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HomeMy WebLinkAbout03-6107 MANDY L. COLLINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v. CIVIL ACTION - LAW DOCKET NO. C3 - t..167 C .-U~ L ~~ DNORCE JASON R. COLLINS, Defendant. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Jason R. Collins c/o Brian Zellner, Esq. Law Office of Darrell Dethlefs 3805 Market Street Camp Hill, PA 17011 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 armuhnent 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 Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 291574-1 MANDY L. COLLINS, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW v. JASON R. COLLINS, DOCKET NO. ()3 _ (,/677 <3o~l ~ €fl.J", ) DNORCE Defendant. MANDY L. COLLINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v. CIVIL ACTION - LAW DOCKET NO. ()3 - (.1tP) DIVORCE c'i.>;L <-r~ JASON R. COLLINS, Defendant. COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Mandy L. Collins who currently resides at 7 A South Second Street, Wormleysburg, Cumberland County, Pennsylvania, 17043. 2. Defendant is Jason R. Collins who currently resides at 183 Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on December 31,1997 in Perry County, PA. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers and Sailors Civil Relief Act of the Congress of 1940 and Its Amendments. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. The 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. 8. Plaintiff avers that there are two children born ofthis marriage under the age of 18: Jason Russell Collins, Jr. (dob: 2/1/99) and Tiffany Marie Collins (dob: 6/21/97). 291574.1 COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER & 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The marriage ofthe parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing and service of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that 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 filing and service of this Complaint, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to 9 330I(c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER & 3301(d) OF THE DIVORCE CODE 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. The marriage of the parties is irretrievably broken. 14. The parties are living separate and apart, and at the appropriate time Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years as specified in ~ 330l(d) ofthe Divorce Code. 291574-1 WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to S 330I(d) of the Divorce Code. COUNT III REQUEST FORA FAULT DIVORCE UNDER & 3301(a) OF THE DIVORCE CODE 15. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 16. Defendant committed adultery. 17. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to S 3301(a) of the Divorce Code to Plaintiff, the innocent and injured spouse. COUNT IV EQUITABLE DISTRIBUTION 18. The prior paragraphs ofthis Complaint are incorporated herein by reference thereto. 19. During the marriage, the parties acquired marital property, assets and debts which Plaintiff requests the Court to distribute and assign equitably. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce, enter an Order equitably distributing the marital property, and enter such other orders as are appropriate and just. 291574-1 COUNT V SUPPORT, ALIMONY AND ALIMONY PENDENTE LITE 20. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 21. Plaintiff requires reasonable support and/or alimony and/or alimony pendente lite to adequately sustain herself within the standards ofliving established during the marriage. 22. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce, award Plaintiff support, alimony and alimony pendente lite, and enter such other orders as are appropriate and just. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ( Andrew C. Spears Supreme Court LD. No. 87737 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Date: \ \ - \ l\ ' C~ 291574-1 VERIFICATION I, Mandy L. Collins, verify that the statements made in the foregoing Complaint for Custody are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Q}{" ~~f\ ~ Dated: /1 /10/ 0 ~ 291574-1 - ~ 1\ ~ ~ ~ CJ1 ~ ~ -...0 D ( ~ ""0. ~ "' () ~ ~ . d g ~ I I::v ~)VP:::: ~~ '---L.... r:-- W ~ :. -. - , 8 err- : '<<.0- ti;: " ,,-- ..:z~ ':. _ ~-') --.. (J', MANDY L. COLLINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION - LAW v. DOCKET NO. 03-6107 CIVIL TERM JASON R. COLLINS, DIVORCE Defendant. AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff Mandy L. Collins, in the above- captioned divorce action, hereby certify that a true and correct copy ofthe Divorce Complaint in Divorce was served upon Defendant' counsel on November 26, 2003. Attached hereto, marked as Exhibit A and incorporated herein by reference, is an Acceptance of Service signed by Defendant's Attorney, Brian K. Zellner, Esquire. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: c Date: f J, ) S- ) D} Andrew C. Spears, Esquire Attorney I.D. No. 87737 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 291574.1 MANDY L. COLLINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Plaintiff, v. CIVIL ACTION - LAW DOCKET NO. (J.~ -fa/OJ ~ ~ JASON R. COLLINS, DIVORCE Defendant. ACCEPTANCE OF SERVICE I, Brian Zelmer, Esquire, Attorney for Defendant Jason R. Collins, hereby certify that I accept service of the Complaint in Divorce this 2t,.f-. day of /l!ove.... k ,2003. fLk9 Bri~er 291574.1 0 c-, 0 c: , 1 s: ;..-, -0 \. ;: ~ , rn C " Z J Z [" .... 0 , ~ r.: L <- ~. v" zt: ~C) c: ',' ---, z ~ -'. =< :1] (T'> -< MANDY L. COLLINS, COURT OF COMM N PLEAS CUMBERLAND CO NTY, PA Plaintiff NO. 03 - 6107 CIVIL ERM v. JASON R. COLLINS, CIVIL ACTION - DIV RCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affi avit, you must file a counter affidavit within twenty (20) days after this Affidavit has bee served on you or the statements will be admitted. 1. The parties to this action separated on March 27, 2003 a d have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, d ision of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the p nalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to Date: 7- 3/- <75- C> C -? ...off) ~'rr' '0~_\ 7_""" ~_:~:.' ~C,' ~(-- p...t.../ Y-C: 2':- :;;l. .-> ~ CS' ~ -;;0 I <1' o "" :t.-:D P'iQ ?69 g,,i. :;:: -1'1 ,;; C). ~"(" <-~ ?: ~ -'0 ?' ~ o rv MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVIL TERM v. JASON R COLLINS, CIVIL ACTION - DIVORCE Defendant CERTIFICATE OF SERVICE I, Brian K. Zellner, Esquire, do hereby certify that on April 7, 2005, I did seNe a certified copy of the Defendant's Affidavit under Section 3301 (d) of the Divorce Code by regular mail upon the Plaintiff. Date: 1f/7 / oS- ~ klU rian' K. Zellner, Esquire =--------. 2132 Market Street P.O. Box 368 Camp Hill, P A 17001 (717) 975 - 9446 Attyfd. No. 59262 --_.-'---- ...., :::5 c.n :-'> -a ::;n c' ~, ,I s:' __ 1Tlp::' yc:n ..)CJ {')T ~::~() . "T -...-{ ~~ co ::2 ,....:.., ~) c; MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVIL TERM v. JASON R. COLLINS, Defendant CIVIL ACTION - DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (d) DIVORCE DECREE TO: Mandy L. Collins, Plaintiff You have been sued in an action for Divorce. You have failed to answer the Complaint or file a Counter - Affidavit to the Section 3301 (d) Affidavit. Therefore, on or after May 19, 2005, the other party can request the court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an Answer with your Signature notarized or verified on a Counter - Affidavit by the above date, the Court can enter a Final Decree in Divorce. A Counter - Affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the Court may grant a Divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter - Affidavit does not protect your economic claims. 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. Date: "1/2- q/ t) S Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 - 3387 (717) 249 - 3166 tl-IL2Le- Brian K. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, P A 17001 (717) 975 - 9446 Attyld. NO. 59262 MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVIL TERM v. JASON R. COLLINS, Defendant CIVIL ACTION - DIVORCE COUNTER - AFFIDAVIT UNDER SECTION 3301 Cd) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because (check (i), (Ii) or both): (i). The parties to this action have not lived separate and apart for a period of at least two years. (ii). The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not with to make any claims for economic relief. I understand that I may have rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyers' fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Entry of Divorce Decree, the Divorce Decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this Counter - Affidavit are true and correct. I understand that false statement herein are made subject to the Penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: PLAINTIFF NOTICE: IF YOU DO NOT WISH TO OPPOSE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER - AFFIDAVIT. Q .,...,) 0 (-:-~:;) < c~ -n <J' , ~-,-, '-'1 -;J -;;0 1ne. -('1 ,>' r,' _,""T"? u:> "":~(~ V- (,~.~:~ :::,C - .' - .~-~ -;-.... ;- '~;:J -' ....( -" MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVIL TERM v. JASON R. COLLINS, CIVIL ACTION - DIVORCE Defendant CERTIFICATE OF SERVICE I, Brian K. Zellner, Esquire, do hereby certify that on April 29, 2005, I did serve a IcoPy of the Defendant's Notice of Intention to Request Entry of 3301(d) Divorce lDecree with Counter - Affidavit attached by regular mail upon the Plaintiff. Date: crf2.-10r- dt? Brian K. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Atty Id. No. 59262 (') c~ .-' l~:7) 1':;::'1 d' ~:"" ~) ?o '" ..0 o '-n .-l ::r:-rj n1F.:. -;-J~ ~.'}Y C?~ (7, "'. ~,~ p --" -~., ,""'--'..:.' ,-:.t~~f,- ~ ",~'J. .~,~ - - :;:- , MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVIL TERM v. JASON R. COLLINS, CIVIL ACTION - DIVORCE " , 0 'n ---",. :.~ - fii w -" , -.'" -." . {'-.J :~J --. ,-,"; .< Defendant 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. Grounds for Divorce: irretrievable breakdown under Section 3301 (d) of the Divorce Code. 2. Date and manner of service of Complaint: November 26, 2003 by acceptance of service by counsel for the Defendant 3. (a) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: March 31,2005. (b) Date of service of Defendant's Affidavit upon the Plaintiff: April 7, 2005. See attached time - stamped copy of the Affidavit and the Certificate of Service. 4. Related claims pending: none. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: April 29, 2005 via U.S. First Class mail. See attached time - stamped copy of the Notice of Intention. Date: s: 1141..00(" g,Jc-7k:--- - Brian K. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Atty Id. No. 59262 -MANf>-Y-b.-G0bblNS, IN-1H&GG8R-T-GF-GGMMGN-PbE-AS __ _~.._.____~___.._~______________:_____OF_CUMBERLAND_COUNTY, PA________ Plaintiff, etV~e'ft6-N . "t':'.kW v. DOCKET NO. . --- JASON R..COLLINS, -~~----_. ---:-.J;;~.".. DIVORCE Defendant. ACCEPTANCE OF SERVICE I, Brian Zellner, Esquire, Attorney for Defendant Jason R. Collins, hereby certify that I accept service of the Complaint in Divorce this 2(;.(-. day of ./IJ()ve.... k ,2003. !t~ ,fBri e er / 291574-1 MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. NO. 03 - 6107 CIVIL TERM (") c <.:- ~ft (0,:" -<...' ~ ~~.~: CIVIL ACTION - DIVORC~ ~:~ Pc: ~ --< JASON R. COLLINS, Defendant NOTICE ..., = ~ = en :> ~::Il " ::>::l m~ I ::g 0'1 ()o " ::;:i'j c5::Il :x -'';7<"') N csrn -., ---. 0 :n N .< If you wish to deny any of the statements set forth in this Affidavit, you must file a counter affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNpER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on March 27, 2003 and have continued to live separate and apart for a periOd of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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. 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 Date: :? - 3' / - <:75- t~;/~ Pa.C.S. Section 4904, relating to unsworn falsification to MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVIL TERM v. JASON R. COLLINS, CIVIL ACTION - DIVORCE Defendant CERTIFICATE OF SERVICE I, Brian K. Zellner, Esquire, do hereby certify that on April 7, 2005, I did seNe a certified copy of the Defendant's Affidavit under Section 3301 (d) of the Divorce Code by regular mail upon the Plaintiff. Date: Lf/7j 00 ~ /clU rian'K. Zellner, Esquire --............. 