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HomeMy WebLinkAbout07-4777IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Julie K. Irwin, ) Civil Action -Law Plaintiff, ) vs ) No. 2007- ~/"J'Y Richard F. Irwin, ) Defendant, ) In Divorce a v.m. 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 pages by the Plaintiff. You may lose money 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 of the Cumberland County Courthouse, First Floor, 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABAOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Bar Association Lawyer Referral Service 1-800-692-7375 (PA Only) or (717) 238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin 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 arrangement must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Julie K. Irwin, ) Civil Action -Law Plaintiff, ) vs ) No. 2007 - `~~ ~ 7 ~ `~'`"' Richard F. Irwin, ) Defendant, ) In Divorce a v.m. COMPLAINT UNDER SECTION 3301 (a) OR 3301 (c) OR 3301 (d) OF THE DIVORCE CODE COUNT 1 DIVORCE 1. Plaintiff is JULIE K. IRWIN, a sui juris adult, who currently resides at 5 Essex Drive, Carlisle, Cumberland County, Pennsylvania, since September 30, 2000. 2. Defendant is RICHARD F. IRWIN, a sui juris adult, who currently resides at 5 Essex Drive, Carlisle, Cumberland County, Pennsylvania, since September 30, 2000. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 18, 1992. 5. There have been no prior actions of divorce or annulment of marriage between the parties except the action represented by this Complaint. 6. The marriage is irretrievable broken. 7. Neither the Plaintiff nor Defendant is a minor or incompetent. 8. Plaintiff has been advised that counsel is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a decree of divorce. VERIFICATION I verify that the statements made in the foregoing document 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. DATE: 0 - ~D - D DATE: ~- l~-(~7 ~"~.- Anne .Johnson, squire Attorney I.D. # 78039 33 South Main Street Chambersburg, Pa 17201 (717)262-2185 Attorney for Plaintiff ~ ..~, s ~ _ ~- ~~ ~ ` ~ d ~~_ N _~ C,-= ~+J W N to G O --~ rZ I°r ITi ~ ( Z .?; i ,~ ~J rrj -~ ~7 `C Iv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Julie K. Irwin, ) Civil Action -Law Plaintiff, ) vs ) No. 2007- 4777 Richard F. Irwin, ) Defendant, ) In Divorce a v.m. ACCEPTANCE OF SERVICE I, Richard F. Irwin, the Defendant, in the above-capiioned matter, do acknowledge that I have received a true copy of the Complaint for Divorce, filed in the above-captioned matter on August 13, 2007. Date: ~ ` i~ -C7~ \~~~,,~~~ Richard F. Irwin CJ ~ ~ ~-- x - -~ r ~.. --;~ r~'r.:' "'C"71.. :.! ~ . -~ ? l., ) , C: ~,._ C3 ' _) +- ...: __ ~, . .'"-~ ~,_. I:. 1' ~''i <: ; ~ ~ :~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Julie K. Irwin, ) Civil Action -Law Plaintiff, ) vs ) No. 2007- 4777 Richard F. Irwin, ) Defendant, ) In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301 (c) or (d) of the Divorce Code was filed on August 13, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of the final Decree of 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 SECTION & 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 4. 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. 5. 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.A. § 4904, relating to unsworn falsification to authorities. Date: ~~ ' ~ 7 ~ ~ 7 Julie K. Irwin h ~ ~ ~, ~ ~ ~ ~ ~~ _ ~ ~ ~ y . ;1 - 't~ -~ -Y-` ~ V ~ ~.~.J ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Julie K. Irwin, ) Civil Action -Law Plaintiff, ) vs ) No. 2007- 4777 Richard F. Irwin, ) Defendant, ) In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301 (c) or (d) of the Divorce Code was filed on August 13, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of the final Decree of 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 SECTION & 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 4. 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. 5. 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.A. § 4904, relating to unsworn falsification to authorities. Date: - /'~-U .xre~ ~..~''~` Richard F. Irwin rte. ~' ~ -~ `s~F ~. -~ w.:`- ,~ ~, ~: ~: ,,~, ~ ~, MARTHA B. WALKER LAW OFFICE 33 SOUTH MAIN STREET CHAMBERSBURG, PA 17201 (717) 262-2185 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Julie K. Irwin, ) Civil Action -Law Plaintiff, ) vs ) No. 2007- 4777 Richard F. Irwin, ) Defendant, ) In Divorce a v.m. 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 Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: August 14, 2007 - by Acceptance of Service, and filed August 20, 2007. 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code by Plaintiff, November 14, 2007; by Defendant, November 14, 2007. 4. Related claims pending: Resolve through private Agreement; 5. (a) Date Plaintiffls Waiver of Notice in Section 3301(c) Divorce was filed with Prothonotary: November 15, 2007. (b) Date Defendant's. Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: November 15, 2007. MARTHA B. WALKER LAW OFFICE BY: C S. Johnso squire Attorney I.D. # 78039 33 South Main Street Chambersburg, PA 17201 (717) 262-2185 Attorney for Plaintiff C3 ^~ C. ~ a -., ~ "~ ~=; ~ W 1~. ~ ~ t~fi. ~, z..,. -.-.. ~ ~P7 'fi't "'~ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. =;~ ~, - JULIE K. IRWIN PLAINTIFF VERSUS RICHARD F. IRWIN DEFENDANT NO. DECREE IN DIVORCE AND NOW, ~t.C.L1M~D``r ,~ 2007 IT IS ORDERED AND DECREED THAT JULIE K.~RWIN 2007 - 4777 PLAINTIFF, AND RICHARD F. IRWIN ,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; BY THE COURT: ATTEST: ~ J . r PROTHONOTARY ~~' L © ~.l ~'/ 2 ~ ~~ .. i ~~k e '