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Home My WebLink About07-5188MELISSA J. TAYLOR IN THE COURT OF COMMON PLEAS OF Plaintiff ~ CUMBER~,~A-ND COUNTY, PENNSYLVANIA v. NO. d~_ 5tS$ Civil `~P.r•M CARSON R. TAYLOR, JR, Defendant :Civil Action - In Divorce NOTICE TO DEND 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 roamed 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 claim of 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 grounds for the divorce is indignities or irretrieVabie 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 Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY O!F 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 (717) 249-3166 MELISSA J. TAYLOR Plaintiff v. CARSON R. TAYLOR, JR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. c~ 7- si$p~ Civil Action - In Divorce NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, Pennsylvania. This notice is to advise you that in acxordance with Section 3302(d) of the Divorce Code, as amended, you may n~quest that the Court n~quire you and your spouse to attend marriage counseling prior to a Divorce Decree being handed down by the Court. A list of professional marriage counse~rs is available at the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling services are to be home by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twerrty (20) days of the date on which you receive this Notice. Failure to do so will oonstihate a waiver of your right to request counseling. MELISSA J. TAYLOR IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. D ~~S'/8Y CARSON R. TAYLOR, JR, Defendant :Civil Action - In Divorce COMPLAINT COUNT 1-Divorce 23 Pa. C.S.A. §3301(c) 1. Plaintiff Melissa J. Taylor, is an adult individual residing at 107 Woods Drive, Marysville, Peny County, Pennsylvania 17053. 2. Defendant Carson R. Taylor, Jr., is an adult individual residing at 171 West Vine Street, Apartment F, Shiremanstown, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of th~ Commonwealth of Pennsylvania and have resided therein for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 1, 2002, in Harrisburg, Dauphin County, Pennsylvania. 5. Plaintiff avers that the ground upon which this action is based is that the marriage is irretrievably broken. 6. There have been no prior actions of divorce between the parties in this or any other jurisdiction. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The marriage is irretrievably broken. 9. 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. 10. Plaintiff avers that there were two children bom of this marriage, namely Dionte A. Taybr, bom March 15, 1999, and Jayden T. Taylor, bom January 12, 2002. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce. Respectfully submitted, FENSTERMAC~IERAND ASSOCIP-TES, P.C. By: DATED: ~~ Z$~p7 Joh . Fenstemtacher Supre a Court I.D. #29940 15 ast Trindle Road Mec anicsburg, PA 17050 (717) 691-5400 Attorney for Plaintiff 2 VERIFICATION 1, Melissa J. Taylor, have read the foregoing Complaint and hereby certify that the facts set forth are true and con~ect to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. Const. Scat. Ann. §4904 relating to unswom falsification to authorities. Melissa J. T or DATED: ~~; Q~ 3 N o ~ ~ c~~ ~ ~ ~ -~z ~~i ~ ~~` N -G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MELISSA J. TAYLOR Plaintiff v. N0.07 - 5188 CARSON R. TAYLOR, JR, Defendant Civil Action - In Divorce CERTIFICATE OF SERVICE I, Matthew Aaron Smith, Esquire, hereby certify that on September 7, 2007, Defendant Carson R. Taylor, Jr., was served, via United States Certified Mail, with Plaintiff Melissa J. Taylor's Complaint in Divorce, at the following address: Carson R. Taylor, Jr. 171 West Vine Street, Apt F Shiremanstown, Pennsylvania 17011 Respectfully Submitted, FENSTERMACHER AND ASSOCIATES, P.C. By: J hn R. Fensterrnac upreme Court I.D. #29940 Matthew Aaron Smith Supreme Court I.D. #94603 5115 East Trindle Road Mechanicsburg, PA i 7050 (717) 691-5440 Attorneys for Plaintiff DATE: l D - ~ -2du~ '{Y.