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Home My WebLink About07-4721John C. Howett, Esquire HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff, Jayme Cashman NO JUDGE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAYME Y. CASHMAN, Plaintiff ) v. ) NO. 2007- ~7~ ~ CIVIL TERM BARYON R. CASHMAN, ) CIVIL ACTION -LAW 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 maybe 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 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, PA 17013 Telephone: (717) 249-3166 AMERICANS WITH DISABII.ITIES 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. 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAYME Y. CASHMAN, ) Plaintiff ) v. ) BARYON R. CASHMAN, ) Defendant ) NO. 2007- '~'~~ ~ CIVIL TERM CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Jayme Cashman, by and through her counsel, Howett, Kissinger & Holst, P.C., who states the following in support of the within Complaint: 1. Plaintiff is Jayme Y. Cashman, an adult individual who currently resides at 4808 Virginia Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Barton R. Cashman, an adult individual who currently resides at 22 Arlington Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Both the Plaintiff and the Defendant have been bona fide residents in the Commonwealth of Pennsylvania for a period of at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on September 2, 2000, in Camp Hill, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States of its allies within the provisions of the Servicemembers Civil Relief Act. 6. There have been no prior actions for divorce or annulment of the marriage instituted by either of the parties in this or any other jurisdiction. 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. The parties have been separated since on or about July 6, 2007. COUNT I -DIVORCE PURSUANT TO §3301(c) or d~ OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The marriage of the parties is irretrievably broken. 11. The parties have executed a Marital Settlement Agreement dated August 3, 2007 resolving all issues ancillary to the dissolution of the marriage, which will be incorporated but not merged in the divorce decree when granted. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to §3301 of the Divorce Code and respectfully requests that this Honorable Court enter an order incorporating, but not merging, the fully executed Marital Settlement Agreement into the Decree. Respect lly sub Date: Jo . Howett, squire HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff, Jayme Cashman ,. VERIFICATION I, Jayme Y. Cashman, hereby swear and affirm that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: b' ~' (~ ~ ~ _..... Jayme Y. Ca hman 1,`~ ~~ ~ ~~ ~ ~ t_~ .~_a ~ -s-r t ~ ._, :% ``` °.J t V V t j ~a~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAYME Y. CASHMAN Plaintiff NO. 2007-4721 CIVIL TERM v. BARYON R. CASHMAN, Defendant CIVIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Barton R. Cashman, Defendant in the above-captioned divorce action, hereby accept service of the Complaint in Divorce. Date: ~ ~ S ~ ~ ~LJ~/~i I` <:. Barton R. Cashman Defendant C ...r r ~ N ~` ~~~ :~' _~ 'Y i -; y h ~ i 7 J ~_ 7 E. = ' ~-,,, cam, ~~ ° ~ (~.; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAYME Y. CASHMAN Plaintiff ) NO. 2007-4721 CIVIL TERM v. ) BARYON R. CASHMAN, ) CIVIL ACTION -LAW Defendant ) IN DIVORCE ACCEPTANCE OF SERVICE I, Barton R. Cashman, Defendant in the above-captioned divorce action, hereby accept service of the Complaint in Divorce. Date: ~ l ~ ~ ~ ( 1~ •> Barton R. Cashman, Defendant rv 'art -,-, -_ 4.. l •-.• ~ ~''-H ~ ~ ~ ~ j f (t \ Tj {~ W' ~ - ~: ~ raw ~ .,,1 - - .. ~ f ~ .- . . z~ • • l,~t "~ t~ ~~ R; G - ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAYME Y. CASHMAN, ) Plaintiff ) NO. 2007-4721 CIVIL TERM v. ) BARYON R. CASHMAN, ) CIVIL ACTION -LAW Defendant ) IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A compiaint in divorce under §3301(c) of the Divorce Code was tiled on August 9, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE 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 above 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: (I ~!~ l07 ~- Barton R. Cashman, Defendant C'3 +v -~: ..E..t ~~. ~ ~ C? t ~ r, "^~. '~}~..'~ _ _ fir- ..... .f1 fi ^ ~ . }~ (`{+w"ut s~ s f~T ~~ // ~' 7 ~ ~....., ~~°° • ~ t ~~ ~,. ~ _~, ~} .•,~ ,tom • c~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAYME Y. CASHMAN, ) Plaintiff ) NO. 2007-4721 CIVIL TERM v. ) BARYON R. CASHMAN, ) CIVIL ACTION -LAW Defendant ) IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on August 9, 2007. 2. The mamage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE 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 above aze true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~S ~~ . Jayme . Cas , P iff i, ~-,. %- ~ ~ ~ ~~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAYME Y. CASHMAN Plaintiff } NO. 2007-4721 CIVIL TERM v. ) BARYON R. CASHMAN, ) CIVIL ACTION -LAW Defendant ) 1N 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: 1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service accepted by Defendant Barton R. Cashman on August 15, 2007; Acceptance of Service filed on August 20, 2007. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff, November 15, 2007; by defendant, November 16, 2007. 4. Related claims pending: No related claims pending. 5. Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: contemporaneously herewith; date defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: contemporaneously herewith. Date: ~ ~l ~U ._.___ /r ,,. John . Howett, Jr., E uire WETT, KISSINGER HOL T, P.C. 130 Walnut Street, P. O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Jayme Y. Cashman C7 ~ p C ~; - ~ . - ~ !~#` ~ ~ ~ v ~ ' ° -C .-. ~ ~ '~ .. .3 r_. 'C ... ~ t =,.2 t.. . ' 7 .G'n ~ .~ ` ~ _~ - ~~ _ _ ,~ ~ .,, 4 I N THE COURT OF COM 1VION PLEAS JAYME Y. CASHMAN N O . 2007-4721 CIVIL TERM VERSUS BARYON R. CASHMAN Defendant DECREE IN DIVORCE r+~ 2007 AND NOW, ~ ` IT IS ORDERED AND OF CUMBERLAND COUNTY STATE OF " ~ PENNA. =~ ~, - , DECREED THAT JAYME Y. CASHMAN PLAINTIFF, AN D BARYON R. CASHMAN 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. PROTHONOTARY ~ ~,«"~ ~K ~O~ ~L ~ ~~ ~. ~ 9~