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HomeMy WebLinkAbout03-5217Ryan Colson, Cassandra Colson, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0.3 .. ~',~/7 CIVIL TERM IN DIVORCE NOTICE TO DEFEND 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 important to you, including custody or visitation of your children. When the ground 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 Cumberland County Court House, High and Hanover Streets, Carlisle, PA. 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 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES 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. Ryan Colson, Cassandra Colson, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~3. ~.a/7 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Ryan Colson, who resides at 929 Burnt House Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Cassandra Colson, who resides 529 North Pitt Street, Apt. #2, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiffand Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on May 19, 2000 in Shelby, Cleveland County, North Carolina. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 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. Plaintiff requests the Court to enter a Decree in Divorce. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & BAYLEY Date: Mark F. Bayle-y, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Plaintiff 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. n, P,~ff Ryan Colson, Cassandra Colson, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant CIVIL ACTION - LAW NO. 03-5217 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filin9 of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. _-dR~AN ~"~ LSO N/'- Ryan Colson, Cassandra Colson, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant CIVIL ACTION - LAW NO. 03-5217 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. Date CASSANDRA COLSON Ryan Colson, Cassandra Colson, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-521'7 IN DIVORCE CIVIL TERM WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE', CODF 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 F'a.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date // y RYAN COLS~q'. Ryan Colson, Cassandra Colson, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5217 IN DIVORCE CIVIL TERM WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33011c) OF THE DIVORCE CODF 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 THE FOREGOING 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. Date Ryan Colson, : 1N THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION- LAW Cassandra Colson, : NO. 03-5217 Defendant : IN DIVORCE CIVIL TERM PROOF OF SERVICE Proof of Services for the above caption matter is attached below. · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse es that we can re{urn the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. A~licle Addressed to: 2..Nlicle Number (rran,~W from ~,~ce ~t~0 PS Form 3811. August 2001 A. Signature ' .8. n~?.~,~v~ 3y ~7~l,xt~' h~m?e) C. Date of Del~ r9.~ ~d~ ~ 17 ~ Yes ~ Mail E~p~ Mail R~urn R~ipt for M~ Mail ~.D. Dom~Sc R~torn Receipt Ryan Colson, Cassandra Colson, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-5217 IN DIVORCE CIVIL TERM 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. Grounds for divome: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: October 6, 2003 was served on Defendant by Certified Mail, Return Receipt Requested and signed for October 11, 2003. 3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce Code: by the Plaintiff March 26, 2004; by the Defendant March 26, 2004. 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: April 14, 2004. Date: April 14, 2004 Mark F. Bayley, Esquire 155 South ttanover Street Carlisle, PA 17013 IN THE COURT OF COMMON Rvan Colson OFCUMBERLANDCOUNTY STATE OF PENNA. Plaintiff VERSUS Cassandra Colson Defendant PLEAS NO. 5217 03 DECREE IN DIVORCE AND NOW,~( ~ ~~ 2 ;33 p~ - , IT ~S ORDERED AND DECREED THAT Rvan Colson , PLAINTIFF, AND Cassandra Colson ,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