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
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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
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^ 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
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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
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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
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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.
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K STIE L. CORLE
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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
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I N THE COURT OF COMMON PLF.~AS
OF CUMBERLAND COUNTY
STATE OF PENNA.
JASON L. CORLE
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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
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