HomeMy WebLinkAbout99-07512
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IN THE COURT OF COMMON FLEAS
s OF CUMBERLAND COUNTY
-?,n; •? PENNA.
STATE OF 7ek?- f,
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AMY...FURLOUGH.• .................... ................... i
u .............. 9.-7,512.............
........._.
Plaintiff.. ...._........ ........
....._......... Versus
.; JASON FURLOUGN,_ ,.
Defendant_
i
DECREE IIV
DI WORCE
ryjz,?: j? -2;408 it is ordered and
AND NOW, ...
t
plaintiff,
AMY FURLOUGH
? decreed that ...............................................
JASON FURLOUGH defendant,
and
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 S
been entered;
......................................................................... q
1 ;101 .................. ........................................................
?i By T c c rrt
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Attes
d Prothonotary
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AMY FURLOUGH,
Plaintiff
VS.
JASON FURLOUGH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 7512 CIVIL TERM
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:
1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and manner of service of the complaint: Certified Mail, Restricted Delivery, on
12/31/99.
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 the Plaintiff 4/5/00; By the Defendant 5/6/00.
B. (1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the
Divorce Code:
(2) Date of service of the Plaintiffs affidavit upon the Defendant:
4. Related claims pending: NONE
5. Complete either (a) or (b).
A. Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached:
B. Date Plaintiff Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary:
5/6/00; Date Defendant's Waiver of Notice in 3301(c) Divorce was filed ?ith the Prothonotary 5/12/00.
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AMY FURLOUGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY. PENNSYLVANIA
VS. : CIVIL ACTION - LAW
: NO.99 -7,% CIVIL TERM
JASON FURLOUGH,
Defendant : 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 maybe 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request
marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County
Courthouse, 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, please contact our office. All arrangements must be made at least
72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing.
James J. Kayer, Esquire
Attorney for Plaintiff
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-7922
I,)
AMY FURLOUGH,
Plaintiff
VS.
JASON FURLOUGH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 -P./z CIVIL TERM
: IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 310I Lc OF THE DIVORCE CODE
COMES NOW, Plaintiff Amy Furlough, through her attorney, James J. Kayer, Esquire and avers as
follows:
COUNT I - DIVORCE
1. Plaintiff is Amy Furlough, an adult individual, whose current address is 560 South Hanover
Street, Carlisle, Cumberland County, Pennsylvania, 17013
2. Defendant is Jason Furlough, an adult individual, whose current address is 905
CentervilleTumpike, Chesapeake, Virginia.
3. Plaintiff has been bona fide residents of the Commonwealth for at least six
months immediately previous to the filing of this Complaint
4. The Plaintiff and Defendant were married on April 4, 1998, Chesapeake, Virginia
5. There have been no prior actions of divorce filed in his matter.
6. Plaintiff and Defendant are not members of the United States Armed Forces.
7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c).
8. 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.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
Date: December 15, 1999
(717) 243-7922
VERIFICATION OF PLEADINGS
The foregoing document is based upon information which has been gathered by my counsel
and myself in the preparation of this action. The language of the document may, in part, be the
language of my counsel and not my own. I have read the statements made in this document and to
the extent that it is based upon information which I have given to my counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the contents of the
statements are that of counsel, I have relied upon counsel in making this Verification. I understand
that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904, relating to
unsworn falsification to authorities.
`J
Date: 5 '1999
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A Professional Corporatlo
Liberty Loft • 4 E Liberty. .Avenue • 'Ca
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rlisle PA %17013 „
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AMY FURLOUGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 99 - 7512 CIVIL TERM
JASON FURLOUGH,
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
: SS.
I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is
the attorney for Plaintiff, AMY C. FURLOUGH, and that he did serve a true and correct copy of
the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S.
Mail, postage prepaid, certified, return receipt requested, unto the Defendant, JASON W.
FURLOUGH, on December 31, 1999. The return receipt is attached hereto.
Sworn to mid subscribed before me
2800.
this-4th ay of January
o P c
Ia Complete Items 1, 2, and 3. Also complete d Received by (Please Print Gee y) 91. Dale of Delivery
Item 4 if Restricted Delivery Is desired.
¦ Print your name and address on the reverse
so that we can return the card to you. nature
¦ Attach this card to the back of the mailpiece, ? Addressee '
or on the front if space permits.
1. Article Addressed to:
asp uO. Rucl axe h
c a" )Qo( s
delivery address differenTfrom hem 17 ? Yes '
If YES, enter delivery address belw.. ? No
3. Servlcelype
?9'Cedined Mail E3 Express Mail
RRegistered ? Return Receipt for Merchandise
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Enos Fee) ? Yes ,
2. Article Number (Copy from service lebep •--, ??
PS Form 3811, July 1999 Domestic Return Receipt
102595-99-M-0709
THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
:NO.99- 7512 CIVIL TERM
JASON FURLOUGH,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER 4 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 understand that 1 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.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 15, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the
date of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry
of the decree.
4. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses
if I do not claim them before a divorce is granted.
I verify that the statements made in this Waiver and Affidavit are true and correct. 1 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. r U? .2000 1?L \ i
AMY FURL UGII
AMY FURLOUGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS. :NO-99. 7512 CIVIL TERM
JASON FURLOUGH,
Defendant IN DIVORCE
TINDER & 3301fc) OF THE DIVORCE CODE
consent to the entry of a final decree of divorce without notice.
2. 1 understand that 1 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. 1 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.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 15, 1999.
. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the
date of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry
of the decree.
4. 1 understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses
if I do not claim them before a divorce is granted.
1 verify that the statements made in this Waiver and Affidavit are true and correct. 1 understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unswom falsification
to authorities. / rn ,r?
DATE: ! "' IQ2000