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Home My WebLink About03-3462 CRYSTAL C. JAMES, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03 - 3462 Civil Term vs. RICHlE L. JAMES, ACTION IN DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter. affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFlDA VlT OF SEP ARA TION 1. The parties to this action separated on September 21, 2002 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 my 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. 94904 relating to unsworn falsification to authorities. Date: q -:J.,,~ ~(j" f!'Lr-/L1 fI, )f/VTU4- 1/ 8 "'" ~ <=> <=> $: .r- -0 lX) en :r ~~H IT! m~ -0 Zlj; N :gZ ~"" -' _. ~:r' C'I ;.::: .. -u ~o ::J:: ~(~ :>0 rn C ~ ~ ~i5 tN '< vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0 3 - 3~ I. do. Civil Term CRYSTAL C. JAMES, Plaintiff RICHIE L. JAMES, : ACTION IN DIVORCE Defendant 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. Where the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 CRYSTAL C. JAMES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term RICHIE L. JAMES, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE I. Plaintiff is Crystal C. James, a competent adult individual, who has resided at 373 A. Sherwood Drive, Carlisle, Cumberland County, since October 2002. 2. Defendant is Richie L. James, a competent adult individual, who resides at RD#3, New Bloomfield, Perry County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married in April 2000 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is availab'e and that p'aintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens ofthe United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces ofthe United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, P'aintiffrequests the court to enter a decree in divorce. 1 verify that the statements made in this Complaint are true and correct. I understand that false statements herein. are made subjecfto the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. (1M ~,~ Cryst~, Plai& . Respectfully submitted, Date: /-r;J-l-03 ~~ e Adams, Esquire . No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -- (--, ( ~ ~ ~~ .. ~cg!..... .. (n & . ') H, :c: ieo ....c ~ ~ :1. V' CRYSTAL C. JAMES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 03 - 3462 Civil Term RICHIE L. JAMES, : ACTION IN DIVORCE Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Respectfully submitted, "", r;( 7,1" ~3 ams, Esquire . No. 79465 South Hanover Street Carlisle, POl. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF (') c: <"" tJ ct' n\f",", Z::.t :;?:: [~. 0) ,,' ~r~.' ..::: -. 2:-"c' ;SC, )>or" :::;;- ~ ~ c:' C,,) u') rq " I o " :=.-3 ',\_!.,' ., nrn ~J~s '''';-11 :~:JJ -=-:..-C) ~Jm '< .;. -0 :J:;: f:-? r:- (D LEE N. STONE, Plaintiff vs. ESTHER S. STONE, Defendant - : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 03 - 3464 Civil Term : ACTION IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: P'ease reinstate the Complaint in the above-captioned matter. Date:q ..~. D~ Respectfully submitted, R~ Adams, Esquire I.D No. 79465 South Hlmover Street Carlis'e, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -. . ," () c: '" "Oi'!:: nlp--, z.':' zr U) ., -r' ",' r:: ~~- ~~~ ~(-~ 5>cc~ ...::::: ...,. C) W .:;:, ,.., "1J I .~' "'U ::l:: r:-7 r-- "",.J o~ " :'1 J'l ':Ie] . , ::;(~) --.