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Home My WebLink About07-2538.. Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 Fax: 717-975-0697 Email: dianeradcliff C~comcast.net Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, ; Plaintiff N0.0^I ~ o2.s'3d~ CIVIL TERM v. CIVIL ACTION -LAW. CYNTHIA P. WARD, DIVORCE Defendant 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 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDER YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-31 b6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. O'1'- a 33 8' CIVIL TERM V. CYNTHIA P. WARD, Defendant CIVIL ACTION- LAW DIVORCE COMPLAINT Plaintiff, Scott M. Ward by his attorney, Diane G. Radcliff, Esquire, and files this Complaint in Divorce of which the following is a statement: 1. The Plaintiff is Scott M. Ward, an adult individual who currently resides 725 S. Main Street, Marysville, PA 17053. 2. The Defendant is Cynthia P. Ward, an adult individual residing at 107 Salt Road, Enola, PA 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 29, 1992 at Jeffersonville, NY. 5. Plaintiff avers that there is one(1) child under the age of eighteen (18) born of the marriage, namely, to wit: Brett Ward, born October 12, 1994. 6. There have been no prior actions of divorce or annulment between the parties. 7. 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. 8. Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. Plaintiff avers that the grounds on which the action is based are: 2 A. Section 3301(c) Mutual Consent No-Fault: The marriage is irretrievably broken; B. Section 3301 (d) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart. Once the parties have lived separate and apart for a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, IANE G. RADCLIFF, ESQUIR ndle Road Camp Hill, PA 1701 1 Phone: (717) 737-0100 Supreme Court ID # 32112 Attorney for Plaintiff 3 VERIFICATION SCOTT M. WARD verifies that the statements made in this Complaint are true and correct. SCOTT M. WARD understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~~~ SCOTT M. WARD Date: y' ~ 7 - ~~ -3- ~ ~ W ~ ~ ~ ~ t? c - `O ~ W 6~ 1i l! ~t .~, ,~` (- ~ ~ ~ _:~ C~ ^:f, ~ 0 .. i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. 07-2538 CIVIL TERM v. CIVIL ACTION -LAW CYNTHIA P. WARD, DIVORCE Defendant AFFIDAVIT OF SERVICE I, Diane G. Radcliff, Esquire, being duly sworn according to law, depose and say that on May 7, 2007, I served a true and correct copy of the Complaint in Divorce upon Cynthia P. Ward, the Defendant, by Certified Mail, Restricted Delivery, addressed as follows: Cynthia P. Ward 107 Salt Road Enola, PA 17025 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. DIANE G. CLIFF, ESQUIRE 3 e Road Camp Hill, PA 17011 Supreme Court ID # 32112 Attorney for Plaintiff Sworn to and subscribed before me a Notary Public in and for Cumberland County, Pennsylvania this /b~ day of , 2067. NOTARY PUBLIC COMMONWEi'~LTH OF PENNSYLVANIA Notarial Sea! Deborah L, Donley, Notary Public Camp Hill Boro, Cumberland County ~'!~' Canmission Expires Sept 23, 2007 Member, Pennsylvania Association Of Notaries My commission expires: ,. ~' CompieRe items 1, 2, and 3. Also complete ib~m 4 if Restricted Delivery is desired. ^ Prktt your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, a on the front ff space permits. 1. Reticle Addressed to: ~s fJ27.~1t~ ~ lcJ,cr~.~. /o7,~,ct ,~-u~- ~a, ~~-- Oyu a5 as re /~~~ / ,r ~ n, „ .~ ^ Agent B eceived by (Printed Name) C. Date of DeNwry ~~~~ d; Lucx-~c~ D: Is delivery address tlifierent iron hem 1? ^ Yes tF YES, enter deNvery address below: ^ No 3. ~rl.tar?1{ f~~+$Express Mail ~ Repi i Q.~Setum Receipt for Merchandtee ^ Insured Mal(~~-~ ~ C.O.D. 2. ARblb.NumAer ?005 311 3304 2994 4184 (n.rMrer nom service PS Fomt 3811, February 2004 Domestic Return Receipt 102595-02-nr-1510 EXHIBIT "A" CERTIFIED MAIL RETURN RECEIPT CARD C"} ~ <,~7 ''~" ,+.y 4 _.,] t Tt iT' ~ : 1 _~ _.i - _ y ~ :"; Y - Jr) _ - _ rte 4, _ __ ` ~~~ ~, ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. 