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HomeMy WebLinkAbout03-3976IN THE COURT OF COMMON PLEAS OF CLPMBERLAND COUNTY, PENNSYLVANIA STEPHEN W. TAYLOR, ) Plaintiff ) ) v. ) ) SANDRA L. TAYLOR, ) Defendant ) NO. 2003- ,,~c~i~,/_ CWIL TERM CIVIL ACTION - LAW 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 ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of manSage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. 11: 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. 1~ 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 hearing or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN W. TAYLOR, ) Plaintiff ) ) v. ) ) SANDRA L. TAYLOR, ) Defendant ) NO. 2003- ~ ?l CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Stephen W. Taylor, by and through his counsel, Howett, Kissinger & Conley, P.C., who states the following in support of the within Complaint: 1. Plaintiff is Stephen W. Taylor, an adult individual who currently resides at 121 Windrush Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Sandra L. Taylor, an adult individual who currently resides at 4204C Society Park Court, Harrisburg, Dauphin County, Pennsylvania, 17109. 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 September 28, 1969 in York, 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. The parties have lived separate and apart since in or about August 1, 2003. 10. Plaintiff requests the court to enter a decree of divorce. Date: Respectfully submitted, Donald T. Kissinger, Esquire HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Stephen W. Taylor VERIFICATION I, Stephen W. Taylor, hereby swear and affirm that the facts contained in the foregoing Complaint in Divorce are true 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: %. AYLO~7 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA STEPHEN W. TAYLOR, ) Plaintiff ) ) SANDRA L. TAYLOR, ) Defendant ) NO. 2003-3976 CIVIL TERM CIVIL ACTION - LAW 1N DIVORCE ACCEPTANCE OF SERVICE_. I, Sandra L. Taylor, Defendant in the above-captioned divorce action, hereby accept service of the Complaint in Divorce filed with this Court on August 14, 2003. Date: andra L. Taylor, D-ef~d~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN W. TAYLOR, ) Plaintiff ) ) v. ) ) SANDRA L. TAYLOR, ) Defendant ) August 14, 2003. 2. NO. 2003-3976 CIVIL TERM CIVIL ACTION - LAW 1N DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divome 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 REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divome 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 m~til 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: Steph n Taylm', P ' nti ff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN W. TAYLOR, ) Plaintiff ) ) v. ) ) SANDRA L. TAYLOR, ) Defendant ) NO. 2003-3976 CIVIL TERM CIVIL ACTION - LAW IN DWORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) o~the Divorce Code was filed on August 14, 2003. 2. The marriage of Plaintiff and Defendant i.s 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 fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I ,.mderstand 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 imme. diately 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: ///7_ ~/O~ Sandra L. Taylor, Defen(tJ, mt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN W. TAYLOR, ) Plaintiff ) ) v. ) ) SANDRA L. TAYLOR, ) Defendant ) NO. 2003-:3976 CIVIL TERM CIVIL ACTION - LAW 1N 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 Divorce Code. Date and manner of service of the complaint: Service accepted by Defendant Sandra L. Taylor on August 19, 2003; Acceptance of Service filed on August 25, 2003. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff, November 19, 2003; by defendant, November 29, 2003. Related claims pending: All claims resolved by Marital Settlement Agreement dated July 30, 2003. Date: Date plaintifPs Waiver of Notice in §3301(c) Divome was filed with the prothonotary: contemporaneously herewith; date defendant's Waiver of Notice in §3301(c) Divome was filed with the prothonotary: contemporaneously herewith. '--lYffWald T. Kissinger, Esquire HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P. O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Stephen W. Taylor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. STEPHEN W. TAYLOR, 03-3976 CIVIL TERM NO. Plaintiff VERSUS SANDRAL. TAYLOR, De~ndant DECREE IN DIVORCE STEPHEN W. TAYLOR DECREED THAT SANDRA L. TAYLOR AND 2003, IT IS ORDERED AND , PLAINTIFF, , DEPENDANT, ARE DIVORCED FrOM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE pOILOWING CLAIMS WHICH HAVE BEEN rAISED OF rECOrD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None. YET BEEN ENTERED; It is further ORDERED, ADJUDGED and DECREED that the terms, provisions and conditions of a certain Marital Settlement Agreement between the parties dated July 30, 2003, are incorporatea, but not filea ot recortt, in this Decree in Divorce by reference as fuiiy as if the same were set forth herein at length. Said Agreement shall not merge with burial, survive this De~¢ i, Divo~'c~. .?" ~OU RT: / ATTEST: - ~/ /~~PROTHONOTArY