HomeMy WebLinkAbout99-071971`'
IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
STATE OF PENNA.
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AtitorL?/ /{ GtIPrS7- I? No. q9 -?I9 -- i iiy 17errh
VERSUS
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DECREE IN
DIVORCE
AND NOW, n(J, tI ItA 2000 IT IS ORDERED AND
DECREED THAT A-ttDn-El-j A _ Cfl7acs-r- , PLAINTIFF,
ANDI'C'EER:? I T- C'HP IS7- 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;
BY THE COURT:
ATTEUIT: J
PROTHONOTARY
AUDREY A. CHRIST,
Plaintiff
V.
JEFFREY J. CHRIS'r,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 7197 CIVIL TERM
CIVIL ACTION - LAW
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:
Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Service was accepted by the
Defendant on or about Dom. (S ,1 999, by hand delivery, as evidenced by
the Acceptance of Service executed by Defendant and filed simultaneously herewith.
3. Date of Execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: By Plaintiff d--t-&tx 2000, By Defendant " 2 , 2000.
4. Related claims pending: None.
5. Date Plaintiffs and Defendant's Waivers of Notice under Section 3301 (c) of the Divorce
Code was filed with the Prothonotary: Waivers of Notice are being filed simultaneously herewith.
Date: ! ti Z? p
1 T
Audrey A. Christ, Plaintiff, prose
1208 Allendale Road
Mechanicsburg, PA 17055
(717) 795-7208
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AUDREY A. CHRIST, IN THE COURT OF COMMON
-PI-EASIPRIVATE )
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 9,_ -// 9 7 ?,-?? (ter
JEFFREY J. CHRIST, CIVIL ACTION - LAW
Defendant IN DIVORCE
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following papers, 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. A list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Court House, One Courthouse Square, 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.
Court Administrator
Cumberland County Courthouse
4th Floor
Carlisle, PA 17013
Phone: 240-6200
Audrey A. Chi , prose
AUDREY A. CHRIST,
Plaintiff
V.
JEFFREY J. CHRIST,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 7197 Cuw! Tt,.
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
To the Within Named Defendant:
You have been named as the Defendant in a divorce proceeding filed in the Court of
Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section
3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend
marriage counseling prior to a divorce decree being handed down by the Court. A list of
professional marriage counselors is available at the Office of the Prothonotary, One Courthouse
Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you
are not bound to choose a counselor from this list. All necessary arrangements and the cost of
counseling sessions are to be bome by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within twenty
(20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of
your right to request counseling.
Prothonotary
2
AUDREY A. CHRIST, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
NO. 7/4 7 Cc?
V.
JEFFREY J. CHRIST, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
1. Plaintiff, Audrey A. Christ, is an adult individual, Social Security No. 191-58-0201,
who currently resides at 1208 Allendale Road, Mechanicsburg, Cumberland County, Pennsylvania
17055.
2. Defendant, Jeffrey J. Christ, is an adult individual, Social Security No. 175-40-5257,
who currently resides at 249 Lincoln Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on January 6, 1987, in Mechanicsburg,
Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the parties.
6. The Plaintiff is a citizen of the United States of America.
7. The Defendant is not a member of the Armed Services of the United States of
America or its Allies.
8. The marriage is irretrievably broken.
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9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
10. Plainlif fwquests the Court to enter a Decree in Divorce.
WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the
marriage between the Plaintiff and Defendant.
Date: By: (_/U.-f-6 L a . C(I
Audrey A. Chr' , pro se
1208 Allendale Road
Mechanicsburg, PA 17055
(717) 795-7208
4.
VERIFICATION
I, Audrey A. Christ, verify that the statements made in this Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to uns%vom falsification to authorities.
Date: ::n / oy-. t7 I_ rj, ,L ,2
T- t -? Audrey A. C? ist, Plaintiff
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AUDREY A. CHRIST, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO, 99 - 7197 CIVIL TERM
V.
JEFFREY J. CHRIST, CIVIL ACTION - LAW
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Jeffrey J. Christ, hereby acknowledge that I accepted service of the Complaint in Divorce
in the above-captioned action by way of hand delivery on or about 1 t'_C Ci I 1999•
1 verify that the statement contained herein is true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom
falsification to authorities.
Date:/ u'L (' ` 24 Zc d 4 c?
J ifr y J i s 6eendant
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AUDREY A. CHRIST, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : NO. 99-7197 CIVIL TERM
JEFFREY J. CHRIST, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
DJ m,'--- U 1999-
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of filing 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.
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.A. Section 4904, relating to
unswom falsification to authorities.
Date: /L ILI(141
Audrey A. Chris laintiff
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AUDREY A. CHRIST, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99 - 7197 CIVIL TERM
JEFFREY J. CHRIST, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
_ : a r- -3n 1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of filing 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.
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.A. Section 4904, relating to
unswom falsification to authorities.
Dater / V tu^-G//1 2f1 ?oGO 9C Q 4-
Je re J. a ant
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AUDREY A. CHRIST,
Plaintiff
V.
JEFFREY J. CHRIST,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 7197 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
I consent to the entry of a final Decree in Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of properly,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 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 herein in this affidavit are true and correct. I understand
that false statements made herein are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to
unswom falsifications to authorities.
Dater ? ` , Zo 0 X _
J re t, efendant
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CC ?:'
AUDREY A. CHRIST,
Plaintiff
V.
JEFFREY J. CHRIST,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 7197 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
1. 1 consent to the entry of a final Decree in Divorce without notice.
2. I understand that I may lose rights conceming alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. 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 herein in this affidavit are true and correct. I understand
that false statements made herein are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to
unswom falsifications to authorities.
Date: r, 641 ;Z-`E1 ?o v U
Audrey A. Christ, Plaintiff
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