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HomeMy WebLinkAbout07-5339IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Christian Murray : Case No: 67 433 Q vs. : Civil Action - Law Mary Murray : Divorce NOTICE TO DEFEND AND CLAIM RIGHTS (Action in Divorce) &CJ;L(-W" 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 valuable to you, including custody or visitation of your children. When the 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 the York County Court House, 28 East Market Street, York, Pennsylvania 17401. 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. PENNSYLVANIA LAWYER=S REFERRAL SERVICE PENNSYLVANIA BAR ASSOCIATION PO BOX 186 HARRISBURG PENNSYLVANIA 17015 (800) 692-7375 AVISO PARA DEFENDER Y RECLAMAR DERECHOS (Accibn on Divorciol USTED HA SIDO DEMANDADO EN LA CORTE. Si desea de las quejas expuestas en [as p6ginas siguientes, debe tomar acc i6n con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido an su contra por la Corte. Una decision puede tambi6n ser emitida en su contra por cualquier otra queja o compensaclbn reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes pare usted. Cuando la base para el divorclo es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de oonsejeros matrimoniales estfi disponible en la oficina del Prothonotary, en la York County Court of Common Pleas, 28 East Market Street, York, Pennsylvania. SI USTED NO RECLAMA PENSI6N ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTA PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. PENNSYLVANIA LAWYER=S REFERRAL SERVICE PENNSYLVANIA BAR ASSOCIATION PO BOX 186 HARRISBURG PENNSYLVANIA 17015 (800) 692-7375 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Christian Murray : Case No. 611-` 53 3 4 61,ut L vs. Mary Murray : Civil Action - Law Divorce COMPLAINT 1. The Plaintiff is Christian Murray an adult individual, residing at 415 Garden Drive, Mechanicsburg, PA 17055. 2. The Defendant is Mary Murray, an adult individual, whose last known address is 518 Bedford Ct., Mechanicsburg, PA 17055. 3. The Plaintiff and Defendant were married on June 18, 2003 in Carlisle PA in a civil ceremony. 4. There wast(were) 0 child(ren) bom of this marriage. 5. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a continuous period of at least six months prior to the filing of this action. 6. The Plaintiff and Defendant are not in the military armed forces of the United States of America. COUNT I Divorce Pursuant to Section 3301(C) of the Divorce Code and Divorce Pursuant to Section 3301(D) of the Divorce Code 7. Paragraphs one through five of this Complaint are incorporated herein by reference as if set forth in full. 8. Plaintiff avers that the marriage of the parties is Irretrievably Broken. 9. The parties have been living separate and apart, and not as husband and wife, since on or about July 4, 2005. 10. Plaintiff has been advised of the availability of counseling pursuant to the Pennsylvania Divorce Code and that the Defendant may have the right to request that the Court require the parties to participate in counseling. 11. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning a divorce in this or any other court of this Commonwealth. The Plaintiff has no information of any other divorce proceedings pending in a court of this Commonwealth or any other court of the United States. 12. