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Home My WebLink About03-5340PAULA R. BEAL, Plaintiff THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 ~- o~.~ t/t~ UIVIL TERM CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND 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 warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may 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 ofman'iage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFOKE A DIVORCE 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, Pennsylvania 17013 (717) 249-3166 PAULA R. BEAL, Plaintiff v. § NO. rD3 -,S',j' t/ C) CIVIL TERM § § § THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Paula R. Beal, by her attorney, Laguna Reyes Maloney, LLP, and represents as follows: 1. Plaintiff, Paula R. Beal, is an adult individual who currently resides at 6203 Haymarket Way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant, Thomas E. Beal, is an adult individual who currently resides at 6203 Haymarket Way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and has been so for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married in the Commonwealth on October 6th, 2001 in Cumberland County. ~5. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since September 16t~, 2003 and continue to live separate and apart as of the date of filing this Complaint. Plaintiff desires a divome based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and of the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff waives the right to request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter a Decree of Divorce. Respectfully submitted, Roger R~Laguna, J~r~Esq~'ire0 Supreme Court I.D. 1~o.: 75900 Attorney for Plaintiff LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 VERIFICATION I verify that the statements made in this divorce complaint are true and correct. I understand that false statements made herein may subject me to penalties of Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ~aula R. Beal, Plaintiff LAGUNA REYES MALONEY, LLP A"I-YORNEY FOR PLAINTIFF PAULA R. BEAL, Plaintiff THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 5340 CIVIL TERM CIVIL ACTION - IN DIVORCE ACCEPTANCE OF SERVICE I accepted service of the Divorce Complaint under Sections 3301 (c) or 3301 (d) of the Divorce Code, filed in the above-captioned matter, via regular first-class U.S. mail on October 13t~, 2003. Mr. Thomas E. Beal 6203 Haymarket Way Mechanicsburg, PA 17055 EXHIBIT A PAULA R. BEAL, Plaintiff Vo THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 5340 CIVIL TERM CIVIL ACTION - IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER § 3301(c) OF THE DIVORCE CODE A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 8t~, 2003. The marriage of Plaintiff and Defendant is irretriew]bly broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. I consent to the entry of a final decree of divorce at~er service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit m'e 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 Paula R. Beal EXHIBIT B t o cq PAULA R. BEAL, Plaintiff THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 5340 CIVIL TERM CIVIL ACTION - IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER {}3301(c) AND 3301 (d) OF TIlE I)IVORCE CODE I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I understand that I will not be divorced until a divor,ze decree is entered by the Court and that a copy of the decree will be sent to me inm~ediately after it is filed with the Prothonotary. I verify that the statements made in this waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date Paula R. Beal PAULA R. BEAL, Plaintiff THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 534t} CIVIL TERM CIVIL ACTION - IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER § 3301(c) OF THE DIVORCE CODE o A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 8th, 2003. The marriage of Plaintiff and Defendant is irretriewibly broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. I consent to the entry ora 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. Dat~ Thomas E. Beal &o-4 PAULA R. BEAL, Plaintiff THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 534t) CIVIL TERM CIVIL ACTION - IN DIVORCE DEFENDANT'S 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. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I understand that I will not be divorced until a divor.ce 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 waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date Thomas E. Beal PAULA R. BEAL, Plaintiff THOMAS E. BEAL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 5340 CIVIL TERM CIVIL ACTION - IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: Ground for Divorce: irretrievable breakdown trader Sections 3301(c) or 3301(d). Date and Manner of Service of the Complaint.. October 13t~, 2003, via regular fn'st-class U.S. mail (see Acceptance of ServJ[ce attached hereto as Exhibit A). o Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: by Plaintiff on February 19t~, 2004; by Defendant on February 19% 2004 (Exhibit B). 4. Related Claims Pending: no other marital claims pending. o Notice of Intention to Request Entry of Divorce Decree.. waived by Plaintiff on February 19t~, 2004 and by Defendant on February 19t~, 2004 (Exhibit B). Attorney for Plaintiff/ Supreme Court I.D. No. 78075 LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 IN THE COURT OF COMMON PLEAS Paula R. Beal, Plaintiff VERSUS Thomas E. Beal, Defendant OF CUMBERLAND COUNTY STATE OF I°EN NA. N o. __?003 DECREE IN DIVORCE AND NOW, 2";,~,"x.,~..~ ~ DECREED ThAT Paula R. Beal AND Thomas E. Beal ~},...~O~J</, IT IS ORDERED AND ., PLAINTIFF, , 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; Co : _ ATTEST: PROTHONOTARY