\:8 ~:: ~2 m'}i" :;':' ::5 -< CRYSTAL C. JAMES, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 0 3-~Lt /c. ~ Civil Term : ACTION IN DIVORCE RICHIE 1. JAMES, Defendant AFFIDAVIT OF SERVICE AND NOW, this September 22, 2003, I, Jane Adams, Esquire, hereby certifY that I caused a certified true copy of the NOTICE TO DEFEND, PRAECIPE TO REINSTATE, AND COMPLAINT IN DIVORCE, to be served on the following Defendant at the following address, via hand-delivery, delivered personally by Pennsylvania State Constable Irving Wallace on September 12th, 2003. Richie 1. James at Cressline Plastic Pipe 264 Silver Springs Road Mechanicsburg,Pa.17055 DEFENDANT """"Wly~ ane dams, Esquire I.D. o. 79465 outh Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF - Irving Wallace Pennsylvania State Constable 3 Yz East Louther Street Carlisle, PA 17013 SEPTEMBER15,2003 JANE ADAMS ATTORNEY AT LAW 36 SOUTH PITT STREET CARLISLE PA. 17013 RE: JAMES V. JAMES NO. 03- 3462 CIVIL TERM (CUMBERLAND COUNTY) REMARKS: SERVED MR. RICHIE L JAMES SERVED COMPLAINT AND PRAECIPE. Served RICHIE L JAMES@ 6:20 PM on 09-12-03 AT 264 SILVER SPRINGS RD. MECHANICSBURG PA. 17055 PLEASE REMIT FEE OF: $45.00 PAIDBYCHECK $45.00 ~, Irving Wallace Pennsylvania State Constable 3 % East Louther Street Carlisle, PA 170}~ g ";;:: vC!..: fnrn Z:I' 2T U'^'.; ~c"; ~O "",0 .---c z: ::;! <::> (..) U') r.." ...0 r-0 ..0 o -n .,...~ :~:~~ ?J ,-'1 _.0 '.;J~~ ::_,}~~ ~,~-,,(n '::'4 "p' ~ -0 .,. -"" N CRYSTAL C. JAMES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 03 - 3462 Civil Tenn RlCHIE 1. JAMES, Defendant : ACTION IN DIVORCE MOTION FOR SERVICE BY REGULAR MAIL TO DEFENDANT'S PLACE OF EMPLOYMENT. AND NOW COMES, Crystal James, by and through her attorney, Jane Adams, Esquire and avers the following: I. Defendant in the above-captioned matter is Richie 1. James, whose last known home address is: RD#3, Box 1251, New Bloomfield, Pa., 17068. 2. A Complaint in Divorce was filed in the above-captioned matter on July 21, 2003. 3. Petitioner was unable to serve Defendant with the Notke to Defend and Divorce Complaint at his last known home address; however, a State Constable did effectuate personal service upon Defendant at his place of employment at Cresline Plastic Pipe, 264 Silversprings Road, Mechanicsburg, Pa. 17055 on September 12,2003. (Please see Exhibit A). 4. On or about September 29, 2004, Petitioner made an attempt to serve Defendant with the Affidavit of Separation, Notice ofIntent to Request Final Decree, and Counter-Affidavit at Cresline Plastic Pipe via certified mail. 5. The certified mail was initially accepted; however, Defendant eventually refused to accept this mail and it was marked "not here temporarily." (Please see Exhibit B). 6. Petitioner believes that Defendant is willfully attempting to avoid service of documents pertaining to the above-captioned matter. 7. Requiring service of Defendant via State Constable or by publication would impose an unnecessary financial burden upon Petitioner. 8. Petitioner reasonably believes that Defendant continues to work at Cresline Plastic Pipe and could be served all documents there by regular mail (See Affidavit, which is attached as Exhibit C). WHEREFORE, Petitioner respectfully requests that this Honorable Court allow further service of all documents, including the Affidavit of Separation, Notice of Intent to Request Final Decree and Counter-Affidavit to be effectuated upon Defendant via regular mail, to his place of employment at Cresline Plastic Pipe. Date:{6!f 8!oy Respectfully sub~, ~~ ane dams, Esquire J.D. o. 79465 36 . Pitt St. lisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF CRYSTAL C. JAMES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 0 3- ~l.llo <~ CiviITerm ('") c.=, RICHIE L. JAMES, : ACTION IN DIVORCE c c, ::;:: V) Defendant '"0 n,. ,.,., r:p IT! . ''(1 ~(.' -" -<:',:- \..0 ~C! _~ }:,.