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HomeMy WebLinkAbout99-07376A O? ,_ t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. N t t 99-7376 CIVIL 1999 DECREE IN DIVORCE urt_:/ By Th Co ...'..?....._.._.. Attest: ....................... Prothonotary !1 •.YJi. /?...,?,,. .A. .A. ;ehl •. te; <! • W.+ LY• {1 • :ei ie; te:• •:?:• ;?:• eel <4r, ;Cr - ;o:•' i;0; {O • ?:0:• a?>. te:• e0 <?:. ?w AND NOW, ...........!g44V" v ... y ?. , 1.9.. • • • • . it is ordered and decreed that ......... T.? ?:•. PP:zT• • • • • • . I .... • • • • • " ...... • • • . plaintiff, and • • • • • • • • • • • • ........ • .. , CHRISTOPHER J. PRATT 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; ........................ NvN ............................................ i i O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT Plaintiff VS. CHRISTOPHER J. PRATT Defendant CIVIL ACTION - LAW CASE NO. 99- IN DIVORCE To the Prothonotary: Please 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 201(c)/3301(c) of the Divorce Code. 2. Complaint served on Defendant via First Class U.S. Mail Certified Return Receipt on December 14, 1999 (see attached Verification of Service). 3. Date of Defendant's execution of Affidavit of Consent: July 5, 2000. 4. Date of Plaintiffs execution of Affidavit of Consent: August 4, 2000. 5. Related claims pending: None. Thank you. Date: 4 ? Esquire 4AAttomey . ckle f for the aintiff Supreme Court ID # 38444 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 r C' ?s am co 27 G J ]CL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT CIVIL ACTION - LAW Plaintiff / VS. CASE NO. 99- 73 7& ?ee'L CHRISTOPHER J. PRATT Defendant : IN DIVORCE 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 Court Administrator at the Cumberland County Courthouse, Hanover and High Streets, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT, : CIVIL ACTION - LAW Plaintiff VS. : CASE NO. 99- 737E Ccv?PT?'r` CHRISTOPHER J. PRATT Defendant : IN DIVORCE AND NOW this L _ day of December, 1999 comes Plaintiff by and through her attorney, Joseph D. Buckley, Esquire and requests a divorce from Defendant as follows: 1. Plaintiff is Tina L. Pratt, who currently resides at 607A Geneva Drive, Apartment 31, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Christopher J. Pratt, who had resided at 607A Geneva Drive, Apartment 31, Mechanicsburg, PA 17055 from January 1999 until November 19,1999, but has since moved to 211 East Ray Street, Highpoint, NC 27260. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 9, 1995 in High Point, Gilford County, North Carolina. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken due to irreconcilable differences. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the Court require the parties to participate in marriage counseling. 8. Venue is proper in this Court pursuant to Rule 1920.2(a)(2). 9. Neither Plaintiff or Defendant are members of the armed forces of the United States. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. ? ' a I , ey, Esquire Attorney for the Plaintiff Supreme Court ID # 38444 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 J , I, Tina L. Pratt, 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 unsworn falsification to authorities. Date: December 1999 ' CL Tin L. Pratt, Plaintiff ?t I? I hereby certify that a true and correct copy of the foregoing Complaint Under Section 3301(c) of the Divorce Code was duly served via United States First Class Certified Mail, Return Receipt Requested, Restricted Delivery, postage prepaid upon the following person: Christopher J. Pratt 211 East Ray Street High Point, NC 27260 Date: t act, E? y? i9<.? L? 4? Z/ Joseph D. Buckley, squire Attorney for the Plaintiff r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT : CIVIL ACTION - LAW Plaintiff VS. : CASE NO. 99-7376 CIVIL CHRISTOPHER J. PRATT Defendant IN DIVORCE P INTIEF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 8, 1999, in the above-captioned action. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and at least ninety 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 by the Court of Common Pleas of Cumberland County, Pennsylvania. 4. I understand that I may lose our rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counseling and understand that I may request that the Court require us to participate in counseling. 6. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, which list is available to me upon request. 