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Home My WebLink About03-5412 BARBARANN GREEN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v. CIVIL ACTION - 4A W NO, 03- 5''1 I;;" ~ I..u- ARTHUR EDWARD GREEN, COMPLAINT IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS TO: Mr, Arthur E. Green 10579 Mapleton Avenue Shippensburg, PA 17257 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. 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 the Franklin County Courthouse, 157 Lincoln Way East, Chambersburg, Pennsylvania, 1720 I. 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 TIllS 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 (717) 249-3166 or (800) 990-9108 289303-1 BARBARANN GREEN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v, CIVIL ACTION - LAW NO. 03. Slll.J. Ct;,J -,- Lo- ARTHUR EDWARD GREEN, COMPLAINT IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff, Barbarann Green, is an adult individual currently residing at 220 Senior Drive, Shippensburg, Cumberland County, Pennsylvania, 2. Defendant, Arthur E, Green, is an adult individual currently residing at 10579 Mapleton Avenue, Shippensburg, Cumberland County, Pennsylvania, 3, Plaintiff and Defendant have been a bona fide residents of the Commonwealth for at least six months immediately prior to the filing of this Complaint, 4, Plaintiff and Defendant were married on February 12,2000, in Cumberland County, Pennsylvania, 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6, Plaintiff's Social Security number is 407-82-2258, and Defendant's Social Security number is unknown, 7. There have been no prior actions of divorce or for annulment between the parties. 8, 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. 289303-1 . 9. There were no children born of this marriage. COUNT I - DIVORCE 10. The averments of paragraph I through 9 hereof are incorporated herein by reference. 11. The marriage is irretrievably broken. 12. The parties have been living separate and apart since August 29, 2002. 13. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render Plaintiffs condition intolerable and life burdensome. 14. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a decree in divorce and enter such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By 6-______ Andrew C. Spears, Esquire Attorney LD. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: 101 q (OIJy 289303-1 VERIFICATION I, Barbarann Green, hereby certifY that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities. flNu---- Barbarann Green Date: J..'7 S0t ,U~ 289303-1 ~ ) r ~ J1 ."" ~ '" ~ ~ "'" .. , '" -'" . "" -0 -J:> i :.~ C' 0 ., d BARBARANN GREEN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v. CIVIL ACTION - LAW NO. 03- 51112- COMPLAINT IN DIVORCE ARTHUR EDWARD GREEN, Defendant AFFIDAVIT OF SERVICE I, Andrew C. Spears, counsel for Plaintiff, Barbarann Green, hereby certify that a true and correct copy ofthe Complaint in Divorce was served upon the following, by certified mail, return receipt requested, on October 27,2003. Attached hereto, marked as Exhibit A and incorporated herein by reference, is a copy of the Return Receipt indicating service upon: Arthur E. Green 10579 Mapleton Avenue Shippensburg, P A 17257 METZGER, WICKERSHAM, KNAUSS & ERB By: 0'- Andrew C. Spears, Esquire Attorney LD. No. 87737 3211 North Front Street P.O. Box 5300 Harrisburg, P A 1711 0-0300 (717) 238-8187 Attorneys for Plaintiff Date: Ir/t% '!> I t 292304-1 Q c:> ~ ~ w -""- :z: -~ -00'-' 0 ~1:D ~[; ..;;:: ,. r .~} ;T1 ~t :29 h 1'-' -<::,. '::1 C) c::r:: .0 ".,.-"rl ~... :3: J~) :!J zt. ...0 ;;;2: ~ c!;jm -I Z r:- ~ 0" -< ,J:"" BARBARANN GREEN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v. CIVIL ACTION - LAW NO. 03-5412 Civil Term ARTHUR EDWARD GREEN, COMPLAINT IN DIVORCE Defendant AFFIDAVIT OF CONSEN1: 1. A Complaint in Divorce under 99 330l(c) and (d) of the Divorce Code was filed on October 14, 2003 and served upon Defendant on October 27, 2003. 2. The marriage of Plaintiff and Defendant is irretri(:vably broken, and ninety (90) 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 any false statements herein are made subject to the penalties of 18 Pa.C.S., 9 4904, relating to unsworn falsification to authorities. Dated: d. - ~ ~ - oy &,~ 6~ t?~ Arthur Edward Green 290114-1 r-> Cl C.::! c:-::l --n ...- .-< -., ~:p~ p. 0::> -On"1 N -:-'~)C -J 9:2:) -~- -" .-".., /4'2.J -':- c-co:.c) :....-' r':"7rn c~ t;? ~ -.- '"'~ .~ :2. - - BARBARANN GREEN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v. CIVIL ACTION - LAW 1'10.03-5412 Civil Term ARTHUR EDWARD GREEN, COMPLAINT IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER & 3301(c) 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 in 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 aftf:r it is filed with the Prothonotary. 1 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. S 4904 relating to unswom falsification to authorities. Dated: ,.;(- ~ (p - 0'/ Ik- &~ b~/ Arthur Edward Green 290114-1 , r-, ~:;: .' :;;." ~:: --< "-> C:::;J 5;2 o -n .-j :c-r rnrd -I,m ::-i.'')C1 :;.~~) -,"-,""; :;o"--n >-?O ~~rn :.c:J .-< "'T1 rq co !'.) --.J y 1'..' (. ;.FII.ES'J)ATAI"lLF,G"'''-'I~r,Clmelll\) iJ)j,411'ilJJ1 C,caleU 9...