--, _<-'-0 AFFIDAVIT OF SERVICE ~~~ __ AND NOW, this September 22, 2003, I, Jane Adams, Esquire, hereby certifY =1hat r caused a certified true copy of the NOTICE TO DEFEND, PRAECIPE TO REINSTATE, AND COMPLAINT IN DIVORCE, to be served on the following Defendant at the following address, via hand-delivery, delivered personally by Pennsylvania State Constable Irving Wallace on September 12th, 2003. Richie L. James at Cressline Plastic Pipe 264 Silver Springs Road Mechanicsburg, Pa. 17055 DEFENDANT Respectfully Submitted: G~~ . ~ ane dams, EsqUire J.D. o. 79465 outh Pitt Street Carlisle, Pa. 17013 (717) 245.8508 ATTORNEY FOR PLAINTIFF - EXHIBIT l:t -- o -q ,'1', . j ~~~ _";-TlI . .'c') grn 7'~ J:) -< Irving Wallace Pennsylvania State Constable 3 Yz East Louther Strleet Carlisle, PA 1701 ~I SEPTEMBER15, 2003 JANE ADAMS A TTORNEY A T LAW 36 SOUTH PITT STREET CARLISLE PA. 17013 RE: JAMES V. JAMES NO. 03- 3462 CIVIL TERM (CUMBERLAND COUNTY) REMARKS: SERVED MR. RICHIE L JAMES SERVED COMPLAINT AND PRAECIPE. Served RICHIE L JAMES@ 6:20 PM on 09-12-03 AT 264 SILVER SPRINGS RD. MECIlANICSBURG PA. 17055 PLEASE REMIT FEE OF: $45.00 PAIDBYCHECK $45.00 )/ //d }thj!(::~/ Irving Wallace Pennsylvania State Constable 3 % East Louther Street Carlisle, PA 1701:J:. Ir~.~_ jt:;............ . ~~ 1~ R.~ >'. . P\~ . '}Co'-\ s\\~~\ ~ ~\iJY:r 'P~ :.. \\PSO-~8~D Article Numb8tl (Tiansfer from 8ftrlce 0 '. Ps Form 3811, August 2001 .~~~"'. ,. 3. Service Type · Certified Mail 0 Express Mall o Registered 0 Return Receipt for Merchandlae o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes - ...ii... ~''1'''', Domestic Return Receipt '02S'S.02.Mo'"O 7003 1010 0004 7818 6770 .~~~t~~~l~"~. , . UNITED STATES POSTAL ~.~ ~I\' t:" ,1'\-\' \\''''. _.-1S..- saU--." . \..'; \ 1, ~ . "':~-..' ;jostage & FeeS...P~kl m. . ' ,.,," ~ " .; USPS . , (i . . .. _,0' Permit No. G-10 "~". ~~ ~----~-_._--_..-.. ..-: :.:~~ . Sender: Please print.~Ollrn\iJt'13, acidres', if\~ ;~jp...41l1lt1isbOl<-. ~~. ~.\$\C~V'):~;\ ';.2..1 <- 1$ ,U-,,-,." c-}\':;'. , ,\.1 ., I CLv~,lA"\'--_1~r1 'l)i3 11I.\\i."l\\1!' !I.II..i\ lI' II .,,1.1,,\,\, iI\'i' 11.1.\,,\, ,i ,i ",?Cfi:'";.i-:::2:2.F:. ----_......._""''''......,.'..'~ "'_=-c"~~,",-"..-,,,",,"",' '" ... '" I'- '" C] C] C] C] ... C] ... '" C] C] I'- '( .' 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ArIlcIeNlITIber ~~"'Y'F"~I" Ps Form 3811, AUguSt 1". - , . :'3""..~' .~, ..:ik.", 3.ServIoe~ . CertIfIed MafJ 0 EXpr...M.ir. o Aeg'*'ed 0 Rettm ReceIpt for tMrchandlae DII'IIInd.MaII Dc.a.D. 4. ReelrIctedDelJv8ry?f&t;8Fee) aYes ["Xl-bB IT IS 7003 1010 0004 7818 6770 b'on\abchtMUhl~ptlJi J HIli il 1~'540 ,.,..... CRYSTAL C. JAMES, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 03 . 3462 Clivil Term RICHIE 1. JAMES, : ACTION IN DIVORCE Defendant AFFIDAVIT Affiant, Jane Adams, Esquire, hereby deposes and avers that pursuant to attempting service upon Richie 1. James, Defendant in the above-captione:d matter, the following actions were undertaken by affiant: I. On July 22, 2003, Affiant attempted to serve Richie James (hereinafter "Defendant" with the certified true copy of the Notice to Defend and Complaint in Divorce at R.D.#3, Box 1251, New Bloomfield, Pa. 17068 via certified mail, restricted delivery. Defendant did not claim this mail and it was returned to Affiant. 2. On September 22,2003, Affiant caused a certified tme copy of the Notice to Defend and'Divorce Complaint to be served on Richie James at his plal:e of business at Cresline Plastic Pipe, located at 264 Silver Springs Road, Mechanicsburg, Pennsylvania, 17055, via State Constable. 3. On May 4, 2004, Affiant sent a letter to Richie James at Cresline Plastic Pipe via regular mail. This mail was accepted. 4. On or about September 29, 2004, Affiant attempted to serve Richie James the Affidavit of Separation, Notice of Intent to Request Entry of Divorce Decree, and Counter- Affidavit via certified mail. Although Sherri Smart initially signed to accept this mail, the mail was eventually marked "not here temporarily" and was returned to Affiant. 