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HomeMy WebLinkAbout99-07111a a a 1h I 1 1114 i r IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY STATE OF r't+. PENNA. JOHN.. H... ARNOLD 11 ) ............... 9.9.-71 1.?............. ............Plaintiff .................................................. . Versus BETTY.. ELAINE.. ARNOLD, ...................... .... Defendant........... DECREE IN Di V O R C E 1T1f??r?? AND NOW,... ttA.4'?.?........... ? ,,, 1?4" •'//?? • , it is ordered and decreed that ..... J?o -}1J .. • 4 • ' • • Aii:WQ•j. • • • • • • • • • • , Plaintiff, and ...6.EX-7!?} ... G.(,4&./PJC.. Af.20.gb ............. defendant, 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 been entered; /t) ?0. .................................... . ................................ 7 0 :. s o , Prothonotary i lot ?}. 'rWX lx •x• :o: •w • W•. - • C* • :X... ,w?..:o: cc • VV c0 W. :W • O <o:• to:• <o:.. '0 .V. .W. :4 • <s:• a> <e>.:o ' •:o. 60 1.j- ee* JOHN H. ARNOLD, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-7111 Vs. CIVIL ACTION-LAW BETTY ELAINE ARNOLD, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: Grounds for divorce is irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. The Defendant was served with the Divorce Complaint on November 26, 1999. 3. The Plaintiff executed an Affidavit of Consent pursuant to Section 3301(c) of the Divorce Code on April 17, 2000. The Affidavit of Consent was filed in the Prothonotary's Office of the Cumberland County Courthouse on April 19, 2000. 4. The Defendant executed an Affidavit of Consent pursuant to Section 3301(c) of the Divorce Code on April 3, 2000. The Defendant's Affidavit of Consent was filed in the Prothonotary's Office on April 19, 2000. Attorney or Plaintif? Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 (717)-236-9515 it ?. ti .,? } O C, C F?? -? t u.?b ..- ?-?? '? ' j ?.. C ? ?? ; . ?! r rn .? ?' ? _ U i - - .ii ?_ ? ;71G r 3 r? Q U JOHN H. ARNOLD, Plaintiff, V. BETTY ELAINE ARNOLD, Defendant IN THE COURT OF CONIINION PLEAS , CUMBERLAND COUNTY, PENNSYLVANIA NO. qq- 7111 CIVIL ACTION-LAW 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 in 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. 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. r fCAU17 Cumberland CountyIr {A?s l*UF Carlisle, PA 17013-3387 ? Le " F_ (717)?49-`?9@'* -3 (y, By: / `J - Dated: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 (717)236-8515 Attorney for Plaintiff JOHN H. ARNOLD, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. BETTY ELAINE ARNOLD, CIVIL ACTION-LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW this 19" day of November, 1999, comes the Plaintiff, John H. Arnold, by and through his attorney, Joseph J. Dixon, Esquire, who respectfully avers as follows: 1. The Plaintiff is John H. Arnold, an adult individual who resides at 420 Front Street, Marysville, Perry County, Pennsylvania 17053. 2. The Defendant is Betty Elaine Arnold, an adult individual who resides at 8890 Pineville Road, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Both the Plaintiff and Defendant have been bona fide residents of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 31, 1994 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. 7. Plaintiff has been advised of his right to seek marriage counseling in this divorce action, but waives the right to do so. 8. Both the Plaintiff and Defendant are not members of the Aimed Services of the United States or any of its allies. 9. The Plaintiff and Defendant have been separated since February 1999. 