HomeMy WebLinkAbout99-07111a
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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;
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Prothonotary
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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
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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.
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Cumberland CountyIr {A?s
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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
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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
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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
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COMMONWEALTH OF PENNSYLVANIA
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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
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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.
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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. )
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DATE BETTY E AINE ARNOLD
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