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HomeMy WebLinkAbout07-3770 IuROLD s. IRwIN, III, EsauIRE ATTORNEY ID NO.26Itso 64 soUTN PITT STREET CARLISLE PA 17015 (71 ~ 243-6050 ATTORNEY FOR PLAINTIFF JASON L. CORLE, : IN THE COURT OF COMMON PLEA8 OF PlalntlA :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW N0.200T - 3 7 ~ D CIVIL TERM KRI8TIE L. CORLE, Ds~hndant : 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 in 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, Cumberland County Courthouse, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 JASON L. CORLE, : IN THE COURT OF COMMON PLEAS OF Plalntlil :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO.2007 - 3 776 CIVIL TERM IatIST1E L. CORLE, D~findant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION SS01 c OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is JASON L. CORLE, an adult individual residing at 3148 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is KRISTIE L. CORLE, an adult individual residing at 1056 Rebecca Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on May 23, 1998 in Bedford, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. June 22, 2007 JASON L. CORLE, Plaintiff HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 JASON L. CORLE, : IN THE COURT OF COMMON PLEAS OF PlalntlA :CUMBERLAND COUNTY, PENNSYLVANIA ~, :CIVIL ACTION -LAW N0.200T - 3776 CIVIL TERM KRISTIE L. CORLE, Dehndant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. June 22, 2007 ASON L. CORLE, Plaintiff ~n~. f A~ ~ ~ `"' ~ _ a ~~~~ ti ~ ~ ~~ ~ ~- o ~ ~ d Vic, z ~~ P `'' ~~ ti~ E f HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF JASON L. CORLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW NO. 2007 - 3770 CIVIL TERM KRISTIE L. CORLE, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on June 25, 2007, addressed to the defendant at Dawood Engineering, 2020 Good Hope Road, Enola, PA 17025, Certified Mail No. 7003 2260 0000 8703 0426. 3. A copy of the sender's and signed receipt are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. June 26, 2007 Harold S. Irwin, III Attorney for plaintiff Supreme Court ID No. 29920 64 South Pitt Street Carlisle, PA 17013 717-243-6090 .~ <M7~^^171~^11~II! (Domestic Mail Only; Nc _~ m m v ~ ~" ~ ~ ~/'L71 p~stage $ ~ _ (Certified Fee ` ~ Retum ReGept Fee Postmark 0 (Endorsement Required) 2 ~ ~ Here ^ ResMded Delivery Fee ,,,p (Endorsement Required) f1J ~ Total Postage 6 Fees ~ ant To r~ Street, Apt. No., or PO Box Nd. ~,_a ~..~~ City State, Z +4 Z ^ 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 vre 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: ~'~ISTIE CORLE DAWOOD '1NGINEERIr1G 2 0 2 0 GOOD 1i0PE RD ENOLA P'~ 17025 A. Sig re _ B. Received by (Printed Name) C. Date of ivory ~' a7 D. Is delivery address different from ftem 1? ^ Y If YES, enter delivery address below: ^ No 3. Type Mail ^ Express Mail ^ Registered ^ Return Receipt for Mercharxfise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) es 2. Article Number 703 226 000 8703 0426 (fiansfer from service leb~ PS Form 3811, February 200+4 Domestic Return Reoelpt ~o2sas-o2-M-~sao EXFIIBIT °A° ° C7 G ~ --' -n tty `:~ , _-§ ..~'' r, ~. _ ~~~. ~5, ~ +!~ ~ ~...,~ ~t ry ' V JASON L. CORLE, : IN THE COURT OF COMMON PLEAS OF PlalntliF :CUMBERLAND COUNTY, PENNSYLVANIA r. :CIVIL ACTION -LAW NO. 2007 - 5770 CIVIL TERM KRISTIE L. CORLE, Deiandant : IN DIVORCE AFFDAVIT OF CONSENT A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about June 22, 2007. Service of the complaint was made upon defendant on June 25, 2007 (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 lSON L. CORLE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 5501 jjD) OF THE DIVORCE CODE 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 unsworn falsification to authorities. September, 2007 - ASON L. CORLE ~`~ ,` .. N c~ ~ ~ ~ 1 Ef7 ' ' { `1 ' ( 1 7 "~.y _ fI'1 J ~~ `+./ - 7 ,J i_r w.... .~ -; .l C+'i j:~7 CL ^C JASON L. CORLE, : IN THE COURT OF COMMON PLEAS OF Plalntlff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW NO.2007 - 3770 CIVIL TERM KRISTIE L. CORLE, Defendant : IN DIVORCE AFFDAVIT OF CONSENT A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about June 22, 2007. Service of the complaint was made upon defendant on June 25, 2007 (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 (~~_ ~ G 'Z--- `~K STIE L. CORLE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3307 (D~ OF THE DIVORCE CODE 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 unsworn falsification to authorities. 3e temberr~ ~ 2007 ~ ~~--~ ~ ~, ~'~._ p -, K STIE L. CORLE r` `' =~ --r ~- z " 1 ~ _~ ~ ~- - -. C ;' ~? • ; ~ ~~ .~ _ ~"'~` HAROLD S. IRWIN, 111, ESgU1RE ATTORNEY ID N0.2S920 64 SOUTH PITT STREET CARLISLE PA 17015 (777) 24&6050 ATTORNEY FOR PLAINTIFF JASON L. CORLE, : IN THE COURT OF COMMON PLEA8 OF Plalntlff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW N0.2007 - 3770 CIVIL TERM KRISTIE L. CORLE, 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: Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about June 25, 2007 defendant was personally served with a copy of the divorce complaint (see Affidavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: September 26, 2007 By the defendant: September 27, 2007 (b)(1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: NIA. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: NIA. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: October 1, 2007 Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: October 1, 2007 , October 1, 2007 HAROLD S. IRWIN, Attorney for Plainti ~ ^' ca .--~ -- ~ _ r~i -~a ~ ~-', c.~ jy~ _ _ `~ ~. z,,.> I N THE COURT OF COMMON PLF.~AS OF CUMBERLAND COUNTY STATE OF PENNA. JASON L. CORLE .. .:~ n. Plaintiff VERSUS KRISTIE L. CORLE Defendant No.2oo~ - 3~~o clvlLl DECREE IN DIVORCE AND NOW, ~L-~ . ~ Zc~'?, IT IS ORDE DECREED THAT JASON L. CORLE AND KRISTIE L . CORLE ARE DIVORCED FROM THE BONDS OF MATR{MONY. TERM ED AND PLAT NT~FF, DEFENCPANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS W ICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WH{GH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE ~ BY THE COURT: A EST: ~ J. PROTHONOTARY -.~~~ ~ Q , ~ - of ~~ c. :. S i