7. Being so advised, I do not request that we participate in counseling prior to a divorce decree being handed down by the Court. 8. I am not a member of the armed services of the United States and I was not a member during any time relevant to this action. I hereby 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, which provides that if I knowingly make false statements, I may be subject to criminal penalties. Date: ie/'o, L AX& CTi1na L. Pratt COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss Before me, the undersigned officer, this 71 day of g? 000, personally appeared Tina L. Pratt, known to me (or satisfactorily pro- to be the person whose name is subscribed to the within Plaintiff's Affidavit of Consent and Acknowledgement of Service and acknowledged that she signed the same for the purposes therein stated. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. J liC' ccL N ary / Notarial Seat LKaren Key Buckley. Notary Public th Middleton Twp., Cumbedand County commission Expires June 23, 2001 N i- Ll _ j a. j t=' ;. c i u _ :I) C' o U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT VS. CHRISTOPHER J. PRATT CIVIL ACTION - LAW Plaintiff CASE NO. 99-7376 CIVIL Defendant IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE BEING FILED 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 8, 1999, in the above-captioned action. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and at least ninety 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 by the Court of Common Pleas of Cumberland County, Pennsylvania. 4. 1 understand that I may lose our rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I waive the requirement that a Notice of Intention to Request Entry of Divorce Decree be filed in this matter and pray the Court enter a decree divorcing Plaintiff from Defendant. I, Tina L. Pratt, verify that the statements made in this Plaintiffs Waiver of Notice of Intention to Request Entry of Divorce Decree Being Filed 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. r ????r??' q - ? ADD Date: 1 (Tina L. Pratt, Defendant COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND da of ?, 1000, personally Before me, the undersigned officer, this Y appeared Tina L. Pratt, known to me (or satisfactorily proven to be the person whose name is subscribed to the within Plaintiffs Waiver of Notice of Intention to Request Entry of Divorce Decree Being Filed and acknowledged that she signed the same for the purposes therein stated. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. No Notarial Seal Karen Kay Buckley, Notary Public My Comldmission EPpCes June 23200, L1! ? •• - -? u;: 1•':? -? G.. ??? rJJ . ` it ?" - r, `1W ?' iil(L ?- c t:J C V ?. t . _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT : CIVIL ACTION - LAW Plaintiff : CASE NO. 99-7376 CIVIL VS. CHRISTOPHER J. PRATT Defendant IN DIVORCE ,SERVICE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 8, 1999, in the above-captioned action. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and at least ninety 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 by the Court of Common Pleas of Cumberland County, Pennsylvania. 4. I understand that I may lose our rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counseling and understand that I may request that the Court require us to participate in counseling. 6. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, which list is available to me upon request. 7. Being so advised, I do not request that we participate in counseling prior to a divorce decree being handed down by the Court. 8. I hereby acknowledges that he was serviced with true and correct copies of the Complaint, Notice to Defend and Claim Rights and Notice of Availability of Counseling on December 14, 1999 by means of U. S. First Class Mail, Certified/Return Receipt No. Z 013 277 092. 9. I am not a member of the armed services of the United States and I was not a member during any time relevant to this action. I hereby 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 Is Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I knowingly make false statements, I may be subject to criminal penalties. Date: r/ - S- v p a4/A UiA Christopher J. Pratt STATE OF NORTH CAROLINA COUNTY OF G(1- LF•0a.D : ss Before me, the undersigned officer, this ? day of 3t,\.t,y 2000, personally appeared Christopher J. Pratt, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Defendant's Affidavit of Consent and Acknowledgement of Service and acknowledged that he signed the same for the purposes therein stated. