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Home My WebLink About07-7401 HAROLD S. IRININ, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243.6000 ATTORNEY FOR PLAINTIFF LINDA K. ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff( : CUMBERLAND COUNTY, PENNSYLVANIA V0 : CIVIL ACTION - LAVV : NO. 2007 - 7 `f 0 ( CIVIL TERM VERNON L ANDERSON9 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 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 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 r' LINDA K. ANDERSON, PIalntW V. VERNON L. ANDERSON, Dahndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA CIVIL TERM NO. 2007 - 7q01 IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is LINDA K. ANDERSON, an adult individual residing at 2 North Orange Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is VERNON L. ANDERSON, an adult individual residing at 439 Burgners Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties 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 September 15, 2000, in Carlisle, 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 she has been advised of the availability of counseling and that she 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. I verify that the facts contained herein 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 unsworn falsification to authorities. December 7, 2007 ?s??ltiiS NDA K. ANDERSON, Plaintiff HAMALD S. IRWIN, Attorney for Plainti 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 LINDA K. ANDERSON, Plaintiff V. VERNON L. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - "7 y 01 CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 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. 1 understand that the court maintains a list of marriage counselors in the Prothonotary'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 unsworn falsification to authorities. December 7, 2007 J)LINDA K. ANDERSON, Plaintiff Q ,1?1 I IC) a rTl r-t SA.) ` c.? HAROLD s. IRM11N, III, ESQUIRE ATTORNEY ID NO. 29M 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 2434090 ATTORNEY FOR PLAINTIFF LINDA K. ANDERSON, Plalntm V. VERNON L. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - 7401 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920A (a)(1)(1) NOW, Harold S. Irwin, 111, Esquire, being duly sworn according to law, does depose and state: That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on December 12, 2007, addressed to the defendant at 439 Burgners Road, Carlisle, , PA 17013, Certified Mail No. 7007 0710 0003 2208 3974. 3. A copy of the sender's and signed receipt are attached hereto. 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 unsworn falsification to authorities. December 13, 2007 % -? -L/ i Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 A U 'S CERTIFIED / (Domestic Only; No Insuranc e • .•• Provided) r%- Q' s• M 1 OFFI CIA L USE .0 C] Postage fU l.Z .. ( $ ' ` ""L' IL t is Ce Ied Fee M Postmark C3 Fee Return R ui R Here re d) eq sement (Endor pestrk;ted Delivery Fee (Endorsement Required) C3 N Total Postage $ Fees C3 Sent To a" M Sueei, ilpt: 77o.; - -t C3 171 or PO Box No. p, -- - -------------- a City, Sta ?+4 / Complete items 1, 2, and 3. Also complete item 4 If Reahicted 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 hack of the maiipiece, or on the front If space permits. 1. Article Addressed to: WiI RNON Tom, xNT1 'RSON 4 3 9 -SU' G ER RD C?1RLISLF PA 17013 A. Big Mb" 0 Agent D. Is delivery address dnfwwtt horn item 11? 0 yes If YES, enter delivery address below: 0 No 3. Service Type Mall ? Express Mail P , O Registered 0 Return Receipt for Merchandise 0 insured man 0 C.O.D. 4. RstrMcl ed Delivery? Prins Fee) 2. Articls Nurrrbar 7007 0 710 0003 2208 3974 (rferrdsrtbnrr? id?vtes Aabed) , PS Form 3811. Febwary 2004 PJemuft RaUv Rea lpt 1026ss-M-rt•1640 EXHIBIT W ?,?_ ?+` - ?? ? ?? ?' ??+ ?c? ,. ,.. LINDA K. ANDERSON, : IN THE COURT OF COMMON PLEAS OF P1alntW : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2007 - 7401 CIVIL TERM VERNON L. ANDERSON, : Defendant : IN DIVORCE AFFDAVIT OF CONSENT A complaint in divorce under Section 3301(4) of the Divorce Code was filed in this matter on or about December 7, 2007. Service of the complaint was made upon defendant on December 12, 2007 (see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. March.JLJ_, 2008 LINDA K. ANDERSON WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 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. Section 4904 relating to unsworn falsification to authorities. March Al , 2008 '?? A K. ANDERSON ? ° ` C - ?. --? ?< r - ? r-?? ?. r ?`' u? ? ?_ t - ;?- ?. LINDA K. ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2007 - 7401 CIVIL TERM VERNON L. ANDERSON, : Defendant : IN DIVORCE AFFDAVIT OF CONSENT A complaint in divorce under Section 3301(Q* of the Divorce Code was filed in this matter on or about December 7, 2007. Service of the complaint was made upon defendant on December 12, 2007 (see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. ch 7 , 2008 ?? VERNON L. ANDERSON WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 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. Section 4904 relating to unsworn falsification to authorities. ?Pr< M)(ch ?, 2008 VERNON L. ANDERSON _ Fri HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243.6090 ATTORNEY FOR PLAINTIFF LINDA K. ANDERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. VERNON L. ANDERSON, Defendant : CIVIL ACTION - LAW NO. 07 - 7401 CIVIL TERM IN DIVORCE 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) of the Divorce Code. 2. Date and manner of service of the complaint: On or about December 12, 2007, defendant was served with a copy of the divorce complaint via certified mail, "restricted delivery', addressed to the defendant. (See Affidavit of Service previously filed.) 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: March 21, 2008. By the defendant: April 7, 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): (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: March 25, 2008 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 15, 2008 April 15, 2008 % ROLD S. IRWIN, III Attorney for Plaintiff ? I T ' t- CJl . _, f'7 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LINDA K. ANDERSON Plaintiff N 0.2007-7401 CIVIL TERM VERSUS VERNON L. ANDERSON Defendant DECREE IN DIVORCE AND NOW, 2- ) Zdad , IT IS ORDERED AND DECREED THAT LINDA K. ANDERSON PLAINTIFF, AND VERNON L. ANDERSON 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 BY THE COURT: PROTHONOTARY -Ovv? in?-- -?a "Op? 4? -,kv