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HomeMy WebLinkAbout07-5077v JAYNE A. MONAIIAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION -LAW NO. p? _ rs p•~ 7 C i v; ~ Terns JAMES K. MONAIiAN, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIG~[TS 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 grounds 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES. P. C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 JAYNE A. MONAHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. O7- 57'7 JAMES K. MONAHAN, Defendant IN DIVORCE AND NOW, comes the above named Plaintiff, Jayne A. Monahan, by and through her attorneys, Weigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Jayne A. Monahan, is an adult individual presently residing at 4 White House Road, Southampton Township, Shippensburg, Cumberland County, Pennsylvania, since August 9, 2007. 2. Defendant, James K. Monahan, is an adult individual presently residing at 128 East King Street-Rear, Borough of Shippensburg, Shippensburg, Cumberland County, Pennsylvania. . 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. 5. 6. 7. 8. The Plaintiff and Defendant were married on July 1, 1995, in Hilton Head Island, Beaufort County, South Carolina. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. The Plaintiff requests the court to enter a decree of divorce. WEIGLE & ASSOCIATES, P.G. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID # 49634 126 East King Street Shippensburg, PA 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES, P. C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-7397 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. `~ Dated: ?l 22 D~ ~ ~~- A. MONAHAN, Plaintiff WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 77257-7397 ~ ~_. <, N ~ v ,..~ T a t e.y ~"'~ t~~ ~ r `~~ ~ o~ -~- ~ > 4- tv f~ ( n J C _j ~ W W D JAYNE A. MONAHAN, Plaintiff v. JAMES K. MONAHAN, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW :NO. 07-5077 :IN DIVORCE ACCEPTANCE OF SERVICE I, James K. Monahan, the above-named Defendant, accept service of the Notice to Defend and Complaint in Divorce, in the above-referenced matter. Dated: O d S K. MONOHAN 8 East King Street -Rear Sluppensburg, PA 17257 WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~~ C:T ~.. - ~ a~ ~ ~ ~ N v JAYNE A. MONAHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-507? CIVIL TERM JAMES K. MONAHAN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the. Divorce Code was filed on August 24, 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. r~ , Dated: ~ ~-° ~ ! ~~.._ ~.L'~ J A. MONAHAN, Plaintiff WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 " ` ~~ p err- ~ -ts ~ •~. ~ . [. ~.'~ °v ~ 4 ...~ JAYNE A. MONAHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-5077 CIVIL TERM JAMES K. MONAHAN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 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. Dated: ~ b 1 .~/~,..A~-' JA E ,~ MONAHAN, Plaintiff WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 a ~ ~ :~M '^ ' L,' ~ ... ~ f ~ •~~ i ~ ~ ;~ ~~ ~ ~ JAYNE A. MONAHAN, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-5077 CIVIL TERM JAMES K. MONAHAN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on August 24, 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. Dated: ~~ J S K. MONAHAN, Defendant WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 0 v ' --- t 3 .~. -' .~ ~~. ~~. ~ © 'T7 ~ ~ =1~..~f ~ _ i~ y l JAYNE A. MONAHAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION -LAW . N0.07-5077 CIVIL TERM JAMES K. MONAHAN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 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. /1 _.. Dated: n. ivivi~AnAi~, Leienaant WEIGLE & ASSOCIATES. P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 r. . Y ^' , Y .. ~ . 4~ r~ ~ "'~ ~ ~ ~ ~ ~~ c~- JAYNE A. MONAHAN, Plaintiff v. JAMES K. MONAHAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-5077 IN 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 complaint: September 9, 2007 by Acceptance of Service signed by the Defendant, 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff- December 17, 2007; by Defendant -December 16, 2047. 4. Related claims pending: None 5. Date Plaintiff's Waiver in § 3301(c) Divorce was filed with the Prothonotary: December 18, 2007. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: December 20, 2007. WEIGLE & ASSOCIATES, P.C. r By: ~ - ~~ Date: ~ ~- ~ Zv~n 7 Richard L. Webber, Jr., Esgt~e Attorney for Plaintiff Attorney ID # 49634 126 East King Street Shippensburg, Pa 17257 717-532-7388 WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 726 EAST KING STREET SHIPPENSBURG, PA 17257-7397 C7 C r~ ~, ~ -~ ~u v r-~`i r. ~ r+-~ ~ ~ ~s;~ c-~ ~• ~ -~ -~i ~. n •r . .,,~j "'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JAYNE A. MONAHAN, ~~ -~ r Plaintiff VERSUS JAMES R. MONAHAN ~ Defendant N O. 07-5077 Civil DECREE IN DIVORCE ~--~/.•~s4.~ . AND NOW, ~ ~nn~ , 1T IS ORDERED AND DECREED THAT JAYNE A. MONAHAN PLAINTIFF, AND JAMES R. MONAHAN 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 ~~ (~~~ ~~ ~ ~~ ~~~ ~~~ ~~. /~ ~,, .~ ~~ , :~~~~ .,~ . y