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Home My WebLink About07-2387 Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. Q7-d387 CIVIL 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. Since the ground for the divorce is irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the: Office of Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE 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 (717) 249-3166 Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. CIVIL IN DIVORCE NOTICE REGARDING THE AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint 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 being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, 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 borne 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 you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prepared by: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 737-4433 DAN_REGAN@C OMCA ST .NET Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Mary K. Haley, who has been residing at 324 Third Street, Enola, Cumberland County, Pennsylvania, since April 2006. 2. Defendant is Darrin Haley, who has been residing at 1637 Jefferson Circle, Webb City, Missouri, since August 2006. Defendant's mailing address is 1637 Jefferson Circle, Webb City, MO 64870. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 1, 1998, in Mount Joy, Pennsylvania. 5. There have been no prior actions of divorce or annulment between Plaintiff and Defendant. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Alfies. 7. The man-iage between Plaintiff and Defendant 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 Plaintiff and Defendant to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to 25 Pa.C.S. § 3301(c). Respectfully submitted, eJ DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Counsel for Mary K. Haley, Plaintiff Dated: April 23, 2007 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Mary K. Hale laintiff Dated: April 23, 2007 "~ ~ N ~ d ~ ~ ~ ~ ~ f i ~~ ~ ~ '^a ~y _ ~' ~ ~ p~ - ~ T a v> -c Prepared by: DAN BEGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 737-4433 DAN_REGAN@C OMCAST.NET Mary K. Haley, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Darrin Haley, Defendant CIVIL ACTION -LAW No. 07-2387 CIVIL IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the "Complaint Under Section 3301(c) of the Divorce Code" in the above captioned matter. ~~ ~~~ Darrin Haley, Defenda 1637 Jefferson Circle Webb City, MO 64870 Dated ~~ ~`~ ~ ~.... -r, ,, ~~ ~~ ,,,.,. ~~ j 1 ~ -~. '- ; ^ { ~ ' 3 ---4 r ( - «, ... ;~ ~. a ¢~~G, ~ r~ 9- Prepared by: DAN REGAN ATTORNEY AT LAW 1300 MARKET` ST., St7ITE 1 LEMOYNE, PA 17043 (717) 737-44:33 D AN_REGAN@C OM CA ST .NET Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07-2387 CIVIL 1N DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 25, 2007, and an Acceptance of Service was signed by Defendant on May 11, 2007 and filed July 19, 2007. 2. The marriage of Mary K. Haley, Plaintiff, and Darrin Haley, Defendant is irretrievably broken. Ninety days have elapsed since the date of 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 of Consent are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Dated: g/ "/Z~''7 Mary K. Haley ' laintiff r.~v~ .:. .....,~..~ .'..f ~t1 [d3~ S ` ~ i 1 ~ _ ~~ ,~,~.--, ~l /• ...... • 4 _: 7 ~ ~4 3 _ 4 . ~_ Prepared by: DAN BEGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LF,MOYNE, YA 17043 (717) 737-4433 DAN_REGAN@COMCAST.NET Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW No. 07-2387 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 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 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 notice of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver of Notice are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. ~ ~~ z ~u Mary K. Haley, intiff Dated: 7 ~ rv x: ' ~~, ~:_ ~": _ ~ -n _ __; ;^kL d(( --55 i4/ l ~'.. ~~_~ •a ~Y ~1 .~~ - ~ ti„~ ~~ 4~4 ~ X14... Prepared by: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SL3ITE 1 LEMOYNE, PA 17043 (717) 737-4433 DAN_I~EGAN@COMCAST.NET Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA CIVIL ACTION -- LAW No. 07-23$7 CIVIL 1N DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 25, 2007, and an Acceptance of Service was signed by Defendant on May. 11, 2007 and filed July 19, 2007. 2. The marriage of Mary K. Haley, Plaintiff, and Damn Haley, Defendant is irretrievably broken. Ninety days have elapsed since the date of service of the Complaint. 3. i consent to the entry of a Tina{ decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit of Consent are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. r Darrin Haley, Defendant Dated: ~~ ~~ ~ "I'"6 _,_ -~... C~, -_ - is c~". a,~~:_. C„~'"! .-,.w _ .. ~3 ~~ OrLtG r~JA-~ Prepared by: DAN RF.GAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNI+:, PA 17043 (717) 737-44` ` DAN_REGAN@COMCAST.NET Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBEF2LAND COUNTY, ) PENNSYLVANIA CIVIL ACTION -LAW No. 07-2387 CIVIL } IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may Pose 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 notice of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver of Notice are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Darrin Haley, efendan dated: 1~ ~ .~. _ ~~ ``E-i _ .4~ V ~-.-- ~il:_ n~1 .. ~~ ..-....~ e^~+ -^r„ ` s t cy2.~.e, .,set.. Prepared by: DAN REGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 737-4433 DAN_REGAN@C OMCA ST .NET Mary K. Haley, Plaintiff v. Darrin Haley, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07-2387 CIVIL IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Certified mail sent by Dan Regan, Esq. of Lemoyne, Pennsylvania, on May 2, 2007, per Acceptance of Service filed July 19, 2007. 3. Date of execution of Affidavit of Consent required by § 3301(c) of the Divorce Code: By Plaintiff: August 11, 2007. By Defendant: August 11, 2007. ti 4. Related claims pending: NONE. 5. Date Plaintiff's Waiver of Notice under § 3301(c) of the Divorce Code was filed with the Prothonotary: August 21, 2007 (mailing date). Date Defendant's Waiver of Notice under § 3301(c) of the Divorce Code was filed with the Prothonotary: August 21, 2007 (mailing date). Respectfully submitted, Dan Regan, sq. Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Dated: August 21, 2007 ~...._~ i;~% s ~^ ;'~ f:::. ~.. ~.a~ ~~ S .-~~ r~' _ > ' '' 1J ~,." I N THE COURT OF COM 1VION PLEAS M~1 f~ Y K . 1-t ~ L Eye PL ~4 r ~l'T t IF F VERSUS ~~R.R~~1 H~LEy, !> E F E~J 1~A-~1 ~ No. 07- 2387 ~t~~~.- DECREE IN DIVORCE AND NOW, s,~~~'t~.v c~~, Zoo IT IS ORDERED AND DECREED THAT - M~~,( K - ~~L'Ey PLAINTIFF, AND D~~Q t~ ~'1'~4'~-E~ 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; r~jo~F, PROTHONOTARY OF CUMBERLAND COUNTY STATE OF ~ PENNA. _~ ~~ ~ ~- .~~ ~o L ~ - ~ ~o~~>-~ ;_