HomeMy WebLinkAbout03-6420
TAMMIE 1. ANDERSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03 - ~4~D
C1o\l't-82..wt
JAMES E. ANDERSON,
Defendant
: CIVIL ACTION - LA W
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
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 iITetrievable breakdown of
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary, 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 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, PA 17013
Telephone: (717) 249-3166
TAMMIE 1. ANDERSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03 -1-lf'JO
(!iu~l Ly-~~
JAMES E. ANDERSON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
I. The Plaintiff is Tammie J. Anderson, an adult individual currently
residing at Lot 136, 6280 Carlisle Pike, Mechanicsburg, Cumberland County,
Pennsylvania, 17050.
2. The Defendant is James E. Anderson, an adult individual residing at
Lot 127, Betty Nelson Court, Carlisle, Cumberland County, Pennsylvania. 17013.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately
previous to the filing of this Complaint.
4, Plaitttiff and Defettdant were married on February 11, 2002, in
Cumberland County.
5. There have been no prior actions of divorce or annulment between the
parties in this or any other jurisdiction.
6. This actiott is not collusive.
7. Plaintiff and Defendant separated on or about Jutte 14,2003.
8. The causes of actiott and sections of the Divorce Code under which
Plaintiff is proceeding are:
A. Section 3301(c) - The marriage of the parties is iITetrievably
broken.
B. Section 330 I (d) - The marriage of the parties is iITetrievably
brokett. The parties separated on or about June 14,2003.
C. Section 3301 (a)(6) - The Defettdant has offered such
indignities to the Plaintiff, the innocent and injured spouse, as to render
her condition intolerable and her life burdensome, to wit, Defendant has
been abusive towards the Plaintiff, both physically, emotional, and
mentally. Additionally, he has sexually abused the parties' baby daughter.
9. Plaintiff and Defendant have one child under the age of eighteen,
namely Amanda K. Anderson, born October 29, 2002.
10. Plaintiff has been advised of the availability of marriage counseling
and understands that she may request that her spouse and she participate in counselittg.
II. Plaintiff does not request that the Court require that her spouse and
she participate in counseling prior to a divorce decree being handed down by this Court.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter
a final decree itt divorce.
Date:
/1/1/' )
Respectfully submitted,
THE LAW OFFICES OF
SILLIKER & REINHOLD
~~..
ark T. Silliker, Esquire
5922 Linglestown Road
Harrisburg, PA 17112
(717) 671-1500
J.D. No. 33671
Attorney for Plaintiff
AFFIDA VIT
I,TtJfVIJ'I\ie J PrJ..ff5lY\ ,hereby certify that the aforegoing is true
and COITect 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. 4909 relating to
unsworn falsifications to authorities.
Dated:
1//(3/03
*;/V___
lit~
~ ::; ~
CI) :0 0'
c5--;:c)
~ ~~
()
s;~ -"
Z'. ::
(r
~
,',
~
::Po' .
>; :-:.)
=2 - :::;'
U] ~
,
~
TAMMIE J. ANDERSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03 - 6420
JAMES E. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE
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 UNDER SECTION 330I(d)
OF THE DIVORCE CODE;
1. The parties to this action separated on June 14,2003, and have continued
to live separate and apart for a period of at least two years.
2, The marriage is iITetrievably broken.
3, I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if! do not claim them before a divorce is granted.
I verify that the statements made in this affidavit arle 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:
dy~~
4~'~
Tamn~n erson
TAMMIE J. ANDERSON,
Plaintiff
: IN THE COURT OF COMMONN PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 03 - 6420
JAMES E. ANDERSON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE OF INTENTION TO REOUEST ENTRY
OF SECTION 3301(D) DIVORCE DECREE
TO: James E. Anderson, Defendant
You have been sued in an action for divorce. You have failed to answer the
Complaint or file a Counteraffidavit to the Section 3301(d) Affidavit. Therefore, on or
after July 25, 2005, the Plaintiff can request the Court to ent,er a final Decree in Divorce.
If you do not file with the Prothonotary of the Court an answer with your
signature notarized or verified, or a counteraffidavit by the above date, the Court can
enter a final Decree in Divorce. A COUNTERAFFIDA VIT WHICH YOU MAY FILE
WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE.