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays your honorable court to grant a divorce a vinculo matrimoni from the Defendant. September 4, 2007 RESPECTFULLY SUBMITTED, Christian Murray, Pro Se w VERIFICATION I verify that the statements made in this 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 unswom falsification to authorities. September 4, 2007 L r-1-- Christian Murray cn r C-n co a C ? ? N a^.1 G C/1 ?I -_j co ra rv --c CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLVANIA n N V. NO. 2007-5339 CIVL TERM MARY MURRAY, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST = r ENTRY OF 3301(d) DIVORCE DECREE To: MARY MURRAY Co You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the §33011(d) affidavit. Therefore, on or after May 1, 2010 the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotaryl of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which youi may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim or economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of thel form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORM41ON 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, PA 17013 (717) 249-31616 or 800-990-9108 FLOWER & LINDSAY 26 West High Street Carlisle, PA Respectfully submitted, SAUDIS, FLOWER & LINDSAY Dated: 3/1 S /Z) I G MarSIbu tas, Esquire Attorney .84919 26 West High Street Carlisle, PA 17013 (711) 243-6222 Counsel for Plaintiff CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLVANIA V. NO. 2007-5339 CIVL TERM MARY MURRAY, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separatled on July 4, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 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. I verify that the statements made in this affidavit are true and correct. I understand SAIDIS, FLOWER & LINDSAY ?t uw 26 West High Street Carlisle, PA that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: 2- 2 51IaA-0 CHRISTIAN MURRAY r_- `PJ ? _ f ?? r17 _CJ Cri M Ca3 r!'l V --C CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLVANIA V. NO. 2007-5339 CIVL TERM MARY MURRAY, CIVIL ACTION - LAW [1 Defendant IN DIVORCE- PETITION OF NOTICE OF PUBLICATION en -D { 11 ` ??1 NOW COMES, Petitioner, Christian Murray, by and through his ataoiney, wryl -1 r (f? ki Matas, Esquire, and petitions this Honorable Court as follows: c; 1. Petitioner is Christian Murray, Plaintiff in the above captioned divorce matter, and an adult individual residing at 415 Garden Drive, Mechanicsburg, Pennsylvania 17055. 2. Respondent is Mary Murray, Defendant in the above captioned divorce matter, and whose address is currently unknown to Petitioner. 3. Petitioner and Respondent are husband and wife, having been married on June 18, 2003, and separated on July 4, 2005. 4. Petitioner filed a Complaint for Divorce on September 7, 2007, a copy of which is attached hereto as Exhibit "A". 5. Petitioner served Respondent with the Divorce Complaint via publication in The Sentinel, the general local newspaper. A copy of the Proof of Publication was published on September 19, 2007, and is attached hereto as Exhibit "B". 6. Respondent did not respond to the publication. 7. Petitioner has not been able to locate the Respondent. 8. Respondent's last known address is 518 Bedford Court, Mechanicsburg, Cumberland County, Pennsylvania. 9. Petitioner attempted service at that address but mail was returned from SA MILS, FLOWER & LINDSAY xnloATJAW 26 West High Street Carlisle, PA that location. 10. Respondent has no current telephone book listing for her address. 11. Respondent has a criminal background, but contact with probation has not yielded an address. A copy of correspondence to York County Probation Department is attached hereto as Exhibit "C." 12. A search of WhitePages.dom -- Online Directory Assistance, Google and Accurint have not produced address information for Respondent. 13. Based upon the foregoing searches, Petitioner does not believe that he can locate Respondent or will be able to serve her at any address. 14. Petitioner has signed and filed the §3301(d) Affidavit and the Notice of Intention to Request Entry of a 3301(d) Divorce Decree. A copy of the signed and filed Affidavit is attached hereto as Exhibits "D" and "E". WHEREFORE, Petitioner prays this Honorable Court to permit service of the §3301(d) Affidavit, Counter-Affidavit and Notice of intent to proceed to Request Entry of a 3301(d) divorce by publication. SAIDIS, FLOWER & LINDSAY quire Es Ma I to?' Supreme No. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Petitioner SAIDIS, FLOWER SL LINDSAY ,?uw 26 West High Street Carlisle, PA CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLVANIA V. NO. 2007-5339 CIVL TERM MARY MURRAY, CIVIL ACTION - LAW Defendant IN 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. §4904, reiatmg to uns"rn faisifications to autiiorities. Christian Murray, Petitioner Date: SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Christian Murray :Case No. D7 - s339 (? to L,ex vs. : Civil Action - Law Mary Murray : Divorce NOTICE TO DEFEND AND CLAIM RIGHTS (Action in Divorce) 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 valuable to you, including custody or visitation of your children. When the 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 the York County Court House, 28 East Market Street, York, Pennsylvania 17401. 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. PENNSYLVANIA LAWYER=S REFERRAL SERVICE PENNSYLVANIA BAR ASSOCIATION PO BOX 186 HARRISBURG PENNSYLVANIA 17015 (800) 692-7375 AVISO PARA DEFENDER Y RECLAMAR DERECHOS (Acci6n en Divorcio) USTED HA SIDO DEMANDADO EN LA CORTE. Si desea de las quejas expuestas en las pAginas siguientes, debe tomar acci6n con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decisi6n puede tambien ser emitida en su contra por cualquier otra queja o compensaci6n reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la York County Court of Common Pleas, 28 East Market Street, York, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, LISTED PUEDE PERDER EL DER 0 A RCLAMAR CUALQUIERA DE ELLOS. - d o USTED DEBE LLEVAR ESTA PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABO AD. ,+ VAY`tf0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENGIA LEG PENNSYLVANIA LAWYER=S REFERRAL SERVICE PENNSYLVANIA BAR ASSOCIATION PO BOX 186 -r HARRISBURG PENNSYLVANIA 17015 cr (800) 692-7375 -? EXHIBIT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Christian Murray vs. Mary Murray Case No. Civil Action - Law Divorce COMPLAINT 1. The Plaintiff is Christian Murray an adult individual, residing at 415 Garden Drive, Mechanicsburg, PA 17055. 2. The Defendant is Mary Murray., an adult individual, whose last known address is 518 Bedford Ct,, Mechanicsburg, PA 17055. 3. The Plaintiff and Defendant were married on June 18, 2003 in Carlisle PA in a civil ceremony. 4. There was/(were) 0 child(ren) born of this marriage. 5. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a continuous period of at least six months prior to the filing of this action. 6. The Plaintiff and Defendant are not in the military armed forces of the United States of America. COUNT I Divorce Pursuant to Section 3301(C) of the Divorce Code and Divorce Pursuant to Section 3301(D) of the Divorce Code 7. Paragraphs one through five of this Complaint are incorporated herein by reference as if set forth in full. 8. Plaintiff avers that the marriage of the parties is Irretrievably Broken. 9. The parties have been living separate and apart, and not as husband and wife, since on or about July 4, 2005. 10. Plaintiff has been advised of the availability of counseling pursuant to the Pennsylvania Divorce Code and that the Defendant may have the right to request that the Court require the parties to participate in counseling. 11. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning a divorce in this or any other court of this Commonwealth. The Plaintiff has no information of any other divorce proceedings pending in a court of this Commonwealth or any other court of the United States. 12. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays your honorable court to grant a divorce a vinculo matrimoni from the Defendant. September 4, 2007 RESPECTFULLY SUBMITTED, By: Christian Murray, Pro Se V00, VERIFICATION I verify that the statements made in this 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. September 4, 2007 <f--AA Murray PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s) September 19, 2007 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this 19th. day of September, 2007. Notary Pu c My commission expires: q1' lop COMMONWEALTH OF PENNSYLVANIA Notarial Seal Chnstina L. Wolle, Nolaly PUWC Carlisle Boro, Cumbedattd County My Commission Eom Sept 1.2008 Member. Pennsylvania Association Of Notaries EXHIBIT 26 West High Street, Carlisle, PA 17013 717-243-6222 Phone 717-243-6486 Fax 1-M117; To: York County Probation From: Marylou Matas, Esquire/Judy Derr, Legal Assistant Fax: (717) 771-9846 Pages: 1 (Including cover) Phone: Date: February 22, 2010 Re: Mary Murray CC: Urgent For Review 0 Please Comment 0 Please Reply O Please Recycle To Whom It May Concern: Could please check your records for a current address on Mary Murray, (dob September 2, 1983). Her Case No. was CP-67-CR-0001232-2004. We are trying to locate her to serve documents pertaining to a divorce matter. Any information would be greatly appreciated. ank you ,A 1, I J dy D ` , Legal Assistant PRIVILEGED AND CONFIDENTIAL information intended only for the use of the addressee(s) named below. If the reader of this message is not the intended recipient(s) or the employee or agent responsible for delivering the message to the intended recipient(s), please note that any dissemination, distribution or copying of this communication is strictly prohibited. Anyone who receives this communication in error should notify us immediately by telephone and return the original message to us at the address above via the U. S. Mail. Please advise if your copy quality is not adequate. E EXHIBIT CHRISTIAN MURRAY, Plaintiff V. MARY MURRAY, Defendant COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (check (i), (ii) or both) (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I FLOWER & LEVDSAY MWISMORW 26 West High Street Carlisle, PA understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND, PENNSYLVANIA NO. 2007-5339 CIVL TERM CIVIL ACTION - LAW IN DIVORCE MARY MURRAY NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLti4Nl c_*? `f7 V. NO. 2007-5339 CIVL TERM - -n MARY MURRAY, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST - D?11 rr? ENTRY OF 3301(d) DIVORCE DECREE cc? Zo To: MARY MURRAY You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the §3301(d) affidavit. Therefore, on or after May 1, 2010 the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim or economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAE A LAWYER, 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, PA 17013 (717) 249-3166 or 800-990-9108 FLOWER & LINDSAY 26 West High Street Carlisle, PA Respectfully submitted, Dated: 3// S IZ.?j I G SAIDIS, FLOWER & LINDSAY _ CIA'A 0"." 71?? Marp6u tas, Esquire Attorney .84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLVANIA V. NO. 2007-5339 CIVL TERM MARY MU.RRAY, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on July 4, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 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. I verify that the statements made in this affidavit are true and correct. I understand rW rV M LINDSAY 26 West High Street Carlisle, PA that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: CHRISTIAN MURRAY n -9 C.; ?.d -< ? I MAR 16 2010 CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLVANIA V. : NO. 2007-5339 CIVL TERM MARY MURRAY, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this 17. day of -rnaseA , 2010, upon