10. The Plaintiff avers that the ground on which this action is based is that the marriage is irretrievably broken. WHEREFORE, The Plaintiff prays this Honorable Court enter a Decree in Divorce in accordance with Section 3301(c) of the Divorce Code. Respectfully submitted, By: Zfoseph J. Dixon, Esquire Attorney ID No. 28290 126 State Street Harrisburg, PA 17101 (717) 236-8515 Attorney for Plaintiff VERIFICATION if I that the statements made in this Divorc e Com plaint y ver are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S. 54904, relating to unsworn falsification to authorities. DATED:November 19, 1999 W? ? J c7t, i t- L d i 1 J rig` ? ri M 1>. ..ticn w u: N t,- 7_ ?1 ?, r gnu .na. LLi ON CJ U JOHN H. ARNOLD IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. BETTY ELAINE ARNOLD No. 99-7111 CIVIL ACTION-LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE i it COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Personally appeared before me, a Notary Public, in and for the aforesaid Commonwealth and County, JOSEPH J. DIXON, ESQUIRE, who first being duly sworn according to law, does depose and say that he made service of the Complaint in Divorce upon the Defendant by placing a true and correct certified copy with the Notice to Defend and Claim Rights in the United States Mail at Harrisburg, Pennsylvania. Certified Number: Z 227 572 788 The same was received and acknowledged on behalf of the Defendant, BETTY ELAINE ARNOLD, on this the 26" day of November, 1999, as the addressee. Receipt for mailing is attached hereto. Swore to and subscribed before me this __?_ day of rj v -e 2000. isph J. Dixon, Esquire ey for Plaintiff l- A ?T D.llvVDTT 'OMT 1& T*/:T . i ? SENDER: I v eComptets Items t end(X 2 for adcUftW services. A CaapetaMemoa ab ? I also wish to receive the :P , • 4 Your name arid idtl a address on IN ravens of this form W that we can return We ( C CeM toyyoou. following services (for an B7dfa fee): ' sAttech dds roan to ft had of du matlpiecs, or on the beck it tpaca doe, not ppee o 0Wdtto Refum RwWpt Requested-wommail t 1. ? Addressee's Address , Z p acebelowewerddenumber. $ -the Rolm Racaipt VAN show to rdom a* a We wa, deMend end the data ty 2.?Resblcted Delivery p fnl ` ar?' 0 Consult postmaster for fee. i 3. Article Addressed to: 4a. Article Number I n8e_7 Ty ELAnje 402rVO4p Z Adz 573. 74f od 90 P/Aj E?/&LZ A4,41-, 4b. Service Type ? Registered W? ( SHE Elt/16U?6 ??' ndS 7 fled rc i ? Express Mall ? In ed c ( ? Retum Recelpt for Merchendse ? COD i 7. Date of Delivery ° S. Received 8Y' . (Pdnt Nerve ) B. Addressee's Address (Onty!lrequested . and lee Is paid) `S g 6. g : (Address nf) F T E Rs Form 3811, mbar rasa 10259&97-8-0179 Domestic Retum Receipt r t1 ,^ I G, G 1 1 ?) 1 U ? 1 1f f s 1 4 JOHN H. ARNOLD, Plaintiff BETTY ELAINE ARNOLD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7111 CIVIL CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT & WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on November 23, 1999. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) 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 without formal notice of the intention to request entry of a divorce decree. 4. 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. 5. I 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. Sec. 4904 relating to unswom falsification to authorities. '/'4Z A /J'O H. ARN D _. _ .._.. ?`''. ?= ,:.; - ::? ;;_: -:? ?? _ ,,. _ ';' _ ?r_ •=J J r- J U JOHN H. ARNOLD, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7111 CIVIL CIVIL ACTION-LAW BETTY ELAINE ARNOLD, Defendant IN DIVORCE AFFH)AVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODF, 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 23, 1999. 2. The marriage of Plaintiff and Defendant is irretrievable broken and ninety (90) 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 without formal notice of the intention to request entry of a divorce decree. 4. I understand that I may lose rights concerning alimony, division of property, attorney's fees or expenses, if I do not claim them before a divorce is granted. 5. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree s\wiil be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and con•ect. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 re la ing to unsworn falsification to authorities. ) 3 l?l ?&Ilt_". DATE BETTY E AINE ARNOLD (r-.h z".-T.. "