5. On or about October I, 2004, Affiant called Cresline Plastic Piping at (717)766-9262 and asked if Richie James currently worked there. The person at the other end of the line confirmed that he did currently work at that location. - eXHIBIT c. 6. Affiant searched Superpages.com but found no other address listed for Richie James which could be used to effectuate service. Date: (0 (;3 /~ r; . ane Adams, Esquire J.D. No. 79465 36 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND ) On this, the /3'- day of (j~ ~ , 2004, before me, the undersigned officer, personally appeared JANE ADAMS, ESQUIRE known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. C/Qurh~C f1t,urt~ Notary Public My commission expires: rf -,-/-6 ";, - SEAL , NOTARIAL SEAL . CLAUDIA~. Bi1EWBAKEf1. NOTARY PUBliC CarliSle Bora, Cumberland Courlty My Commission bi~dfes Apl'it I.), 2005 '.' 0 ~" <-:"~::'I G'~::.Jo ~- n.) .-'-1. q -'':1 -. c.~) ...r:- CRYSTAL C. JAMES, Plaintiff vs. RICHIE L. JAMES, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA y : No. 03 - 3462 Civil Term : ACTION IN DIVORCE ORDER AND NOW, this ,Z&. I day of, tffirJ"~ 2004, after careful consideration of Plaintiff's Motion for Service by Regular Mail, it is hereby ORDERED and DECREED that Plaintiff may serve all future documents filed in the above-captioned matter upon Defendant via regular mail, to his current place of employment. cc: ~e Adams, Esquire ..Aichie L. James ) J. /lJ ~ ~ /6)t -01 ,..,,11 ) </ 'n! ".. .'.)' \':J ._, I--JI'"Z lJ. ,'!} 'i:!.,1 ... V ....~..,. ,,~J CRYSTAL C. JAMES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 03 - 3462 Civil Term RICHIE L. JAMES, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE. AND NOW, this October 28,2004, I, Jane Adams, Esquire, hereby certify that on October 27,2004, a certified true copy of the Affidavit ofS(~paration, Counter-Affidavit, and Notice ofIntent to Request Final Decree in Divorce were served, via regular mail, addressed to: .... Richie L. James Cresline Plastic Pipe 264 Silver Springs Road Mechanicsburg, Pa. 17055 DEFENDANT . , U.S. POSTAL SERVICE MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, D<(ES N PROVIDE FOR INSURANCE-POSTMASTER , f One piece 01 ordinary mail addressed to: ~'I~'t-e l- ,3"'o,,,,,,u ~ ~ ~1t.J..e PI a.~.t\"(. ~~ d fol.\ L;,\i0c ~'i~ {fJw. \)-'\ {V\'I.n~v~' (A \ lQ~ PS Form 3817, January 2001 Respectfhlly Submitted: ~O--- an Adams, Esquire I. . No. 79465 6 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF g ~ 0 c;:) -n ,""'" J:" -;,... ~ ~:!1 "9] ~.. fTl ~)"; I ~6 ;;.:: .. ~v k:: CJ -0 ~~ ~(') 3 5>2- - 0 ~ .. ?IS N c.n .....( CRYSTAL C. JAMES, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 03 - 3462 Civil Term RICHIE L. JAMES, : ACTION IN DIVORCE Defendant AFFIDAVIT OF NON-MILITARY SICRVICE Plaintiff, CRYSTAL C. JAMES, deposes and says that she is the Plaintiff in the above- captioned matter; that she personally knows that RICHIE L. JAMES, Defendant, is over the age of 18 years; is not in the military service as defined in the Soldiers' and Sailors' Relief Act of 1940 and its amendments hereto, for the following reasons: he works in Mechanicsburg, Pennsylvania. Plaintiff verifies that the statements made in this Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: I J - ~ - () 4- ~I'O~ (- . Crystal . James, Plainti 0 ,....., 0 = ~~~ = ., ..c- i-, z -l I-r'l l' CI nl- .....r.:; -0 fTi L ." I -ljO o..D Of) ::rI'-f; -0 96 '- :n: (; "-";'rn c: ", CJ --I ~';..." """:'::,.. :3 ::.q --- Ul ... ... -c. I' .... CRYSTAL C. JAMES, P'aintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 03 - 3462 Civil Tenn RICHIE L. JAMES, : ACTION IN DIVORCE Defendant NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Richie L. James clo Cresline Plastic Pille 264 Silver Sprinl!s Road Mechanicsburl!. Pa. 17055 DATE: October 27. 