HomeMy WebLinkAbout99-07334i;
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IN THE COURT OF COMMON FLEAS
OF CUMBERLAND COUNTY
STATE OF tr PENNA.
..... ..KAREN..K....WEBB,................... ._....... .............
................. P.lainti f.f ................................
Versus
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HORACE.. D.... WEBB,. .............. ..................... 'I
....Defendant .... _..._ _ ...... _. ii
No. 99-7334 Civil... 19 99
DECREE IN
DIVORCE
AND NOW, ... 1 .v.t .?....Z.? ......... I D%M• , it is ordered and
decreed that .......... KAREN.K,.,,WEEB ........................ plaintiff,
and ............ HQRKE..R.. W955 ............................. 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; Alo,ve,
By The C rt: ;•;
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Attest:
:.
-- prothonotary
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KAREN K. WEBB, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PA
VS. : NO. 99-7334 CIVIL TERM
HORACE D. WEBB, ;
Defendant IN DIVORCE.
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the following information, to the Court for
entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the complaint: December 13, 1999 by Certified
Mail Restricted Delivery U.S. Postal Service.
3. (Complete either paragraph (a) or (b).).
a. Date of execution of the affidavit of consent required by Section 3301(c) of
the Divorce Code: by plaintiff on March 14.2000; by defendant on March 14, 2000.
b. (1) Date of execution of the affidavit required by Section 3301(d) of the
Divorce Code:
(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE
5. (Complete either (a) or (b).)
I
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached: N/A
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary: March 14,
Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary:: March 14, 2000.
0% 1&
Dater HENRY F. CO ESQUIRE
Attorney for Plait if
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KAREN K. WEBB,
Plaintiff,
VS.
HORACE D. WEBB,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. ?79 733y CIVIL TERM
: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 of 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013
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, TO GET LEGAL HELP SHOULD
CONTACT:
Cumberland County Lawyer Referral Service
2 Liberty Avenue, Carlisle, Pennsylvania
1-(800)-990-9108
COYNE & COYNE, P.C.
Henry F. Coyne, squir-eI If JA
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa.. Supreme Ct. No. 06250
Attorney for Plaintiff
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KAREN K. WEBB,
Plaintiff,
VS.
HORACE D. WEBB
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 0 % • 7-3-yY CIVIL TERM
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE
NOW COMES the Plaintiff, Karen K. Webb, by her attorney, Henry F. Coyne, Esquire and files
this Complaint In Divorce and avers the following in support thereof:
1. The Plaintiff, Karen K. Webb, is an adult individual residing at 307 North Market Street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant, Horace D. Webb, is an adult individual residing at 633 Lititz Manor
Drive, Lititz, Pennsylvania 17543.
3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on March 16, 1985, at Mechanicsburg,
Cumberland County, Pennsylvania, and separated on or about March 13, 1999.
5. The Defendant is not a member of the Armed Services of the United States or any of its
Allies.
6.
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There are no children of the marriage.
There have been no prior actions of divorce or for annulment between the parties.
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8. The marriage is irretrievably broken.
9. 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. Further, Plaintiff waives his
right to request that the parties participate in marriage counseling.
WHEREFORE, Plaintiff respectfully requests that this Ho;
Divorce to Plaintiff.
Dated: 2 !l &P, q 9
Respectfully submitted
COYNE & COYNE, R
IWIZIdA
HENRY F. COYNE E:
3901 Market Street
Camp Hill, PA 17011-
(717) 737-0464
Pa. S. Ct. No. 06250
Attorney for Plaintiff
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VERIFICATION
The facts set forth in the foregoing are true and correct to the best of the undersigned's
knowledge, information and belief and are verged subject to the penalties for unswom
falsification to authorities under 18 Pa. C.S.A. §4904.
Dated: / y ° `f
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KAREN K. WEBB,
Plaintiff
VS.
HORACE D. WEBB,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. W-7337 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To The Prothonotary:
Kindly allow, Karen K. Webb, Plaintiff, to proceed in forma oauneris
I, Henry F. Coyne, Esquire, attorney for the party proceeding in forma nauneris, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to the party. The
party's affidavit showing inability to pay the costs of litigation is attached hereto.
Dated:-,9. '-/ 6N` el 9
HEOY , QUIRE
Co:: ne & Coyne, P. .
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. S. Ct. No. 06250
Attorney for Plaintiff
KAREN K. WEBB,
Plaintiff
VS.
HORACE D. WEBB,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. r N. 733V CIVIL TERM
AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
1. I am the Plaintiff in the above matter and because of my financial condition am unable to
pay the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the
costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is
true and correct.
