Loading...
HomeMy WebLinkAbout99-071971`' IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF PENNA. ? ?itlf Y? AtitorL?/ /{ GtIPrS7- I? No. q9 -?I9 -- i iiy 17errh VERSUS r?? ?T c?+-2rS r- II 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 .n ;. - = = , J % .; :_. ? ? _ ` ? ? , t:v ? : ? ?c_ . :?, ? ? . ? U 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. -m 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 5 1 ?1 L h ?? -° 1. _ lr ? 1 ,? ri in ? U u ? U v n I 7, r V 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 (u !LL 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 ;.n c- _. .]L L' O Z) r. 1 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 1 f ? • r. C3 C7 J 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 Gl 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 vi ? :: ' =' ? - ?__ ." ?-_ r, F? ._ ?._ ? b .' c? U