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HomeMy WebLinkAbout07-6599r V& JEFFREY LEWIS WALDEN, PLAINTIFF VS. REBECCA MARIE WALDEN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.07- 459? CIVIL TERM CIVIL ACTION - AW ACTION FOR DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT YOU HAVE BEEN SUED IN COURT. If you wish to defend against toe claims set forth in the following pages, you must take prompt action. You are warned than if you fail to do so, the case may proceed without you and a decree of divorce or annulment m 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 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 YOU LAWYER AT ONC . IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TEL HONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GE LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 1-717-249-3166 1 JEFFREY LEWIS WALDEN, PLAINTIFF VS. REBECCA MARIE WALDEN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.67 • 1.S9? CIVIL TERM CIVIL ACTION - LAW ACTION FOR DIVORCE Plaintiff, JEFFREY LEWIS WALDEN, respectfully requests this Honorable Court enter a decree of divorce between the above-named parties, granting the relief requested herein against the Defendant, and Plaintiff states for reasons as follows: 1. Plaintiff is JEFFREY LEWIS WALDEN, who currently resides at 912 Bonny Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055, for over 5 years 2. Defendant is REBECCA MARIE WALDEN, who currently resides at 912 Bonny Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055, 3. PLAINTIFF AND DEFENDANT have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on April 24, 1993. 5. There have been no prior actions of divorce or for annulment between the parties except 03-1678. 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. Plaintiff has chosen not engage in, or to request any counseling. 8. Neither Plaintiff nor Defendant was a member of the Unito States Military Services. 9. Plaintiff and Defendant have no children from their marriage. 10. 11. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to the divorce. Plaintif believes Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of fileing of this Complaint, Plaintiff, JE?FREY LEWIS WALDEN requests the court to enter a Decree of Divorce pursuant to Section 3301(c ) of the Divorce Code. I verify that the statements made in this Complaint are true and co t. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S ' § 4904, relating to unworn falsification to authorities. 912 Bonny Lane Mechanicsburg, PA 17055 Plaintiffs phone number: (717) 697-5848 Date: 3 / -';Z-00 Plaintiff requests the court to enter a decree of divorce. Plaintiffs mailing address: 0 a W - -Z7 x -yetTrey LV-W;S ?JQ,td Plaintiff, vs. CeQ rAart e l.tlQll A Defendant. IN THE COURT OF COMMON PLEAS 'OUNTY, PENNSYLVANIA No. 61- 4'Y.49 CIVIL ACTION - LAW IN DIVORCE 76&feqd4ht-s AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 3301 (C, OF THE DNORCE CODE ii1. A Complaint in Divorce under 3301 (c) of the Divorce Code was filed on -1YDv'evn-&? 1, aOO 7 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce without notice. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses K I do not claim them before a divorce is granted. 5. 1 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § QQU4 relating to unsworn falsification to authorities. Dated: -?lcnyd aqD? Aeflo 27? a?,*???G? a d The Plaintiff: Jeffrey L. Walden and Defendant: Rebecca M. Walden does here-by mutually consent to divorce and in accordance the following conditions. 1. The Plaintiff Jeffrey L. Walden has willfully consented to remanding the residence at 912 Bonny Lane, Mechanicsburg, PA to the Defendant Rebecca M. Walden. 2. The Plaintiff Jeffrey L. Walden relinquishes all rights to the Defendant Rebecca M. Walden's 401 K, retirement, savings bonds, and any other money earned by the Defendant. 3. The Defendant Rebecca M. Walden gives up all rights to any savings, or money earned by the Plaintiff Jeffrey L. Walden. 4. The Defendant Rebecca M. Walden gives up all rights to the Plaintiff s business "Walden Associates". 5. The Plaintiff Jeffrey L. Walden will retain ownership of his Subaru vehicle. 6. The Defendant Rebecca M. Walden will retain ownership of her Acura MDX and Saturn SL2. 7. The Plaintiff Jeffrey L. Walden agrees to move out of the residence at 912 Bonny Lane, Mechanicsburg, PA, at the termination of the divorce. 