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 VALERIE MARIE NORTON Plaintiff V. ALAN ROY NORTON Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 -6ZaS CIVIL TERM IN DIVORCE ACKNOWLEDGMENT OF SERVICE OF COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, Defendant. Alan Roy Norton, and does hereby acknowledge that on the date indicated below he did receive a verified copy of a Complaint in Divorce filed against him in the above captioned case. DATED: A2 Alan Roy Norton l' - C\J N L-t - - [L V\