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. \\AU1\11111111 II IIIIIIryH pJA `?VsobQ,V .. AUST?N.,,y Notary ?o: fj?p /o/yy/auuy :NDIARY PUB0t -* , h 5- S c ' i? y LIL. J ..: L 'YIl1 O O U r R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT : CIVIL ACTION - LAW Plaintiff Vs. : CASE NO. 99-7376 CIVIL CHRISTOPHER J. PRATT Defendant : IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION Tn REQUEST ENTRY OF DIVORCE DECREE RFING FIT ED 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 8, 1999, in the above-captioned action. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and at least ninety 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 by the Court of Common Pleas of Cumberland County, Pennsylvania. 4. I understand that I may lose our rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I waive the requirement that a Notice of Intention to Request Entry of Divorce Decree be filed in this matter and pray the Court enter a decree divorcing Plaintiff from Defendant. I, Christopher J. Pratt, verify that the statements made in this Defendant's Waiver of Notice of Intention to Request Entry of Divorce Decree Being Filed 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 unsworn falsification to authorities. Date: 7- s c-?z) ChnstPrat' t fendant STATE OF NORTH CAROLINA COUNTY OF ss Before me, the undersigned officer, this -5P4 day of 3u ?y , 2000, personally appeared Christopher J. Pratt, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Defendant's Waiver of Notice of Intention to Request Entry of Divorce Decree Being Filed and acknowledged that he signed the same for the purposes therein stated. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary(a IC)hLI hoU4 Ov ; r NpTAF3Y PUBI-t ii: ... • ey? Ilm 1•- P_ -?.,, ELI (l O ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TINA L. PRATT VS. CHRISTOPHER J. PRATT Plaintiff CIVIL ACTION - LAW CASE NO. 99-7376 CIVIL Defendant : IN DIVORCE I, Joseph D. Buckley, hereby verify that a true and correct copy of the Complaint in this matter together with a Notice to Plead was duly served via First Class U.S. Mail, Certified Return Receipt No. Z 321 756 146 (Restricted Delivery) on December 9, 1999 as evidenced by the attached Receipt for Certified Mailing and received by Defendant on December 14, 1999, as evidenced by the attached Return P.S. Form 3811 executed by Defendant. I hereby certify that the statements made herein are true and correct to the best of my knowledge, information and belief. I understand that statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: ? - ey' Oa Attdmey fort c Plaintiff Supreme Cou ID # 38444 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 I Z 013 277 092 N kn m &MV to G 0 0 L _ -a t O h $ ' Ne hems t actor 2 for additional UrAW S. COm I also wish to receive the l n : Complateharns3,40.ardab. following services (for an ! g •Pdm your name and address an the reverse of this form so that we ken return this extra fee): ' l C l cedto you. sAttach Ws loan to the from of the malldece, or on the beck If space does not 1, O Addressee's Address 8 t to pemut. naMec fum Requested' • 2. Reslrtcted Delivery p (n; I eceipt The Rol •The Return Receipt will show to o whom rito e arti snide was delivered end the date whom the delivered. Consult postmaster for lee. 0 3. Article Addressed to: 4a. Article Number CHRISTOPHER. J. PRATT 7. 013 277 092 E i E 211 EAST RAY STREET 4b. Service Type m j $ HIGHPOIIIT NC 27260;??01/fp\ -"?• O Registered ® Certified cc t ` ? Express Mail O Insured E , ? ® Return Receipt for Meronandise O COD I a C 1 c ? 7. Dale of Delivery i . \? /O TI + S. Received By: (Print Name) 8. Addressee's Address (Only if requested d f I id an ee s pa ) 6. Sign . (.j0 ressee rAge r) T V / r( i e mbar 1994 Pratt v. Pratt Domestic Return Receipt PS Form 3811, D US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. nn nM ,.?. L., Inleme6nnnl u.n c-- 'MI to CHRISTOPHER J. PRATT suoeld oer r 21 f EAST RAY STREET Post ZIP Code NC 27260 Postage $ Cadirod Fee 1H O F-71-dal Delivery Fee Restricted Delivery Fee Rehm Receipt Stuawing to -t 6f77aWDeriwred ? [. alb sessee e J4 fALPosla e d Feas J P arK er Dab \ f`- 4? li I i f r jp ?\ u co -L ? fl[1 i G CD U l c:v ?