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Atty Id. No. 59262 "> g 0 c.n " ~ =rt :;v [11 ill J :;? rn co ~~6 t;) ',_. "l"i ::i: :,_')~~ r;:.' c5rn ~':; --< C) MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA (2 ~ ~:; Plaintiff O"O~. i ,'," r-.) 0 ~-; -11 0"'" ~""T"'! -;; fn p_ ?'J f'J --y,C) t" . "- '-'> (),C! ,-, "11 .'1,. ~,\ ~ \:,2;:-,.,') ~,. \ ::: :~?.tn - -,-" c. .- .:::;) -;::, s:;; :...c :2. --1 NO. 03 - 6107 CIVIL TERM v. JASON R. COLLINS, Defendant CIVIL ACTION - DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (d) DIVORCE DECREE TO: Mandy L. Collins, Plaintiff You have been sued in an action for Divorce. You have failed to answer the Complaint or file a Counter. Affidavit to the Section 3301 (d) Affidavit. Therefore, on or after May 19, 2005, the other party can request the court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified on a Counter. Affidavit by the above date, the Court can enter a Final Decree in Divorce. A Counter - Affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the Court may grant a Divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter - Affidavit does not protect your economic claims. 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. Date: '1/2Of/Or Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 - 3387 (717) 249 - 3166 a-lc2U Brian K. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, P A 17001 (717) 975 - 9446 Attyld.No.59262 MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVIL TERM v. JASON R. COLLINS, Defendant CIVIL ACTION - DIVORCE COUNTER - AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because (check (i), (ii) or both): (I). The parties to this action have not lived separate and apart for a period of at least two years. (ii). The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not with to make any claims for economic relief. I understand that I may have rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyers' fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Entry of Divorce Decree, the Divorce Decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this Counter - Affidavit are true and correct. I understand that false statement herein are made subject to the Penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: PLAINTIFF NOTICE: IF YOU DO NOT WISH TO OPPOSE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER - AFFIDAVIT. MANDY L. COLLINS, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff NO. 03 - 6107 CIVil TERM v. JASON R. COLLINS, CIVIL ACTION - DIVORCE Defendant '" c::::) 0 c.:., -., 2;j ::;:f ;;0 ffi ~ -~, f""" f'...) :r.Jer) w S3c> .-.~, _ ? ~~~1 ..>,.-: - ;:.:.-.-rn I, Brian K. Zellner, Esquire, do hereby certify that on April 29, 2005, I d~se~ a?Ji copy of the Defendant's Notice of Intention to Request Entry of 3301(d) Divorce C;) -c CERTIFICATE OF SERVICE Decree with Counter - Affidavit attached by regular mail upon the Plaintiff. Date: cit.-.1or tfl? Brian K. Zellner, Esquire 2132 Market Street P.O. Box 368 Camp Hill, PA 17001 (717) 975 - 9446 Attyld. No. 59262 --- c c --" -". d') \" ~. ... . .~. ;,; - ii'1';+;;+;;f.;+; ;+; +. ~~ ~ ~~~~~ ~~ ;+;;f.~~ ~~~ ~ ~ ~~~~~~~~~~~ ~ ~~~~~ ~~~ ~~:+:;+; +~ .. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY MANDY L. COLLINS PENNA. STATE OF No. 03-6107 CIVIL TERM VERSUS JASON R. COLLINS DECREE IN DIVORCE AND Now,---lMt~ -2.Y\ --- -~ J, IT IS ORDERED AND +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. ~'+'f~+'l'~~+'f+~;t'~~'f~ MANDY L. COLLINS DECREED THAT , PLAINTIFF, AND JASON R. COLLINS , 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; / .4 ;/ /" jL~ . / PROTHONOTARY +. +. 'f+'f~+~~~:+:++'f~+~~+'f~++~? :+: +~+ +'f:+:~~~++~+ :+: +~~++'f++'f'f+:+:++'f~~+ + +. ~~ +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. J. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. +. (~?(J fir ~ I~~ C~nfllt3) _~? P. ~?'>'" ~~4"/,(, ~ f!. ,/'rJ-pJ-1,f ~? .p;p . ". ~)V hr:' ~r;: .'i(J , ;, C'- ~ ~.