consideration of the within Petition, service upon Defendant of the 3301(d) Affidavit, 3301(d) Counter-affidavit and Notice of Intent to Proceed shall be by publication. Plaintiff shall publish the documents in the newspaper of general circulation in Cumberland County, Pennsylvania, The Sentinel, and by publication in the Cumberland County Law Journal, two times each. BY THE COURT, SAMIS,, ENDS" erroRNM•uuw 26 West High Street Carlisle, PA cc: ?Marylou Matas, Esquire Attorney for Petitioner ?y CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNS YLVANIA V NO. 2007-5339 CIVL TERM . MARY MURRAY, CIVIL ACTION - LAW ro?z s,• Defendant IN DIVORCE ''-' `a te <r,' ? ?ilt AFFIDAVIT OF MARYLOU MATAS, ' ATTORNEY FOR CHRISTIAN MURRAY cn •-c MARYLOU MATAS, ESQUIRE, being duly sworn, states as follows: I have caused for a publication in the Cumberland County Law Journal. Please see attached "Exhibit A". Further, the Affiant sayeth not. SA "IS, IINDSM ,?ruw 26 West High Street Carlisle, PA Date: 40 4 (to ( 6 MAR ATAS, quire COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss On this, the I((, day of r2 , 2010, before me, the undersigned officer personally appeared MARYI-09 MATAS, ESQUIRE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. In Witness Whereof, I have hereunto set my hand and official seal. ?-' (SEAL) 'V itle of Officer P0W B W"YCooft Cgf" ARBARA 5.Cobw1ad PA hone ?, 2011 Commiss<ioc E hl" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 2 and April 9, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true, is arie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this 9 day of April, 2010 J Notary NOTARIAL SEAL DEBORAH A COL LINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY MN Commission Expires Apr 28, 2010 CUMBERLAND LAW JOURNAL DIVORCE PETITION CHRISTIAN MURRAY v. MARY MURRAY In the Court of Common Pleas, County of Cumberland, Pennsylvania Civil Action-Law NO. 2007-5339 CIVIL TERM CHRISTIAN MURRAY, Plaintiff V. MARY MURRAY, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 17th day of March, 2010, upon consideration of the within Petition, service upon Defendant of the 3301(d) Affidavit, 3301(d) Counter-affidavit and No- tice of Intent to Proceed shall be by publication. Plaintiff shall publish the documents in the newspaper of general circulation in Cumberland County, Pennsylvania, The Sentinel, and by publication in the Cumber- land County Law Journal, two times each. BY THE COURT, /s/Kevin A. Hess, J. COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) _ I do not oppose the entry of a divorce decree. (b) _ I oppose the entry of a divorce decree because (check (i), (ii) or both) (i) _ The parties to this action have not lived separate and apart for a period of at least two years. (ii) _ The marriage is not irre- trievably broken. 2. Check either (a) or (b): (a) _ I do not wish to make any claims for economic relief. I under- stand that I may lose rights concern- ing alimony, division of property, law- yer's fees or expenses if I do not claim them before a divorce is granted. (b) _ I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. 1 understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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: MARY MURRAY NOTICE: If you do not wish to op- pose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE To: MARY MURRAY You have been sued in an action for divorce. You have failed to an- swer the complaint or file a counter- affidavit to the §3301(d) affidavit. Therefore, on or after May 1, 2010 the other party can request the court to enter a final decree in divorce. If you do not file with the Protho- notary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, CUMBERLAND LAW JOURNAL the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim or economic relief, you must do