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Home My WebLink About99-07514 e' r15" 1 ;g y. :K .ti y iY F' S 3j_1?{y?t?1? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF _ PENNA. KIMBERLY B. CUNNINGHAM Plaintiff N O. 99 - 7514 VERSUS ROBERT J. MOSS Defendant DECREE IN DIVORCE AND NOW, ?wG, ' I , Z000 , IT IS ORDERED AND DECREED THAT KIMBERLY B. CUNNINGHAM , PLAINTIFF, AND ROBERT J. MOSS 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; AL BY THE COURT: ATTE J. PROTHONOTARY AY4 7 • /9 0D/lltu s?? r '? KIMBERLY B. CUNNINGHAM Plaintiff, v ROBERT J. MOSS Defendant, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 7514 CIVIL 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 (x)3301(c) ()3301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: December 30, 1999, First Class Certified Mail, Return Receipt Requested, Restricted Delivery. 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. April 16,2000; Defendant: April 23, 2000. (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:- c- I 4. Related claims pending: None.. 5. Complete either (a) (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 Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 24, 2000. (c) Date Defendant's Waiver of Notice in §3302(c) Divorce was filed with the Prothonotary: May 2, 2000. 1 Amt ` rt X. Gilroy, I Attorney for Plainytt Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-2434574 in , t `fn :J l:J : J I KIMBERLY B. CUNNINGHAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v :NO. 99-196VIL TERM ROBERT J. MOSS, 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 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 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, PA 17013 717-249-3166 KIMBERLY B. CUNNINGHAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 99-151 CIVIL TERM ROBERT]. MOSS, Defendant : IN DIVORCE COMPLAINT Plaintiff, Kimberly B. Cunningham, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: Plaintiff, Kimberly B. Cunningham, is an adult individual residing at 1713 Cedar Cliff Drive, Camp Hill, Cumberland County County, Pennsylvania. 2 Defendant, Robert I. Moss, is an adult individual residing at 238-11 Lucas Lane, Vorhees, New ]ersey 08043. 3 The parties were married on March 18, 1998, in Philadelphia, Pennsylvania. 4 Plaintiff has lived continuously in the Commonwealth of Pennsylvania and Cumberland County for at least six months immediately previous to the commencement of this action. 5 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 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, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. BROUJOS & GILROY, P.C. By a V - Hubert X. Gilroy, squire Attorney for PI ntiff 4 North Hanover Street Carlisle, PA 17013 717-243-4574 I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa-C.S. 4904 relating to unsworn falsification to authorities. t Gs'/?? K' rly D. y ingham ;' L' ;' Q rt ?,: ' ' ?.:? ?_;.: ?? u ^; ? (`` ? _r ,Q ? ? ? 0 ? ? '? _ ? ? ? ? ? .__ 1T ?., ,?, s ,cn ..,xcss 3301(c).not KIMBERLY B. CUNNINGHAM, Plaintiff M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-7514 CIVIL TERM ROBERT J. MOSS, Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I . A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on December 15,1999. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about December 30,1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: 61C 0 er1yA. M Plaintiff ?, - .. , _. - ?- , ?:. ,?. :i ?; 3301(c).not KIMBERLY B. CUNNINGHAM, Plaintiff V ROBERT J. MOSS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-7514 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I . A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on December 15,1999. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about December 30,1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: d WMoss.fee Rob j?.'- -, - -- ?;, =,`-:? '; ,_-? = , ., el 1 KIMBERLY B. CUNNINGHAM :IN THE COURT OF COMMON PLEAS OF Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 99- 7514 CIVIL ROBERT J. MOSS Defendant, : IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant, Robert J. Moss, by certified mail on December 30, 1999. A copy of the Certified Mail - Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. i /00 DATE Swom and subscribed before me this--- day of JJ 2000 ??M Hubert X. Gilroy squ Attorney for P Intiff Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Notary Publi =elAnn otarial Seal [8C,,Cd Corcoran, Notary Public o, Cumberland County ? r Expires June 10, 2002 - ??. _ J. ..- ". J '?J L1 ? V J m: D 1' m L o ENDER' I also wish to receive the ?Complole items t and/or 2 for xadNonal sarncos, following services (for an Complato items a. 4a, and 4b. Print your name and address on the reverse of INS term so that we can return this extra fee): u t card to you. I.? Addressee's Address i Aaach Iris loran to the front of the rnailpim. or on the luck it space does not pWerm.1 2.0 Restdcled Delivery - On the I i The Return ROCCnPI ' O Show to wrom the a,nda was dahvo od and the data Consult postmaster for fee. o. ' delivered. 3. Article Addressed to: 4a. Article Number Mr ri)b.4 S. Mess vSa y?9 139 ¢ 1 E II LvccS ?.ne. s °Uor h?esr NS, o?&/3 PS Form E ; 41b. Service Type a `: ? Registered l?Cerlitied ¢ , ? Express Mail ? Insureds v 9 Return Receipt for Merchandise ?COD ' 7. Date of Delivery /yam O ( v2 r ?t, '?,r 8. Addressee's Address (Only i requested m l! t(?I and lee is paid) L 102595.988.0229 Return EXHIBIT da Y J _ I D C y, ' _ L ? U ,l