8. The Plaintiff Jeffrey L. Walden willfully agrees to leave the household items acquired during the marriage to the Defendant Rebecca M. Walden except for the agreed upon items the Plaintiff Jeffrey L. Walden requested to keep in his possession. The mantel clock, the antique table that his mother awarded to him, his computers, and other personal items. 9. The Defendant Rebecca M. Walden will retain ownership of her Dell laptop and her digital camera 10. The Plaintiff Jeffrey L. Walden will pay the tax debt for all back taxes filed jointly up through 2006. 11. The Plaintiff Jeffrey L. Walden agrees to pay for any past and current credit card debt or any other debt incurred by the Plaintiff which he is currently responsible for paying. Jeffrey L. Walden should have the Defendant Rebecca M. Walden's name removed from said debts. 12. The Defendant Rebecca M. Walden agrees to pay for any remaining credit card debt or debts that she is currently responsible for paying. The Plaintiff s name has been removed from any debt owed by the Defendant. 13. The current vehicle and home owner's insurance through Encompass insurance will change to indicate that the Plaintiff Jeffrey L. Walden and the Defendant Rebecca M. Walden are divorcing and will require their own independent insurance. 14. The Defendant Rebecca M. Walden relinquishes all rights to any retirement earned by the Plaintiff Jeffrey L. Walden. 15. The Plaintiff Jeffrey L. Walden and the Defendant Rebecca M. Walden are entering this divorce as friends and agree that no legal action of any kind will be filed against the other partner. Both agree to work together during the finalization of the divorce. Both the Plaintiff Jeffrey L. Walden and the Defendant Rebecca M. Walden agree to the stipulations listed in this document. Signatures below signed in the presence of a notary witnesses this agreement. Commonwealth of Pennsylvania County of Cumberland On this the .?10 day of , before me, the undersigned Notary Public, personal) appeared Rebecca M. Walden and Jeffrey L. Walden, known to me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My Plaintiff's signature Defendant's signatw JAMES 1E GREEN, Natary Pub MC r?P NiH Boro, Cwnberlend Cagy Commission Expires June 6. 2009 r-? ? m ??, ?'?"' ?- "•. ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey Lewis Walden Plaintiff VS. No. 07-6599 of 2007 Rebecca Marie Walden Defendant AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on October 31, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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, I / "_) Date: / / 3 0 Printed Name: Jeffrey Lewis Walden 726 Renner Ave. Melbourne, FL 32935 MM W&T OF PENNS NOTARIAL SEAL l j SUSAN J: 'MILLER, Notary / Camp Hill Bono, Cunnberlaod %Ali f`nmmiegwn Expires to11 N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey Lewis Walden Plaintiff VS. No. 07-6599 of 2007 Rebecca Marie Walden Defendant AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on October 31, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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 unworn falsification to authorities. Date: Printed Name: Rebecca Marie Walden Sworn and subs i:'J : -,. before me this 152 day of , 20 ?-VM1WU1rwEALTH OF pENNSYLWtN1A lug% JAMES E. GREEN ! Nc Camp Hill Boro, end My Commission Ifas Aft 6. Colft C`) rv sacs tx ZI cr?a? w trs css IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey Lewis Walden Plaintiff VS. Rebecca Marie Walden Defendant No. 07-6599 of 2007 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. 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 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 unworn falsification to authorities. Date: f?l LE) -2-61-22- (Defendant) C C7 -n c e •*r•x F-m ?? W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey Lewis Walden Plaintiff VS. No. 07-6599 of 2007 Rebecca Marie Walden Defendant 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. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4944 relating to unworn falsification to authorities. Date- Y a R C= 0 ril ._,; !?" 5 V? e G- 1 S VOL Idle-14 f VS. [? f / jf + l f /l e l0 ?? G? c%c 14a r, i e " (O' e--0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION NO. 07-- (o5-99 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: CIVIL TERM 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) (Strike out inapplicable section). 