(a) Name: Karen K. Webb
Address: 307 North Market Street
Mechanicsbure. PA 17055
Social Security Number: 177-50-7783
(b) If you are presently employed, state
Employer: None- Social Security Disability Since 19961
Address:
Salary or wages per month: $638.00 Disability Payment
(c)
Other:
(d)
Type of work: Di 5 A g k o
If you are presently unemployed, state
Date of last employment: N rdo-A'Yt ", Iq C1 C--
Salary or wages per month: M .L?i
Type of work:
Other income within the past twelve months
Business or profession: N rpyiz
Other self-employment: It tiM Q
Interest: UV r o_
Dividends:_ /V rVxj
Pension and annuities: IV^ A/h,L
Social Secmity Benefits: L? i 5 A A, ?; ?d ? d?. oo m+N
Support payments: N cnrnL
Disability payments: (.'4 r Ct.?j nt,J
Unemployment compensation and supplemental benefits: Ar'IvV%-L
Workman's compensation:
Public Assistance:
Other contributions to household support
Husband Name: ualff4-l &" l / f u,
If your husband is employed, state v'ytkt* ?
Employer:
Salary or wages per
Type of work:-
Contributions from
(e) Property owned
Cash:_N(y - a
Checking Account: P) E I Co - R Ana . ?? 3 d 0 °S=
Savings Account: ?, (I K 6
Certificates
Real Estate
Motor vehicle: Make To YnTA ca at e / Year I q S
Cost .? 60o Amount Owed Z± uL G
Stocks; bonds: 181 r - a
Other: N t ?> 3
(0 Debts and obligations
Mortgage: 111 ,,r
Rent: 5?-:-7 do m n v cn?l'?i
Loans: Q d ma ¢
Monthly Expenses: Mother Pa9s'-/ xenc
($50.00); Daughter Pays: Gas ($25.00); Electric ($20.00);
Phone ($20.00); Cable ($60.00); Water ($20.00)
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(g) Persons dependent upon you for support J41
Husband Name: N a
Children, if any:
Name: ) CAV Age:
4. I understand that I have a continuing obligation to inform the court of improvement in
my financial circumstances which would permit me to pay the costs incurred herein.
5. 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 unswom
falsification to authorities.
Date: II??9
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KAREN K. WEBB,
Plaintiff
VS.
HORACE D. WEBB,
Defendant
I.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
NO. 99-7334 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE.
Original service of the Complaint in Divorce, tiled December 7, 1999, was made upon
Defendant on December 13, 1999 by First Class Certified Mail, Restricted Delivery, United
States Postal Service.
Coyne & Coyne, rc.
Dated: bo-8-
Henry F. Coyne, squire
3901 Market Stre t
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. Supreme Ct. No. 06250
Attorney for Plaints
SENDER -. • 2 ' ' :'f
•; :Complete Items t and/or '2 additional services 'I,'ele i wla
iptato Items 3 and 4s d b.
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following set
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• Pyour nemeand address on the reverse of this lone so t we con fel
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raw ide card to you A
dof permit
.write:'Return Receipt Requested" on the mellplece below the article number
•;. The Return Receipt will show to whom the article was delivered and the date Consult e6[I
'delivered
3. Article Addre sad to: , ; '. 4e Article Number-<--
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7. Date of Delivery. .
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KAREN K. WEBB, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
Vs. : NO. 99-7334 CIVIL TERM
HORACE D. WEBB,
Defendant : IN DIVORCE
WAIVER OF NOTICE OF COUNSELING
I, KAREN K. WEBB, Plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I may
request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I participate
in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. No.
4904 relating to unsworn falsification to authorities.
Dated: A. ?4) ", w,
s?1 K. WEBB, Pla'ntiff
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KAREN K. WEBB,
Plaintiff
VS.
HORACE D. WEBB,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7334 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on
December 7, 1999.
2. The marriage of 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 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. Section 4904 relating to unswom
falsification to authorities..
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Dated: i!/I ICf /r n? / a?C50 a-N K. WEBB, laintiff
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KAREN K. WEBB, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 99-7334 CIVIL TERM
HORACE D. WEBB,
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
I . 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. 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. Section 4904 relating to unswom
falsification to authorities.
Date: y( , A00 0
EN K. WEBB, Plaintiff
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KAREN K. WEBB, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO.99-7334 CIVIL TERM
VS.
HORACE D. WEBB, ;
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on
December 7, 1999.
2. The marriage of 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 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. Section 4904 relating to unswom
falsification to authorities.
Dated: X004=
HORACE D. WEBB, Defendant
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KAREN K. WEBB,
Plaintiff
VS.
HORACE D. WEBB,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7334 CIVIL TERM
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 3301fcl
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 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. 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. Section 4904 relating to unswom
falsification to authorities.
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Date: ?i' ? / 4Lf A006) I'0 O'/,. /n y OAS"0-
HORACE D. WEBB, Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Ka?Pn Kulehb
Plaintiff 733tt
File No. 7 79
VS. IN DIVORCE
?-braae- D. c)e-bb
Defendant
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
o23Y=Q day of h '? /eMh , Odmo , hereby elects to resume the
/- - Lu ther and gives
prior surname of k117rifA
this written notice pursuant to the provisions of 541 P.S. S 704.
DATE: g/k ?/0o Q / 'Y
Si nature
nature Ana being resumed
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
On the o? day of Ad2 L , &901?, 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.
In Witness Whereof, I have hereunto set my hand and official
seal. ??////11'
Notary Public
140 ARIA1. SEAL
PAT; ;C;A A SKJ-10, Ni[trry Public
Gs1471e 90ro. 4,11M,*Iand County
My f.?micl:r,r, %! liras Da,smber 17, 2001