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Home My WebLink About07-4544r JESSICA K. CLARK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW TERRY F. CLARK, : NO.07- L{ SN ~ CIVIL TERM Defendant : 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 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. 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 .r. ~ - r JESSICA K. CLARK, Plaintiff v. TERRY F. CLARK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07- ~~y~ IN DIVORCE CIVIL TERM COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Jessica K. Clark, who currently resides at 960 Forge Road, Carlisle, Cumberland County, Pennsylvania, 17015. 2. Defendant is Terry F. Clark, who currently resides at 220 Meals Drive, Carlisle, Cumberland County, Pennsylvania, 17015. 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 Defendant were married on May 14, 2005, in Navarre, Santa Rosa County, Florida. 5. Plaintiff and Defendant separated on or about June 9, 2007. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. 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. s 9. Both parties did serve in the United Armed Forces. Both parties are now retired from the United States Armed Forces. 10. Plaintiff requests the Court to enter a Decree in Divorce. By Paul Bradford Orr, Esquire Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717)258-8558 Supreme Court ID # 71786 .. VERIFICATION I verify that the statements made in the foregoing Divorce 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. DAT ~~ J ica K. Clark, Petiti ner ~ C`a ~ ^~ ~ W "~ ~~~: ~-}~ F_ -~, ~"'- ~ .~ 1 , L~7 _ _ W ~ "," C ~- ~ ._ ~~ -- ; + ~ V1 (~ ~ ~' w o'~" ~ W ~ v M ~ Q 1 Q JESSICA K. CLARK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - L[A~W TERRY F. CLARK, : N0.07- ~~~ 6 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of myself, the Defendant, Terry F. Clark, in the above-captioned action. DATE: U ~ ~~ B Y ~ --3 r ~ . T~ ~,} `~ ~ ~r , "k7 r ^ ~ ~ . ~ ~ JESSICA K. CLARK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW ~ o ,~ TERRY F. CLARK, : NO. 07- 4544 CIVIL TERM _,.,_ ~ ,; Defendant : IN DIVORCE ,~ '~ ~} AFFIDAVIT OF CONSENT ~' c.a ~~~'' 1. A Complaint in Divorce under Section 3301(d) of the Divorce Code was filed on July 31, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. § 4904, relating to unsworn falsification to authorities. Date: ( ~ ~' _.~ ~ L; Terry F. Clar JESSICA K. CLARK, : IN THE COURT OF COMMON PLEAS OF LVP~,IIA Y Plaintiff :CUMBERLAND COUNTY, PENNS C ,~ a _~ `~ v. :CIVIL ACTION -LAW -~.~~ ~ -~ -~ , ~ ~, TERRY F. CLARK, : NO. 07- 4544 CIVIL TERM ~'~ ' - Defendant : IN DIVORCE f~ ;~ -~ ~=_ ~T> .--' - w --j WAIVER OF NOTICE OF INTENTION ~;, ~ ~., TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (d) 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 this 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: ~ ~' r' (~ ~' Terry F. Clark JESSICA K. CLARK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW TERRY F. CLARK, : NO. 07- 4544 CIVIL TERM Defendant : IN DIVORCE r'' ° v ~ a ~7 ~.: ~ WAIVER OF NOTICE OF INTENTION f `: -- ~~ TO REQUEST ENTRY OF A DIVORCE DECREE = r" 'fit UNDER § 3301 (d) OF THE DIVORCE CODE ~t --: ~' .yam v 1. I consent to the entry of a final decree of divorce without notice. ~ .fi- -..s -c 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. §4904, relating to unsworn falsification to authorities. Date: / o~ d \ ssica K. Clark JESSICA K. CLARK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. TERRY F. CLARK, Defendant CIVIL ACTION -LAW NO. 07- 4544 CIVIL TERM IN DIVORCE n ~? v C « f~ ~c~ ~ .._ ` ~ ~ ~-, cf ~ z?~ _~ _ .. -n ~;. _ -r~ - AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(d) of the Divorce Code was filed on July 31, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. § 4904, relating to unsworn falsification to authorities. Date: ~ ~ _ J ica lark JESSICA K. CLARK, Plaintiff v. TERRY F. CLARK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 07-4544 fN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD n ~ _., = ~ z =, ' ~ c . ~ - -r . ~' - ~ . ..,~ r-~, TO THE PROTHONOTARY: `=' 1:.5 .r - "U -' ~ ~=~~ Transmit the record, together with the following information, to the Cc~ti~for try ~ ~ ~ a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) or (d) of the Divorce Code. 2. Date and manner of service of the complaint: August 8, 2007, by hand delivery. Acceptance of Service filed with the Courts on August 10, 2007. 3. Date of execution of the affidavit of consent required by Section 3301(c) & (d) of the Divorce Code: by the Plaintiff on January 6, 2010; by Defendant on January 6, 2010. 4. Related claims pending: NONE 5. Date Plaintiff's Waiver of Notice in §3301 (c) & (d) Divorce was filed with the Prothonotary: January 11, 2010. 6. Date Defendant's Waiver of Notice in §3301(c) & (d) Divorce was filed with the Prothonotary: January 11, 2010. U By. Date: Paul Bradford Orr, Esq~ 50 East High Street Carlisle. PA 17013 (?17) 258-558 IN THE COURT OF COMMON PLEAS OF JESSICA K. CLARK :CUMBERLAND COUNTY, PENNSYLVANIA V. TERRY F. CLARK NO. 07-4544 DIVORCE DECREE AND NOW, ~i' 7.oio , it is ordered and decreed that JESSICA K. CLARK plaintiff, and TERRY F. CLARK 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 ~~ ry By the Court,