07-2538 CIVIL TERM V. CIVIL ACTION- LAW CYNTHIA P. WARD, DIVORCE Defendant IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE ACOUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 1, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 unsworn falsifications to authorities. Date: June 4, 2007 SCOTT M. WARD, Plaintiff ~ ~ C. _ ~' -~ rr; 3 `j ..-t, ~TJ r->- ~, ^ +.: ~ --~ C ? r' t_.r ~- G.J t~ ':.~ ~ w > ~-,. ~ -C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. 07-2538 CIVIL TERM V. CYNTHIA P. WARD, Defendant CIVIL ACTION- LAW DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 2, 2007, and served upon the Defendant by Certified Mail Restricted Delivery on May 7, 2007 as more fully appears in the Affidavit of Service filed of record in this case. 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 in 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 i8 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: O 'O~~ ~ Q ~ 9~I SCOTT M. WARD C~ `~~' ~ G ^~ _° x- ~.r ~ .xw. ~ -`-~ - tj:r ~ -v ~~ . ~. ~; cx~ r-r~ . xa -r -r ~ ~ ~~ --r tit ~ rn i r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. 07-2538 CIVIL TERM V. CIVIL ACTION- LAW CYNTHIA P. WARD, DIVORCE Defendant 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 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. Dated: ~-ay-G1 SCOTT M. WARD C`? ~ Q :~ ~ -:y '~ {.... ~. ~;~ fir; ~3 ~C ' . ~~~ ,~, ~ ~ era ~ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. 07-2538 CIVIL TERM V. CYNTHIA P. WARD, Defendant CIVIL ACTION- LAW DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on May 2, 2007, and served upon the Defendant by Certified Mail Restricted Delivery on May 7, 2007 as more fully appears in the Affidavit of Service filed of record in this case. 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 in 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 unsworn falsification to authorities. Dated: ~~P + 3 , a00~ CYNTHIA P. WARD ° . .+ ~ ~ , ' CC +~;~ --~ 5 d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. 07-2538 CIVIL TERM V. CIVIL ACTION- LAW CYNTHIA P. WARD, DIVORCE Defendant 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 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4404 relating to unsworn falsification to authorities. Dated: ~~Pf '> °'t-dd~ ~-~ ~`'".'`~ CYNTHIA P. WARD ..f_~ ~} ~ ..., '~; ~~ .,U ~„~ ~ p~' W.~i ~ *~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT M. WARD, Plaintiff N0. 07-2538 CIVIL TERM V, CIVIL ACTION- LAW CYNTHIA P, WARD, DIVORCE Defendant PRAECIPE OF 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 OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: May 2, 2007 b. Manner of Service of Complaint: Certified Mail/Restricted Delivery c. Date of Service of Complaint: May 7, 2007 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: August 24, 2007 b. Defendant: September 3, 2007 OR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301(D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: a. Date of Execution: N/A b. Date of Filing: NIA c. Date of Service: N/A 4. RELATED CLAIMS PENDING: No issues are pending. No issues have been raised in this case, and there are no issues outstanding. 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(D)(1)(1) OF THE DIVORCE CODE: a. Date of Service: N/A b. Manner of Service: N/A OR DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: August 28, 2007 b. Defendant's Waiver: September 12, 2 D LIFF, ESQUIRE oad Camp Hitl, PA 17011 Supreme Court ID # 32112 Rhone: (717) 737-0100 ' ? C k ~ ~ ~ ~ ~'UU ', ~ ~ LF s~ ,; ~" '~ ~ ~"; .~ ~..--~. j 1•+ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. _~ ~~ N~• t77-2538 C'TVT7, TERM VERSUS CYNTHIA P. WARD, Defendant DECREE IN DIVORCE AND NOW, ,2~_, IT IS ORDERED AND DECREED THAT ~~,~+~+ ~~~ y,~Dn ,PLAINTIFF, AND CY]~T~jTA P_ WARD ,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; ~ ~~~n ~Q. ~~ .b ~ ,~- . _~, . 4 +. 3 ~ -~