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HomeMy WebLinkAbout03-4259Matthew C. Cornman, : iN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW Sharon Comma, : NO. 03- ~/.l.~q CIVIL TERM Defendant : iN DIVORCE NOTICE TO DEFEND 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, PA. 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 or (800) 990-9108 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. Matthew C. Comman, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION- LAW Sharon Cornman, : NO. 03- q.2~ CIVIL TERM Defendant : 1N DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Matthew Corm-nan, who currently resides at 65 East Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266. 2. Defendant is Sharon Cornman, whose address is 144 West Church Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 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 De£endant were married on September 7, 1996 in Carlisle, Cumberland County, Pennsylvania. 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. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, Michael J. Whare, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 89028 Attorney for Plaimiff VERIFICATION I verify that the statements made in this Complaint 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. Matthew Comman, Plaintiff CERTIFICATE OF SERVICE I, Michael J. Whare, Esquire, attomey for Stephen Barrick, do hereby certify that I this day served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Carlisle, Pennsylvania, addressed as follows: Sharon Comman 144 West Church Ave. Carlisle, PA 17013 Attorney for Plaintiff Date Matthew C. Cornman, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Sharon Comman, NO. 03-425!;) CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 28, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree i~ Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN 'THE FOREGOING 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. Date ~RO hi CORN~N Matthew C. Cornman, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Sharon Cornman, NO. 03-4259 CIVIL TERM Defendant IN DIVORCE WAIVER 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 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 THE FOREGOING 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. Date -- -~ON CORNMA~- IN THE COURT OF COMMON PLEAS OF Matthew C. Cornman, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO, 03-4259 CIVIL TERM Sharon Cornman, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 28, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. MATT'HEW C. CORNMAN Date IN THE COURT OF COMMON PLEAS OF Matthew C. Cornman, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -. LAW NO. 03-4259 CIVIL TERM Sharon Cornman, Defendant IN DIVORCE WAIVER OF INTENTION TO RF. QUEST. ENTRY OF A DIVORCE DECREIE UNDER_ .~ 330t(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 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 THE FOREGOING 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. Date Matthew C. Cornman. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY. PENNSYLVANIA : V. : Sharon Comman, : CIVIL ACTION - LAW : NO. 03-4259 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORi~ TO THE PROTHONOTARY: Transmit the record, together with the tbllowing information, to the Court for enlD, ora divorce decree: 1. Grounds for divorce: irretrievable breakdown under ~ 3301 (e) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail - received and signed for on September 5. 2003 by' Defendant, attached as Exhibit "A". 3. Date of execution of the affidavit of consent required by § 3301(e) or The Divorce Code: by the Plaintiff July 18. 2004: by the Defendant July 10, 2004. 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: ~ Date: 7--~% ~}-,o ~ Michael J. Whare, Esquire Rominger, Bayley & Whare 155 South Hanover Street Carlisle, PA 17013 Supreme Court ID # 89028 Matthew C. Comman, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : V. : Sharon Comman, : CIVIL ACTION - LAW : NO. 03-4259 CIVIL TERM Defendant : IN DIVORCE P~ROOF OF SERVICE ·Complete items 1, 2, and 3. ,Nso complete item 4 if Resttfcted Dellve~ is desired. ·Prlllt your name and address on the reverse so that we can retum the card to you. ,.B Attach this card to the back of the mailpiece. Nam~ Or O~ the fro~t if space permits. 1. ~cleA,~_~._~j io: D. Is~.~,x ~G~ d/~lf~t fmmitam i? Yes ~ M~lil [] E~l~f~ Moll [] ¢.O.B. Ps Form 3811. August 2001 Dora~tic Return Receipt Exhibit IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF ~ PENNA. Matthew C. Cornman Plaintiff NO. 4259 03 VERSUS ~hn~n ~nm=n Defendant DECREE IN DIVORCE AND NOW, ~;7~/ .~:~' , ~e~/ , It IS ORDERED AND DECREED THAT Matthew C. Cornman , PLAINTIFF, AND Sharon Cornman , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION Of THE FOLLOWING CLAIMS WHICh HAVE BEEN RAISED Of RECORD IN ThIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None A~ ~ J' OTARY