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HomeMy WebLinkAbout03-3876IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH R. STEPHENS, ) Plaintiff ) ) v. ) ) ROBERT SCOTT STEPHENS, ) Defendant ) NO. 2003- ~ ~'7.(,o CIVIL TERM CIVIL ACTION - LAW IN DWORCE 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 maniage counselors is available in the Office of the 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 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 Telephone: (717) 240-6200 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 heating or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH R. STEPHENS, Plaintiff ROBERT SCOTT STEPHENS, Defendant NO. 2003- CIVIL TERM CIVIL ACTION - LAW 1N DIVORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Deborah R. Stephens, by and through her counsel, Howett, Kissinger & Conley, P.C., who states the following in support of the within Complaint: 1. Plaintiff is Deborah R. Stephens, an adult individual who currently resides at 877 Hawthorne Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Robert Scott Stephens, an adult individual who currently resides at 877 Hawthorne Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents in the Commonwealth of Pennsylvania for a period of at least six (6) months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on August 31, 1997 in Mechanicsburg, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States of its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions for divorce or annulment of the marriage instituted by either of the parties in this or any other jurisdiction. 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. The marriage of the parties is irretrievably broken. 9. Plaintiff requests the court to enter a decree of divorce. Date: Respectfully submitted, 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Deborah R. Stephens VERIFICATION I, Deborah R. Stephens, hereby swear and affirm that the facts contained in the foregoing Complaint in Divorce are tree and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ~'/~/&.~ DEBORAH R. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH R. STEPHENS, Plaintiff ROBERT SCOTT STEPHENS, Defendant ) ) ) ) ) ) ) NO. 2003--3876 CIVIL TERM CIVIL ACTION - LAW 1N DIVORCE ACCEPTANCE OF SERVICE I, Robert Scott Stephens, hereby accept service of the Complaint in Divorce filed with this Court on August 8, 2003. Date: Robert Scott Step'cbs, De'~dan-~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH R. STEPHENS, Plaintiff ROBERT SCOTT STEPHENS, Defendant NO. 2003-3876 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on August 8, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry ora final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divome 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 above 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: Robert Scott Stephens/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH R. STEPHENS, ) Plaintiff ) ) v. ) ) ROBERTSCOTTSTEPHENS, ) Defendant ) NO. 2003-3876 CiVIL TERM CiVIL ACTION - LAW IN DWORCE August 8, 2003. 2. PLAINTIFF'S AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on The marriage of Plaintiff and Defendant is irretrievably broken, and ninety 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. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce ~s 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 above 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. Date: /d~ens~,'p~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH R. STEPHENS, Plaintiff ROBERT SCOTT STEPHENS, Defendant ) ) ) ) ) ) ) NO. 2003-3876 CIVIL TERM CIVIL ACTION - LAW 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 §3301(c) of the Divome Code. Date and manner of service of the complaint: Service accepted by Defendant Robert Scott Stephens on August 14, 2003; Acceptance of Service filed on August 20, 2003. Date of execution of the affidavit of consent required by §3301(c) of the Divome Code: by plaintiff, June 25, 2004; by defendant, November 17, 2003. 4. Related claims pending: No related claims pending. Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: contemporaneously herewith; date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the prothonotary: December 9, 2003. Date: 130 Walnut Street, P. O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for PlaintiffDeborah R. Stephens 1N The COURT OF COMMON PLEAS DEBORAH R. STEPHENS, Plaintiff OFCUMBERLANDCOUNTY STATE'. OF PENNA. 2003-3876 CIVIL TERM NO. VERSUS ROBERTSCOTTSTEPHENS, De~ndant AND NOW, DECREED THAT AND DECREe IN DIVORCE DEBORAH R. STEPHENS 2004, It IS ORDERED AND , PLAINTIff, ROBERTSCOTTSTEPHENS ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT rETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICh HAVE BEEN RAISED OF RECORr~I IN THIS ACTION fOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. AtTEST~~ ~ PROTHONOTARY