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HomeMy WebLinkAbout99-06882ti e.1 CY Eve bo v Oft :.: :i: •:O:• •s; .C. <i} W. W. :0:• •:ii W. <0}"bi s?CO_ <i:'.`?,?•.,`?•.,;.,.'???. -iu':0}..{0:• <b:Y^ii {i:{-:?•: ;,. t IN THE COURT OF COMMON PLEAS t ! OF CUMBERLAND COUNTY '•' N N A K" ?`?' . STATE OF P E 0 TERESA LYNN DAMONi 99-6882 Civil :. Plaintiff MARK DAMON, Defendant 0 ? i. 4 e DECREE IN DI V 0 R CE Z? P i J AND NOW,........ , .... • . it is ordered and decreed that ..ERESA,LYNN.DAMON ................................ plaintiff, ••' .. .... . . . . . . . . . . . . . . . . . . . MARK DAMON ............. .......... defendant, and ...... 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 s been entered; ?? is '• kk .... O'.v.?....................... ; :+.: ............... ................................... ............ .. t t I V z V Prothonotary o r r , f W -:V S X77 00 . Cj h?? f <uf 4 i i ` - cam. . ?: ur Lj- 1 _ . a 1EIeSC; Lynn l?Anior 1'.. ?:, " .,.,. ...ADS, 1iJ '1'1iE CUCJR'I' CE COMMON PLEAS Plaintiff CJi•;IIi:R.LF•VD COCIN'1"i, PENNSYLVAbiIA VS. : D10. 1`199-5;H2 CIVIL mARK WivioU nnrrrizc nnmc,?,r?[?.:r,:??5 ' Defendant CIVIL ACTION - FA2,1ILY DIVISION - DIVORCE PRFtECIPE TO TRA2v131IIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the COllYt for entry Of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(x_)(1) of the Divorce Code, 2. Date and mariner of service of tii,:, complaint: November 15, 1999, certified mail. 3. (a) (1) Date of execution of the Affidavit of Consent required by Section 3301(c) Of the Divorce Code by Plaintiff: February 19, 2060 Of execution of t' `) Date ne ar,.davit of Consent required by Section 3301(c) of the Divorce COdn -y Defendant: February 1-1, i999 +. Related Claims Fending: None. There are no ec,-,:,,:mic clai:ra as a.aets ha.t OrP_vlously been distribute:i. 5. (a) Date Plaintiff's waiver of Notice in section 3301(c) Divorce was filed with the prothonotary: February 19, 2000 (b) Date Defendant's waiver of. Notice in Section 3301(c) Divorce was filed with the prothonotary: February 18, 1999 Attorney for Plaun Scott Alan Bly Attorney ID 1171887 P.O. Box 341 Hershey, PA 17033 (717) 533-8315 I TERESA LYNN DAMON, Plaintiff. 14ARK DAMON, VS. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. i? 1 ? ? ?tlf+ C CIVIL ACTION - FP14ILY DIVISION - 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 for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to vou, 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, Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED YOU14AY 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 LAWYER REFERRAL SERVICE Court Administrator, 4th Floor Cumberland County Courthouse Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 TERESA LYNN DAMON, Plaintiff vs. 14ARK DAMON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - FAMILY DIVISION - DIVORCE TO THE HONORABLE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Teresa Lynn Damon, by her attorney, Scott Alan B1y, Esquire, and files this complaint in Divorce, and in support thereof avers the following: COUNT I SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Teresa Lynn Damon, who currently resides at 506 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070 and has resided there since on or about October 30, 1999. 2. Defendant is Mark Damon, who currently resides at 912 Trudy Road, Harrisburg, Dauphin County, Pennsylvania 17109 and has resided there since on or about 1963. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 18, 1998 in Swatara Township, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage has been irretrievable 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 avers that neither Plaintiff nor Defendant is in the military service. 9. Plaintiff avers that there are no children of the parties under the age of 18: WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE (Alternative to Count I) 9. Plaintiff incorporates the allegations of every paragraphs enumerated above of this Complaint as if said paragraphs were fully set forth here at length. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT I I I EQUITABLE DISTRIBUTION 10. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. WHEREFORE, Plaintiff requests the court to allocate equitable distribution between Plaintiff and Defendant. Scott Plan Bly Attorney for Plaintiff I.U. 1171887 P.O. Box 341 Hershey, PA 17033 (717) 533-8315 I, ? by affirm nhat- all re[ UkOntc Kul'o in tllf_' are tt1C' u) the best of my knowledge. ? understand that: 'vise t:ssert_ons may lead to my prosecution under 18 Pa. C.S.A. Section 4904 :'or i;nsworn Falsifica,- on to Authorities. Date: PR00[ OF SGRVICE The undersigned certifies that a ropy of the foregoing instrument was served upon the attorneys of record of all parties to the above cause, or parties of record if not represented by attorneys, by mailing same to them at their- respective addresses as disclosed by the pleadings of record tie ein %,i.th postage fully pre aid thereon on the IS'' day of 0.)y ,i 19 I declare that the statements above are true to the best of my knowledge, information and belief. Respectfully submitted, I AQi Scott Ala n Bly V Attorney at Law p.0. Boy. 341 Hershey, PA 17033 (717) 533 -8315 i? r:. ON r ,. C f I ? y TERESA LYNN DAMON, Plaintiff MARK DAMON, VS. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6P82 CIVIL CIVIL ACTION - FA14ILY DIVISION - DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 15, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 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. 4904 relating to unsworn falsification to authorities. Date: A-/9 a' Teresa fnn?Damon TERESA LYNN DAMON, Plaintiff VS. MARK DAMON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6082 CIVIL CIVIL ACTION - FAMILY DIVISION - DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 15, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 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. 4904 relating to unsworn falsification to authorities. Date: ^?J Ui Mark Damon r TERESA LYNN DAMON, Plaintiff VS. MARK DAMON, Defendant CERTIFICATE OF SERVICE I hereby certify that on this day of wiaftLP 1S , ffl? , I have served the foregoing document upon the person(s) and in the manner indicated below. Service in person by certified mail, return receipt attached: Mark Damon 412 Trudy Road Harrisburg, PA 17109 Dated: al11Wo ?4 & - BI, Scott Alan Bly, Esq...--_ Attorney for Plaintgy_qW.qy_qWpVpqpmjWqpMW _ 1. Article Addressed lo: .4a -T(adlij k-cl. 140m s6u: ',6-' , PA ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. to Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. j'I 6691 Cwi`1 CIVIL ACTION - FAMILY DIVISION - DIVORCE A. Received by (Please Print Clearly) B. Date o Delivery C. Si lure ?? Ag X0 v+] ?+ r? A L1`?1'IO Addressee D. Is Ae very address different from item 1? ? Yes If YES, enter delivery address below: ? No )1 )1: ?? 3. Service Type Certified Mail ? Express Mail Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (Copy from se vico label) PS Form 381 t-uuy`,99g Domestic Return Receipt I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TERESA LYNN DAMON Plaintiff VS. MARK DAMON Defendant File No _ 99-6882 Civil IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff /Defendant in the above matter, having been granted a Final Decree in Divorce on the 20th day of March 2000 , hereby elects to resume the prior surname of Costello , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: C8-.-A-CO . ?,ip4 , V Signature !L,, d gnat a of name being resumed COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND _4LOC/ n On the trrl? day of -yVfa Lc-/ 1-9- , before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. seal. In Witness Whereof, I have hereunto set my hand and official ,?L9-LtcLLL'i_? t7`t?tl%CtfG?7•?L'v-' Notary Public E t:, idc:ory R::::- on Go?nt?, ?i. luy Ib, .JOI ip;_flir 1?