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