so by the above date or the court may grant the di- vorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 LAW- YER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OF- FER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on July 4, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the pen- alties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Dated: 2/25/2010 /s/ Christian Murray CHRISTIAN MURRAY MARYLOU MATAS, ESQUIRE Attorney Id. 84919 SAIDIS, FLOWER & LINDSAY Counsel for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 Apr. 2, 9 I have caused a Notice of filing of the divorce documents in The Sentinel, a CHRISTIAN MURRAY, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLVA NIA V. NO. 2007-5339 CIVL TERM MARY MURRAY, CIVIL ACTION - LAW Defendant IN DIVORCE ° a s ? ^' AFFIDAVIT OF MARYLOU MATAS, ;-,- ? to ATTORNEY FOR CHRISTIAN MURRAY tv ?+ MARYLOU MATAS, ESQUIRE, being duly sworn, states as follows: newspaper of general circulation in Cumberland County, Pennsylvania. Please see attached "Exhibit B". Further, the Affiant sayeth not. SAMIS, LENDS" 26 West High Street Carlisle, PA Date: ¢12-zl ZO / 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the Aj ) day of Ppr,"Z , 2010, before me, the undersigned officer personally appeared MARYLOU MATAS, ESQUIRE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. AL411L" MA MATAS, Esquire ss In Witness Whereof, I have hereunto set my hand and official seal. r (1,16 d &,-,j-(SEAL) itle of Officer A BARBARA E. STEE4 NO ICY Public Carlisle BOro, Cumbalaud County, PA My Commission Ex ices June 7, 2011 PROOF OF PUBLICATION State oFPennsylvania, County of Cumberland runes Kleinklaus llirector of Sales and Marketing, of The Sentinel, of the County and Stale aforesaid, being dul}~ sworn, deposes and sa}'s that THE SENTINEL, a newspaper of general circulation uT the P~orough of Carlisle, CoLmt}~ and State aforesaid, was established December 13111, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly tl~Je same as was printed and published in the regular editions and issues of "THE SENTINEL on the ft)llowing day(s): 1v9arch 30 and Anril b, 2010 COPT OF NOTICE OF PUFLICATION i .~: `t ~~. IN tHE'C6lllil OI' COIJIMnN PLEAT U INIGTIAh1M UIIFIAY OUIJTI'OF(.I11A6PRLAr D FCNNCYLV 4NIA J_~~a 1n 1111 Nc ~ooi-f.31E ~crnLT~Rtt~ ";-.I s' I i -rinUVrnuHHr ~IVU_A null IoW - ulDivoir, DarenH~,m I ' courrl~grgFFlDAai NnEr~~gasol~d)otT~IEDIVOacECgnE 1 (r ti i 1 J i I~ C,ho koltlie(l )ol (l ).: ` ~-'. 121 =1't{~ nQi oPP s WIN of d14Q7o doe e (bl i oPl ~ I en;i olfi d orr 1 d r h: ) (chor.~ (~) (I) °f, i, I e Ge Ih) ' ff ~ ' (IV. _ l h~ pa tilt s 1 th vctbl I ~e n I by t cP rato~n Id ap r(tol _ pernclc( (o st1 y~~V ( v 1 TI a~ma^ nq I iol Irrel vntl I r9~ n };; :.r - o Oh ck elthe l) Qi (I~)~ lal _".I do not kllhlon ak ny cla )e (~r ecgno it tai C~JI d r I n~ Ina1 I n~y los Ighl conoa Tog al moo) d vl Ion l~Vf P r6 , . ~~ ,, y r~fees~oi oxnonsesilld n (claim lhefnh I re Ivojcn c I nt d 11,1 Iwlsh'lo plalm'ecopumtp tell f bleb mayu cludo aim gyldv e~. I f roperly"lavfyer s tae or axpen e ~ o oit nn)Porragi tlgft) dd i b abov I t u 1 Iso II ell P 4 ,, I I r ioersin In claims wnlSlhe Proth ~ot~a y I i ~rlu y End se v Ih ~I d~d~eppl~~~~ - I of e p rly IIIIaJ to do so heforeihed Ie of lorih be ~~el0d wtlhou4S,on I I A q lest DI orce Deoree the tliVnrca d~c [n'JY Ill le - ¢ u moil I m .,anal t Il n pn hie ~nareahof to hie an~._e ohoml lams ' I vet / IhaI=II Intwmenls mad 111 of l r '1(Ildavll a e Idle ar)d c rr ci_" I node rstat d 11 a1121se I 1 nls~ r Irj t ~i Y~, ~nll P- ~, o17B 1'a~ -64Qoa.r I I gi- inew tflf _, - D~Ited. .. MAR MIJRHA . ~ f-: ~ ~. ap:. wry IJ OTICE~II Yo id 'qtt Isl t ppo efh entry, i dlVo(o~ ac(e~ .i y u do n t wltf] to m k ny clalip ( r ero Flo lnlc relle auA 4 n!~' fde rhlsco ntel~~flid It ';: ~ ~ J]'i' TT I "~;°~ ;.r ~~. d~ I ,~ rtJOTICE OFINTEtJTION TO fj EDUESTE~J~Y QF ,73Q1(rl)DIVORGE~-E _ EE ~', ~'•il 4' r ,; r if ~ ~'_ ~ r , I MARL MURRA} {~ ~5 Yof l a e t e sue I I i o I I I ~ dl o~aQ~oul~ ave eded (o a~sy{afjtpa sonlplauSt oFllle GOU let+efltl vM1 to lha§aOQ~{~p Id~~~~s[afo~~6bo or ~~ r G~`aRi ~ [o fa nelde~~:' ' all rMaY 1 2U1101~in olllrrgaflyo 9 fl ~.,~~ r In dvorce ~~zzrr by i 1 not hie Ullhthe Proll ta~~~co~'1I'wd ~Iy eG lio~ye`~elejihe'~ ~, 4 n9lure noter(zed~.or veal d I o coyp 0~ ~ h ourt can enle(aJinal decreol divard~se ~`so let d(4),d,,a~l~tt hl~ ., III k lh the Prothonotary of Iha corlll blrSt~v~e~6~ Y~ l~~O~ o ;). Unless b have (ready bled with lh,~~ o td~ ijr! I$~+ld You-mustdoso bY.ghenlhtd ask,f4~~9oml~;ellelgl~h~l~~yP~~,~.+~fmv~~li Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are tru~%.- ~~ /~ ~~ Sworn to and subscribed before me this ~~~) i~ -I m ia~ hl '~Q ,P~(~ ~ ;~D U ~ i ~~ r ~'I',)'(~,~r~~lL ~,~''.,E~~~~~~~:~~1'~.OJU1~ Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENOORN Notety Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission E>tpiies Jan 27. 201A FC7RT1 =luroRMnnurl-yin ~~~". .sLwlc;E~ T~ LeuTlDl ceer~soN nT`~, HroucEr rrLOFl a;. ' I ', ~`F,u Whorl ndC;ot OIV oar As ocluhod ~ ~ _ South Bedloid Slroet t, adlsl F A von a qn) ~a~aisr rrsoo99n loo ~ ~ SAIOIS FLOWEI & LINDSAY • lJiaryl I t`A iles, L~qu rc n..t,1I ~ - ~`'~'1 ~ z~IwcaiHlgT;'e~reel ' ,~I i '~ rl ~ o, I I Nn) ol~ .~ 1 ~ITIr) 43sz~ 6o el I r ~'la nl (I ualea.fa olt t ^oio ,.e, r+i a _. I .:AFFIDAVIT U1NDFR SECTION O"i01(c110F THE DIVORC CODE~~ 7: TI-~e parues )o~lh glion separated on ,lclyt 00 t~hl ve. I _uad to Ilvr separale~and apart (or.a period of al lee,l iwc Y~..r- -. 2. The mama9eis grefdevahlyhroken ~ ~ - - I I c.l-; ,3.+l understandltial l'maylbse-.n9Rls cogqdemipg olio I!1'~ ,r ~ properly lawyers (ees gf ezpensers'lll donot lal II m[ I divorce is granted -- -_ ° l I verily (hat the slz~lemer IS oo ~~ Ihu alhdav I I I J n e I I `i - =Understand that talse stalemenls herein are I I tJe.l t the I ~ hl~s of ~{ . 19 P O S ¢4904 relahno to lmswom talsTlc. 1 t ih~ r I e Daled'Feo u.~ry ~~^010 CHRISTIAN MIIRRAY _. ~E~CH'IBIT htrj _ „3 " rter "'~ V '~ V >"' } 'Y i = CHRISTIAN MURRAY, Plaintiff v MARY MURRAY, Defendant To the Prothonotary: IN THE COURT OF COMMON P~A~~', CUMBERLAND COUNTY, PENN~YL~TANIA' CIVIL ACTION -LAIN NO. 2007-5339 IN DIVORCE PRAECIPE TO TRANSMIT RECORD Kindly transmit the record, together with the following iinformation, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (d) of the Divorce Code. 2. Date and manner of service of the Complaint: Plaintiff served the original Complaint by publication in The Sentinel on September 19, 2007. 3. Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: February 25, 2010 Date of filing and service of the Plaintiff's Affidavit upon the Respondent: filed on March 15, 2010. Served by publication in the Cumberland County law Journal April 2, 2010 and April 9, 2010 and in Tlhe Sentinel March 30, 2010 and April 6, 2010. 4. Related claims pending: None. SAIDIS, FIAWER ~ LINDS~IY A1Ti)RNEYS•AT•L\W' 26 West High Scrcc~ Carlisle, PA 5. Date and manner of service of the notice of intention to file praecipe a copy of which is attached: Served by publication in the Cumberland County law Journal April 2, 2010 and April 9, 2010 and in Tlhe Sentinel March 30, 2010 and April 6, 2010. SAIDIS SULLIVAN LAW - , Ma tas, Esqu e_ ` Suprem urt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for the Plaintiff CHRISTIAN. MURRAY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. MARY MURRAY NO. 2007-5339 DIVORCE DECREE AND NOW, ZL ?ot c , it is ordered and decreed that CHRISTIAN MURRAY ,plaintiff, and MARY MURRAY ,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 By the Court, . /~~ P J. rothonotary