- 'fit ~ ~ ~. • • ~t~ N ,~anati,r _ i C~o~mp ete rtem~s a 2 and 3 Alpo complete ~~ ~, rterri 4 rf Restricted De,livc ry ~ de fired °'• ~ ~ ~ ^ ~ ~ '~ X' ~ - ^ Print your name and add~r~r,s'on the reverse ~ ^ ~ i-'" ~.. _~, „~ so~that we can return the card to you. ~ g,' eceived tiyd N m, i - < . C ,t , t o~ ~Ine_ryf ^ Attach this card to the back of the mailpi~c,;, ~ or,on-the front if space permits. ' ~-~L~~ ~ ~~ ^. ~ U. I~ d h i ~ ad tr i7 r ~ :!~~j R,ra= ~ ~ , 1 °ArttdeAdd~essad to ~ .._ ~ li YC _nt~ r ~i li ~ry dr ~~~~ ~ ar~son'.R' aylot , ,;JI ;~ ,'. ~ c~ -a -y' i ~: ~, ~Z ~ e°°s°t ~1net Street;~'`Apt~ F - Uj ~ ; ~ ~s lremanst~ , PA~^~Y170'11 ' ~~. ~c~ ._ a9~.z.i r. 3 ~ r 3 :S eTy~ . ''t~ j ~~ rti ied P1id ~~^ E pr ~~ ~G 'i s ~~ ~a rr T,;^ R ~p L~r.~ ~~n~ tum R ~ ip~,~i r1 u,h.u~~i ~ f -~ ' ^ Y I '~ a' ~~ s 1 . R tn~~tr~J D Ali. ~ry7 I i,ri Fa , z ~a~~~~m'bm`~~~~ 7001, 1940 X0+06 8634 9L76 ~( (T~Sf~k,~ 4T1~..~~efL~ ~9 ~a~JCi~ I J ,~ ., ~. :. ~, (~g pjr~p~$11~A~U USt 2001 ~a ~~.Domestic R turn R~~ipt ~ t~ " e.' r' ~`~+ ,... , I ~~s~~'~~Y;x, vY i _. _.. - - r~ .. . . _ .-._ .. . __ ,,.. ,.. ., r -"~~- -. - First Class Mail I UNITEE} STATES-POSTAL. SERVICE - posty9e 8~ Fees Paid I } USPS Permit No. G'~ 0 I ~'•~Sende~: Please print your name, address; and ZIP+4 in this box • - 1 Matthew A. Smith, Esq. I ,~'enstermacher,';and Associates, P.C. l ,~:.., ~ 5115 East Triridle Road ~ Mechanicsburg, PA 17.050 ~ I I 1 l I I ?I .~ ' i~~a~li~„1!l.~~~,f~lf,~~~~11~i;1f<~„i~i~f~~l~~,11,1~1~~~f~~l ~ r .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MELISSA J. TAYLOR Plaintiff v. CARSON R. TAYLOR, JR, Defendant N0.07 - S 188 Civil Action - In Divorce CERTIFICATE OF SERVICE I, Matthew Aaron Smith, Esquire, hereby certify that on September 7, 2007, Defendant Carson R. Taylor, Jr., was served, via United States Certified Mail, with Plaintiff Melissa J. Taylor's Complaint in Divorce, at the following address: Cazson R. Taylor, Jr. 171 West Vine Street, Apt F Shiremanstown, Pennsylvania 17011 Respectfully Submitted, FENSTERMACHER AND ASSOCIATES, P.C. By: J hn R. Fenstermac r upreme Court I.D. #29940 Matthew Aaron Smith Supreme Court I.D. #94603 5115 East Trindle Road Mechanicsburg, PA 17050 (717)691-5400 Attorneys for Plaintiff DATE: (p - ~ _ 2ou ~ ~R ,. f UNirE~i STHTE:> P~:7a~ SEF:VICE , ~~ fr ~~ I;;:~lll~„Il)...,l~l~l~,~~'~,If~~li,,i~i,i,+i,l,ll,i,l„ll~~l a ~ " ~ ; ~w`ry. D _,_, ~J "T ~{ ~+`3'~ V y 'y MELISSA J. TAYLOR Plaintiff v. CARSON R. TAYLOR, JR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5188 Civil Term Civil Action - 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 the complaint: Certified mail on September 7, 2007. Acceptance of Service filed September 12, 2007. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff December 12, 2007; by defendant December 10, 2007 4. Related claims pending: None. 5. Date of plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Filed herewith Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Filed herewith 1 ,~ f John R. Fenstermacher Supreme Court I.D. #29940 5115 East Trindle Road Mechanicsburg, PA 17050 (717) 691-5400 Attorney for Plaintiff December 20, 2007 O ~'j~ ~ ~ ~ `T'J .~~ {,__ ~.~ ~7 ~.. ~'^ w ~ +... ' ^~- "'~ 1 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. <y", MELISSA J. TAYLOR, II PLAINTIFF N o. o~-5is8 VERSUS CARSON R. TAYLOR. JR. DECREE IN CIVIL TERM DIVORCE AND NOW, "~ IT IS ORDERED AND DECREED THAT AND MELISSA J. TAYLOR CARSON R. TAYLOR, JR. ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, 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; .,.,..~ PROTHONOTARY °... .~ ~ ~ g ~G ., .. ~. . ~: