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HomeMy WebLinkAbout07-68444 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF GLEN A.WOODROW, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW BETH A. WOODROW, NO. 07 - a CIVIL TERM Defendant : IN DIVORCE NOTICE 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 in divorce or annulment maybe 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 ,a STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF GLEN A.WOODROW, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW BETH A. WOODROW, : NO. 07 - CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Glen A. Woodrow, Jr., an adult individual residing at 189 Carlisle Road, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Beth A. Woodrow, an adult individual residing at 189 Carlisle Road, Newville, Cumberland County, Pennsylvania 17241. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on March 23, 1985, in Newburg, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that said parry has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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. Section 4904, relating to unworn falsification to authorities. I - , 2007 -?&? a., WMnAM--J ,-? Glen A. Woodrow, Jr., Plaintiff 2007 -- /f/9 BY: Supreme Coot ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff WOLF & WOLF -44 C> C> ?. ?.t ? CJr { A i c? Fn- 'h STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF GLEN A.WOODROW, JR. Plaintiff V. BETH A. WOODROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - &?yy CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotar/s Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. r - -112007 0.- W oyt e Glen A. Woodrow, Jr., Plaintiff m S o4 ?n c? STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF GLEN A. WOODROW, JR., Plaintiff V. BETH A. WOODROW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - 6844 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, comes Stacy B. Wolf, Esquire, Attorney for the plaintiff, Glen A. Woodrow, Jr., and states that she had caused to be mailed a copy of the Complaint in Divorce to Defendant, Beth A. Woodrow by both regular and certified mail, return receipt requested, to 129 E. Main Street, Walnut Bottom, Pennsylvania., 17266, and that the certified mail was accepted on January 7, 2008. A copy of said receipt is attached hereto indicating service was made on January 7, 2008. Respectfully submitted, WOLF & WOLF .,,4 1Y/ 102008 BY: Stacy B. W0)(1 Esquire 10 West High Street Carlisle, PA 17013 (717) 241-4436 Supreme Court ID # 88732 Attorney for Plaintiff ..-• . ¦ Cd_ is items 1, 2, and 3. Also complete A. SI nature item 4'if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the malipiece, Pff"ed by (Printed ) :' Date of De o or on the front if space permits. A h - -, E raw 1. Article Addressed to: D. Is delivery address different 0 If YES, enter delivery address ? No -A WOCCA C/o v? ?C11 w V\/ 3.^ type Certlfted Mail ? Egress Jvlaii 1 t ? 1 il+l rv?rlrnl VI( Registered E3 Return Receipt for Merchandise Insured Mati ? C.Q.D. O ( 4. Restricted Delivery? (F_idra Fee) ? Yes 2. Article uNumber 7007 2680 0003 0341 3510 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ; .* OO'• 1 r-9 I c Mail Only; I No Insuranc e Coverage Provided) Ln m ' 71 M Postage $ - M certified Fee ?7-1 M C3 Return Receipt Fee (Endorsement Required) $L45 j' Here C3 O Restricted Delivery Fee (Endorsement Required) t W 2O0Q LW VV CO •0 r1J Total Postage $ Fees $r:+} ?f?QCJ Sent MI r?- Street, Api No.; ------ - -----,---A-V I -A---------- --- - °-- - - - - •- - or PO Box No. ?Z V r.1 m ?? f-J, C C. ° -r cx) C:1 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF GLEN A. WOODROW, JR., Plaintiff v. BETH A. WOODROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 07 - 6844 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about November 13, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relaxing to unsworn falsification to authorities. May -!2L, 2008 ?6m alyk BETH A. W ODROW r STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF GLEN A. WOODROW, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ' CIVIL ACTION - LAW BETH A. WOODROW, : NO. 07 - 6844 CIVIL TERM Defendant : IN DIVORCE WALYER OF-NQ]= nu INxFN'' QN TO RF Y OF &D MAD r u 11hMER SEC OF TH-E-01YORCELODE 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, la is 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 con'ect. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: B TH A. WOOD ROW (--,, r.,, CJ 7?f n - J Pei ti STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF GLEN A. WOODROW, JR., Plaintiff V. BETH A. WOODROW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - 6844 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about November 13, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. Ma 2008 0. G.?h/? r?---"? May 2008 A. WOODROW, JR. - >17 e j i STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF GLEN A. WOODROW, JR., Plaintiff' v. BETH A. WOODROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - 6844 CIVIL TERM IN DIVORCE 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. Section 4904 relating to unworn falsification to authorities. _ ? G?? ,-?' Date: Ge - 7- OF GLEN A. WOODROW, JR. c ? yr r cz) 0 c p, - Ic r . ti i7 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 cn7) 2414436 ATTORNEY FOR PLAINTIFF GLEN A.WOODROW, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. BETH A. WOODROW, Defendant CIVIL ACTION - LAW NO. 07 - 6844 CIVIL TERM 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: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about January 7, 2008, defendant was served with a copy of the divorce complaint via certified mail. (See Affidavit of Service previously filed January 10, 2008) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: June 7, 2008. By the defendant: May 21, 2008. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None 5. Complete either (a) or (b): v (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached. N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary. June 19, 2008. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary. May 22, 2008. July -0 2008 Awl STAGY B. ftF Attorney fontiff CrIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF AlLk. PENNA. Glen A. Woodrow, Jr, 4 VERSUS N 0. )nn; -6844 DECREE IN DIVORCE AND NOW, ?J •1 1o , IMV, IT IS ORDERED AND DECREED THAT Glen A. Woodrow, Jr. AND Beth A. Woodrow ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, 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 BY THE COURT: ATTEST: J. c PROTHONOTARY ?? ? ? ... ? . . ? ,?, _. ...