~Qi(l4 I),I)('I'M RcviscJ .,"']5i()~ H41AM Jennifer L Spcars, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD. 87445 ] 0 East High Street Carlisle, P A 17013 (717) 243-3341 Attomeys for Plaintiff BARBARANN GREEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. NO. 03-5412 CIVIL ACTION - LAW ARTHUR EDWARD GREEN, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of Metzger Wickersham Knauss & Erb on behalf of Plaintiff in the above matter. METZGER WICKERSHAM KNAUSS & ERB By: (,.1) \:(J) f'-------/ Andre~ C~pears, Esquire LD.No. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110 (717) 238-8187 Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Plaintiff in the above matter. MARTSON DEARDORFF WILLIAMS & OTTO (Creo Date: /" l\ \ \ \u\ By Ie fer'. Spears, Esquire 1.D. No. 87445 Ten East High Street Carlisle, P A 17013 (717) 243--3341 Attorneys for Plaintiff . CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Paul Bradford Orr, Esquire ORR LAW OFFICES 50 East High Street Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO ~~jJtl~~/ . Tricia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: ;7 MdL It; 2aJ0' l..,' ------------------- BARBARANN GREEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. ARTHUR EDWARD GREEN, : NO. 03-5412 Defendant : IN DIVORCE CIVIL ACTION-LAW 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. Ground for divorce: irretrievable breakdown under Section 3301 (c) & (d) of the Divorce Code. 2. Date and manner of service of the complaint: October 14, 2003, by U.S. Mail, postage prepaid, certified, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301 (c) & (d) of the Divorce Code: by the Plaintiff on October 17,2005; by Defendant on October 17, 2005. 4. Related claims pending: NONE 5. Date Plaintiffs Waiver of Notice in 93301 (c) & (d) Divorce was filed with the Prothonotary: October 19, 2005. Date 1 0 Paul Bradford Orr, Esquire 50 East High Street Carlisle, PA 17013 (717) 258-8558 6. Date Defendant's Waiv the Prothonotary: October 19, 2005. By: ........-., \...,::) - cf\ 0) Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BARBARANN GREEN, v. : CIVIL ACTION - LAW ARTHUR EDWARD GREEN, Defendant : NO. 03-5412 CIVIL ACTION-LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) & (d) of the Divorce Code was filed on October 14, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date}? 60 2(Jh ~~/r) ~ Barbarann Gre Plaintiff" .-/ u....- UJ '-Cl Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BARBARANN GREEN, v. : CIVIL ACTION - LAW ARTHUR EDWARD GREEN, : NO. 03-5412 CIVIL ACTION-LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) & (d) of the Divorce Code was filed on October 14, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. understand that false statements herein are made subject to the penalti es of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: I 0 - I 7 ~ os cfk~ G~ Arthur Green, Defendant ,.c:; ,_r: \..Cl Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BARBARANN GREEN, v. : CIVIL ACTION - LAW ARTHUR EDWARD GREEN, : NO. 03-5412 CIVIL ACTION-LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) & (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. S4904, relating to unsworn falsification to authorities. Date: /7 0(;(' .---- 2(]J~ ~thC-t?#A C Barbarann Green, Plaintiff --- LCJ ()l \.0 - Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BARBARANN GREEN, v. : CIVIL ACTION - LAW ARTHUR EDWARD GREEN, : NO. 03-5412 CIVIL ACTION-LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) & (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. 94904, relating to unsworn falsification to authorities. Date: If) -! 1-1) S- , d;~ 6~ Arthur Green, Defendant i''''' ( :- '~~) ~_i""'" .-} en \.D Plaintiff In the Court of Common Pleas of Cumberland County, Pennsylvania Barbarann Green V5. No. 5412 CiviUI1l2003 Arthur E. Grppn, Civil Law Dpfpnn::lnt Ac.tion in Divnrrp Please Enter ~ R1anc~~~ )DefenORnt. Ar>h"r r.reen To Prothonotary ,# Attorney for eJ,aimiff /, ',' /'~ l}e/{}j)L/! j _~ / (}U\V\ J!! (hi ," L c.; j I'.:: :-:.;: c~ r,~ - \".,..; No. Term, 19 _ VS. PRAECIPE Filed 19 , Atty. + + + + + + + . . . . + . + + . + + . . + . + + . + . + + + + + + . + . + + . +~~+~~++++++++++++~ :f +. + + . + + +++~++ +:+.+.+++++++++':+':t+ ++.+++:f.+ ++++++++++++++.+~ + + . + . + + +.+:+:+ +++++ ., +. +. +. +++++++++ IN THE COURT OF COMMON PLEAS + + + . + + + . + + + . + + + + . + + + + + + . + + + + + . + + + + + + + + . + . . OF CUMBERLAND COUNTY PENNA. STATE OF BarbarA-nn Gr~p.n No. 03-5412 Plaintiff VERSUS Arthur EdwArd Grp.p-n, Defendant DECREE IN DIVORCE + + + + + + + . + + + + + . + + . . + + + . ,+ . .+ .. '. o,...t 2b AND NOW, ,2.D.o.l___, IT IS ORDERED AND Green R;::lrh:=ar::lnn DECREED THAT , PLAINTIFF, Edward Green Arthur AND , 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; .. .. .. .. " " ,. I:. .). .. +> j~ ~:: +. +. By THE COURT: // /I ( Ulj ~ /iZl ^, / v" C-v <) (// /' AHE'T) jl~ +. .. .. + PROTHONOTARY + + + + +",++++++++++ . . . +++++'+''f+'l''f +++++++++'1'+++ +++++"1'++++ .n ++++'l'+ . + . . + . + + + + + + + + . + + + . + . + + . + . + . . + + + . . + + . + . . + . + . + + + + . + . + + + + J. f j'?lF'~1 ,Yli., 7/J?V jr.~.. l- ? ~. .1'/ ~;n ~-7 ff~ 1V.fP/ ! ~I ?Ji . . ~ ~. \.. ", ,'~ -, I(} (:C 11/ .>JiCt!/ -