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Home My WebLink About07-3238MAURICE E. WEST, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW KIMBERLY K. NOLAN-WEST, : NO. 07- 3~- 3 ~ CIVIL TERM Defendant : IN DIVORCE NOTICE 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 the 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 Court House, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 MAURICE E. WEST, v. IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA KIMBERLY K. NOLAN-WEST, Defendant CIVIL ACTION -LAW No. 07- 3 ~- ~ ~ IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE CIVIL TERM 1. Plaintiff is Maurice E. West, who currently resides at 105 East Garfield Street, Shippensburg Borough, Cumberland County, Pennsylvania, 17257. 2. Defendant is Kimberly K. Nolan-West, who currently resides at 105 East Garfield Street, Shippensburg Borough, Cumberland County, Pennsylvania, 17257. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on January 26, 1987, in Hagerstown, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 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. Neither party is now serving in the United Armed Forces. However, Plaintiff served in the US Army from 1969 until 1972. 9. Plaintiff requests the Court to enter a Decree in Divorce. By: Paul Bradford Orr, squire Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 71786 VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §490 , relatin to unsworn falsification to authorities. . ~ ~' d ~ ' r SATE. ~ C Maurice E. West, Petitioner {,~ ~ "J nj~'.; , w _t W a'a~ f4. e ~ ~ '; „a' 4._' ' ` W ~ ~ ~ - t,. .:~- ~ J =~ ~ ~ ~ ~~ 1 n~ c.:.~ --.i 3~- W A C.J cz~ --~ m-" L ~ \ ~~ -~~# MAURICE E. WEST, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW KIMBERLY K. NOLAN-WEST, : NO. 07- ~~~~ CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 7th day of June, 2007, I Paul Bradford Orr, Esquire, attorney for Maurice E. West, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above- captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, restricted delivery, return receipt requested. The original return receipt card signed by the Defendant on June 6, 2007 indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Dated: D LAW FF E F PAUL B By: Paul Bradford Cfrr, I?s~uire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court I.D. # 71786 RD ORR ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print 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, or on the front if space permits. 1. Article Addressed to: I~ i rnbP~\y 1~. I~lola,~- U~1~ ~~~ao-s~ CAa~~-eld Sl-. ~h~I~P ~ 1~1 o~J~ A. Received by (Please Print Clearly) ~ B. Date of C. Sfg`nat~u D. Is delivery address different from item 14 ^ Yes If YES, enter delivery address below: ^ No 3. Service Type Certified Mail ^ Express Mail (~ Registered ('~ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7 CI 0 3 107, 0 0 0 D 1 12 ^ 4 7 7 8 8 (Transfer from service label) PS Form 3811, March ~~ Don>satic Retixrr Rsoeipt 1025e5-01-M-1424 EXHIBIT "A" `'~i _.-~ -n rct E+~ ~ ;-rs ~ "~~ y 2. ~~ J ~~ ~ ~ ~. ~~ fMAiNtiC! f!. w~T, ~. : IN TNT COYRT Or lN11fg1O1i M.fRA~1s OF fl~hint11E1 : CIIMNIRLAND COl~lTY~ f'lNNiYLVANiw fK1~fRRiLY fK. NOLAN-wft~T~ D~~(iwd~nt CMIL wCTEt~I - uw NO. ~00T - 323A CMIL Tfll'IRM IN DIVORCE! AFFDwYiT Of CONff1tNT A complaint in divorce under Section 3301 (d) of the Divorce Code was filed in this matter on or about May 31, 2007. More than ninety days have expired since the service of the complaint on the defendant (see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. September 2007 - ' 1 ERLY K. N N VYEST ww1YRR Of NOT1Ct Op 1N7'f1tNTiON TO RNiIY~T 1E~f1'RY OrF A p1Y~OQ~ UNOtR eft a~ {~) OE 'TNf>t COIK 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 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 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 unswom falsffication to authorities. September 2007 ` KI ERLY K. N WEST -~ cx, ~,, cry ~._ ... s~~ . !V ~ ~~ 7~ N MAURICE E. WEST, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW KIMBERLY K. NOLAN-WEST, : N0.2007- 3238 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) & (d) of the Divorce Code was filed on May 31, 2007. 2. The marriage of Plaintiff and Defendan t 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 of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this AfFdavit 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. L Date: ~ 1 ~ 1, ~ Mau E. West, Plaintiff ° ~s x ~ ~ ;3.1 ~r to ~- N tt; G7 -~ a:,, i. C3 ~ -'~ MAURICE E. WEST, : iN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW KIMBERLY K. NOLAN-WEST, : N0.2007- 3238 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) & (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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 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 unsworn falsification to authorities. 1-) O 1 G. Date: ,~ ~ L ~ ~ Maurice E. West, Plaintiff C:~ C ' s fT1R "~ . ~ y,~).,~14 ~~44 ~ "Cf rte....: " ' fk.; ~ ~ MAURICE E. WEST, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v• :CIVIL ACTION -LAW KIMBERLY K. NOLAN-WEST, : NO.2007- 3238 CIVIL TERM Defendant : 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) 8~ (d) of the Divorce Code. 2. Date and manner of service of the complaint: June 6, 2007, by U.S. Mail, postage prepaid, certified, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) & (d) of the Divorce Code: by the Plaintiff on September 24, 2007; by Defendant on September 24, 2007. 4. Related claims pending: NONE 5. Date Plaintiff s Waiver of Notice in §3301(c) & (d) Divorce was filed with the Prothonotary: September 25, 2007. 6. Date Defendant's Waiver of Notice in §3301(c) & (d) Divorce was filed with the Prothonotary: September 24, 2007 Date: ~ ~~ ~~ g Y• Paul Bradford Orr, E 50 East High Street Carlisle, PA 17013 (717) 258-8558 uire ~ C no ° a -cs ~ ~~`r to rn r ~ ~, '.~~ '~' r- r'^,~. ~ ~ -~ .. Git ~ ~ /-. ~.. 'Ct ~ ~ ~ ~~ ! ! ~~ ~ ~ ~ I N THE COURT OF COMMON PLE S OF CUMBERLAND COUNTY STATE OF " ~ PENNA. ~. - ,.. MAURICE E. WEST, , , Plaintiff N O. 3238 ¢f 2007 VERSUS KIMBERLY K. NOLAN-WEST, Defendant DECREE IN DIVORCE AND NOW, ('~!'LCi,~~~ Z6~~IT IS ORD~RED AND DECREED THAT MAURICE E. WEST PLAIN I FF, AND KIMBERLY K. NOLAN-WEST DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS HICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDE HAS NOT YET BEEN ENTERED; BY THE C URT: ~` AT EST: _ w J . PROTHONOTARY ~~ ~~ ~. ~- " ~ ~ `