2004 You have been sued in an action for divorce. You have failed to answer the Complain or file a Counter-Affidavit to the 3301(d) affidavit. Therefor~ on or after November 17,2004 the Plaintiff 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 date above, the Court can enter a final decr e in Divorce. Unless you have already filed with the Court a written claim for economic relief, u must do so by the above date or the Court may grant the divorc~ and you lose forever the right 0 ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH T E PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court awritten claim for economic relief, you m st do so by the above date or the court may grant the divorce and you will Jose forever the right t ask for economic relief The filing of your 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, OR CANNOT AFFORD ONE, GO TQ OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 . !. CRYSTAL C. JAMES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 03 - 3462 Civil Term RICHlE L. JAMES, ACTION IN DIVORCE Defendant COUNTER-AFFIDAVIT UNDER SECTION 3301( d) of the DIVORCE CODE I. 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 wish to make any claims for economic relief. I understand that I may I e rights concerning alimony, division of property, lawyer's fees, and expenses ifI do not claim them before a divorce is granted. _(b) I wish to claim economic re'iefwhich may include alimony, division ofprope 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 ofIntention to Request Divorce Decree, the divorce deer e may be entered without further notice to me, and I shall be unable thereafter to file any econom claims. I verity that the statements made in this counter-affidavit are true and correct. I understand that tillse statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: Richie L. James, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. ....' C;-:") 'i~ ":.,.) CJ ~ ..."~ (,,., CJ C) CRYSTALC.JAMES Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 03 - 3462 Civil Term RICHIE 1. JAMES, ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a div ce decree: 1. Ground for divorce: irretrievable breakdown under &3301 (d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered bv State Constable. at Defendant's olace of emoloymenl. on September 12.2003. 3. Date of execution of the affidavit required by ~3301(d) of the Divorce Code: By Plaintiff: September 23, 2004. Date of filing and service of the plaintiffs affidavit of separation required by ~3301(d) of the Divorce Code on respondent: Filed: September 27, 2004 Served on Defendant: October 27, 2004 Affidavit of Service filed: November 1, 2004. 4. Related claims pending: No claims raised. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Delivered on October 27, 2004, pursuant to order of court, via regular mail at defendant's place of employment. Date: l\ - 3D - 01 j Adams, Esquire .D. o. 79465 36 . Pitt St. lisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ~B, C) c:""' ~n ""- --- J,' ,~ C~) C~:.:: c..) c:' -,;,} (,,) {".,~ <.::l ~ . . . . . . . . . . . . . - ~~+.~++.+.~+++.++.+.+.+. +. +. +. + + + +.++ ++ ++ ++ + + '+ +. +. + +.+ +. + + +:1' +. +:+ + +++:++++++++.+++.++ IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY STATE OF PENNA. . . . . . . . . . . . . . . . . . . . Crystal C. James, Plaintiff No. 03 - 3462 Civil Te No. VERSUS Richie 1. James, Defendant . . . . . . . . . . . . . . . . . . . DECREE IN DIVORCE tiH .;2q~ 'I :Pee . 1-- , IT IS ORDERE AND NOW, Crystal C. James . . . . . . . . . . . . . . . . . . . . . . . . . . . DECREED THAT , PLAINTIFF, Richie 1. James AND , DEFENDAN , ARE DIVORCED FROM THE BONDS OF MATRIMONY. ++++++++.+ . . + . + + + + . + + + + . + + . . + + + + + . + + + + + + + + . + + + . + + + . + + . + + + + + + . + . + . + AND + . + + + + + . + + + + . + . + . + + + + + + + + + + . + + + + + + . + . + + + + + + . + + + ++++++++ THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAiSED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA YET BEEN ENTERED; None. . . . . . + + . . . . . + . + . . . . . . . ++ +. +. +. '+' + u;:;J AmS1~ ~ PROTHONOT ++++-0:++++++'1- +++++:++ + . ++++++++++++++++++++++++++++++++++ NOT J. RY 1 < /"!'r<fr1/ r;Hf:J1 L. /1,7{7 ('/ . ,A7,\.-' 1 (/ lJiA '*' 1 {1 ^. ~.' f-i/ . ,,' . )>V." C/ ~ 1;:1' 'C /'1''':' , ,," ..' ------