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Home My WebLink About07-3797? w s• ', Sharon R. Daniel IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.07- 3 7 9 7 CIVIL TERM Darryl J. Daniel Defendant 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 marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Sharon R. Daniel IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 3 CIVIL TERM -7 Darryl J. Daniel Defendant IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ??'1(jr?Yl R 'Da A i 0 , who currently resides at _X33 Sum 6TreV-L , Iemqn- r 10 4 T Cumberland County, Pennsylvania. 2. Defendant is DarnAi J Dcni 6 , who currently resides at I ? X Qnll.o_-k6n ::+, Ma Pa III oL- 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on June, i g , 2 M I at to D hnsLI? a h, l? 5. The marriage is irretrievably broken, and the parties separated on J? ZOOS' 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. , a 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. I, I 1 01 Jta? 4'-? i Date Pl mtiff, Pro Se I, Sharon rR D A rit e I , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. G?V*t ? 01 D le: uE1 cyt Plaintiff, Pro Se ?'?/ Assisted by: ??4?pq Marcus A. McKnight II, re Irwin & McKnight Law fices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 Q C= "T7 F ?..,. ? IF S1 ? , C- -n 71 i . rrl cy '. c:y tv w Sharon R. Daniel Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 3 7 7 7 CIVIL TERM Darryl J. Daniel Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Sharon R. Daniel, Plaintiff, to proceed in forma au eris. I, Marcus McKnight, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Date: June 21, 2007 cps A. McKnight Atto ey for Plaintiff " Irwin & McKnight Law 60 W. Pomfret Street (717) 249-2353 N_ C Q 4- r F N SHARON R. DANIEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 3 791 NO. 2007 - 3897 CIVIL TERM DARRYL J. DANIEL, Defendant IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS: NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Darryl J. Daniel, on June 26,2007, by certified, restricted delivery mail, addressed to him at 1128 Rollerton Street, Harrisburg, Pennsylvania 17104, with Return Receipt Number 7004 1350 0003 7289 3402.. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. 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 J,8 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. MARCUS A. Mcl IGHT, III, ESQUIRE Attorney for Plaintiff Date: June 29, 2007 t ru wim"Al C3 7 or m m Mi. ru r` Postage m CiertMed Fee 0 C3 Retum Redept Fee M (Endorsement Requlred) O Ressicted ee u'l (EndotsemeM squired) M r=1 Total Postage & Fees o MR DARRY r- CiWEPiRC - Rn lk CornpNte iterm 1, 2, iMI A90 ccmplate 4 W Resltisted D*.Wy is desired. "r, p" aw so" i 0 on thb fetreiae . so #0 we can reborn the card to you. ¦ Attwh this card to the back of the ffud" ce, or on the front if space permits. 1. ArUcle Addressed to: MR DARRl1. J DAHIn 1128 ROLLMRSTOR STRSBT RARRISBMG PA 17104 M Rmxived by (ftft MernO I C. Is dakwy rtklr 1 dl%m. ftm Item 1? u Yet If YES, enter delivery address below: 0 No 3. Service Type ® Csttflled MeN O Express Mail 0 Registered 19 Re4trn RecW for Mwdtendiae 0 kmmud 4. ReetddAd DeWuery? Pdm Fee) b7 tiin 2. AradeNmber (ww#brftmservke/ew 7004 1350 0003 7289 3402 P$ Form 3811, Febnjary 2004 Domestic Retum Recelpt 102595-02-tin-1540 q gt '+ SHARON R. DANIEL, : IN THE COURT OF COMM PLEAS OF Plaintiff : CUMBERLAND COUNTY, PE NNSYLVANIA V. CIVIL ACTION - LAW NO. 2007 - 3797 CIVIL TERM DARRYL J. DANIEL, Defendant IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you m ust file a counter- affidavit within twenty (20) days after this affidavit has been served on you or t1 ke statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about October 2005, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of pro p , lawyer's fees y or expenses if I do not claim them before a divorce is granted. r 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. 0 4904 relating to unworn falsification to authorities. 1 Date: r V- 7) S ARON R. DANIEL Plaintiff FILES-:1. ,07 THE P 1 V y 2909 JUiiIs 25 Pi6i 21 rEl dNa?`'1?'?1';,'4NA SHARON R. DANIEL, Plaintiff V. DARRYL J. DANIEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3797 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE To: DARRYL J. DANIEL You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the Section 3301(d) affidavit. Therefore, on or after July 26, 2009, the other party can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final Decree in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect your economic claims. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORT TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 SHARON R. DANIEL, Plaintiff V. DARRYL J. DANIEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3797 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE To: DARRYL J. DANIEL SHARON R. DANIEL intends to file with the Court the attached Praecipe to Transmit Record on or after July 26, 2009, requesting that a final Decree in Divorce be entered. IRWIN & McKNIGHT, P.C. By: A.TA?Knight, III, Esquire 60 est Pom' t Street C isle, Penns vania 17013 (71 3 Attorney for Plaintiff Date: June 25, 2009 FILED-i FFIC E OF THE PROTHONOTARY 2009 JUN 2b Pty 2: 52 PENNSYLMA SHARON R. DANIEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2007 - 3797 CIVIL TERM DARRYL J. DANIEL, Defendant IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD 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(d) of the Divorce Code. 2 Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Darryl J. Daniel, on or about June 26, 2007, by certified, restricted delivery mail, addressed to him at 1128 Rollerton Street, Harrisburg, Pennsylvania, 17104, with Return Receipt Number 7004 1350 0003 7289 3402. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by plaintiff: ; by defendant: . (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: June 19, 2009. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: Filing date: June 25, 2009. Service made on or about June 27, 2009. 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: June 27, 2009 by regular mail. A copy of Counter-Affidavit signed by Defendant is attached hereto. (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in Section 3301 ivo a with the Prothonotary: rcus cKmght, III, Esquire Drnev for aintiff Date: July 27, 2009 SHARON R. DANIEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2007 - 3797 CIVIL TERM DARRYL J. DANIEL, Defendant IN DIVORCE COUNTER AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is. not irretrievably broken. 2. Check. either (a) or (b): (a) I do not with to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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 unworn falsification to authorities. , DARRYL J. IEL Defendant Date: -. //- o9 NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. FILE OF THE: 't 20,09 JUL 21 ?? ?? . 3 SHARON R. DANIEL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DARRYL J. DANIEL NO. 2007 - 3797 Civil Term DIVORCE DECREE AND NOW, ZB 2v u 1 it is ordered and decreed that SHARON R. DANIEL plaintiff, and DARRYL J. DANIEL defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, .i ...._ P?.? .. ?fI ?,,