2. Date and manner of service of the complaint: 00 fin(D -c 5/i oZ.© d 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff . 4 U CA (C/?Dl; by defendant ?? vi uQ r 1T o20? (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 'CL zoo Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: y,"9AAtttoorrneeyy for Plaintiff / D endant ?.. ] / 17, JEFFREY LEWIS WALDEN, PLAINTIFF VS. REBECCA MARIE WALDEN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-6599 CIVIL TERM CIVIL ACTION - LAW FOR DIVORCE PLAINTIFF AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER - 3301(c) OF THE DIVORCE CODE 1. A complaint in Divorce under 3301(c) of the Divorce Code was filed on October 31, 2007 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filling and service of Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. 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. 5. 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. J 4904 relating to unworn falsification to authorities. Dated:1 P-.') d Q Ci ? ^D l VS. C QICL rl -e 16? o e- CJ' Q-t a pG IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIV L DIVISION NO. C) 7 - to S? CML TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with fire following information to the court for entry of a divorce decree: 1. Ground for divorce: Trrt t, evable breakdown wader 3301(c) . (Strike out inapplicable section) 2. Date and manner of service of the complaint: P, 41f 3. Complete #ber paragraph (s) a?"-- a. Daft of execution of the affidavit of consent required by 3301 (c) of the Divorce code: by plaintiffby defendant J ?l b. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code. (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: 'YI o e 5. Complete eit zfiz `or (b) a. Date manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: b. Date of plaindirs Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: ?jg?? b . /--3 DQ D Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: go o /' s 2. for aintiff/Defen t c? rTir :1 JEFFREY LEWIS WALDEN, PLAINTIFF vs. REBECCA MARIE WALDEN DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-6599 CIVIL TERM CIVIL ACTION - LAW FOR DIVORCE Acceptance of Service I accept service of the Complaint in Divorce under Section 3301(c). I was handed a copy on October 31, 2007. Date: 3 / 71o S-/ -T' . to. Rebecca Marie Walden U M. DEDERER, Notary Public rE ill ®oro, Cumberland County Commission Expires Aug. 20, 2009 912 Bonny Lane Mechanicsburg, PA 17055 C:? ? ? ,. :t " i $ . t J .. ?rY? ?` ? - y? ??y { IN THE COURT OF COMMON PLEAS s CUMBERLAND COUNTY, PENNSYLVANIA vs. ?/ / CIVIL DIVISION ee- /V L ?''?• e Woe ?de ?I : NO. 0 CNII. 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. 2. 3. (around for divorce: Irretrievable breakdown under 3301 (c) (Sbilm out inapplicable section) . Date and meaner of service of the complgint: LZ b. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: o yr 5. Complete eitheror (b) a. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: b. Date of plaintiffs Waiver of Notice in 330 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary. <n d e for laintifflDef dent CP t 1ae a. Date of execution of the affidavit of consent required by 3301(c) of the Divorce code: by plaintiff 3 ; by defendant yi ?? n - ! i b -p r-n 5c 7 1 P< I" IN THE COURT OF COM MO OF CUMBERLAND COUNTY VERSUS RIO, to 1/7 o/c," DECREE IN DIVORCE PEN NIA. _6 PLEAS '2DD AND NOW, /?? dc-CA ?Q? ,ZoaB ?l1? 1Q DECREED THAT I e PIP S/ LLeA- f S IA JO AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. I DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWI?INAL G CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A ORDER HAS NOT YET BEEN ENTERED; tj E BY THE OURT: "?' /- . 4, /" k ATTE _ w J IT IS ORDERED AND , PLAINTIFF, PROTHONOTARY .? S . - ?" ?,, ? a , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Jeffrey Lewis Walden Plaintiff VS. Rebecca Marie Walden Defendant a FILE NO. 07-6599 Ca 203w IN DIVORCE ?D c? NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 19th _ day of March 2008 hereby elects to resume the prior surname of Rebecca Mane Malone and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: t. oaZ)// Signature ZA=r? Ao? Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND On the day of Ql?DI, , 20-?-L_, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. ?C,? Cd. IDy? U Notary'Public IP I Ifii ?i1smilC) -o rn ?7C7 Z -•n E) o -n ?M 10 11.00 PQ AEFT ?/i5!•f R*a &-V07