Unless you have already filed with the Court a writtm claim for economic relief,
you must do so by the above date or the Court may grant th~: divorce and you will forever
lose the right to ask for economic relief. The filing of the form counteraffidavit alone
does not protect your economic claims.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. ]F
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO Fll-lD OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR AS SOCIA nON
2 Liberty Avenue
Carlisle, P A 17013
Telephone: (717) 249-3]66
TAMMIE J. ANDERSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03 - 6420
JAMES E. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S COUNTERAFFmA VIT
UNDER SECTION 3301(0) OF THE DIVORCE CODE
1. Check either (a) or (b):
_ (a) I do not oppose the etttry 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.
(2) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_ (a) I do not wish to make any claims for economic relief. I understand that
I may lose rights concerning alimony, division of property, lawyer's
fees and 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, lawyer's 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 Intetttion to Request Entry of a
Divorce Decree, the Divorce Decree may be entered without further delay.
I verify that the statemettts made in this counteraffidavit are true and COITect. 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.
Date:
James E. Anderson
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A
DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR
ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTERAFFIDA VIT.
Q ~ q,
c:. ~
7'" '-- ~~
~1:)\J' c::.
nO"~"~ ~..
;; ,.'- - ~~
03
2:fj ~I.,. 0 C~
r~:;:;' .." ~.~C. :t1
..."" ()~
::".(' ';$. F5 ?I,
~"'C'
?c:~ - '"
7- :r""
:l U' ::t
c..n
TAMMIE J. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03 - 6420 CIVIL TERM
JAMES E. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned, Renee Dreisbach, hereby certifies that a copy of a
Complaint itt Divorce was served upon Defendant, James E. Anderson, on December 23,
2003, by certified mail, return receipt requested, addressed as follows:
James Attderson
Lot 46 Betty Nelson Court
Carlisle, PAl 7013
I hereby certify that the aforegoing is 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. g4904 relating to unsworn falsificatiott to
authorities.
Date: 1ft g I co-
~L(~'\i1?c.l-_
R nee Dreisbach
. Complete Items 1, 2, and 3. Also complete
~om 4 ~ Restricted Delivery Is desired.
. PrInt your name and address on the reverse
.. that we can return the card to you.
. Attach this card to the back of the mal/piece,.
Of on the front if space permits.
1. _Add_to:
c.
~J .0.
D. Is delively add.... dlffom<1t from ~em 17 0 Yes
If YES, enter delivery addf'eS6 below: 0 No
00-~/~
Lof~&tIy rJe&r..
Co-rltsk ~ /70/3
'-..,
.
D Express Mall
o Return Receipt for Merchal"ldfH
o
(FxtIa Foel
2. Artk:le Number
(T'8ll8fwr from -we. _I
PS Form 3811, August 2001
7001 1940 0006 2489 0586
Domostle Return Receipt
'I02595-01-M-25Q9
a
(;
.c,,,
-ocr:
,..\"\.(r,'.
'-?'1.\
~?J~
(f~.~
~t
y('"-
':?-C'
<}?'(~-.:
~
~
~
~
G'">
I
co
~
:::1.."
'~~
:JJ t:J
00
-::-;.3-:'.
.~.....,,1
<;;?6
/--tn
S
~
~
co
.'
()\
()\
-
TAMMIE J. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03 - 6420 CIVIL TERM
JAMES E. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned, Renee Dreisbach, hereby certifies that a copy of an
Affidavit Under Sectiott 3301(d) of the Divorce Code, Notice ofIntention to Request
Entry of Section 3301(d) Divorce Decree, and Defendant's Counteraffidavit Under
Section 3301(d) of the Divorce Code was served upon Defendant, James E. Attderson, on
July 14, 2005, by certified mail, return receipt requested, addressed as follows:
James Anderson
31 Betty Nelson Court, Lot 128
Carlisle, P A 17013
I hereby certifY that the afore going is true and COITect 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.
7//Cks-
Ci!!t~cfJrkSfrdi-
enee DreIsbach
Date:
'CompIoJle _ 1, 2, .-.:13. A*> co........
_ 4 K _ Oo4ivery ia 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 mail piece,
or on the front if space permits.
1, ArtIcle Addressed to:
J{1fYL1l5 E. ~YSlJIL
3/ j)pJM NelSlYl Owff'
---0 LlJ /;)2
Car !/~ f2p.. /70/3
. Received by (Printed Name)
D. Is delivery address different from item 1?
If YES, enter delivery address below:
3'Eice Type
. eel Mall 0 Express Mail
Registered 0 Return Receipt for Merchllf'ldiee
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (ExtrB Fee) 0 Yes
2.ArtlcIo_
(1l1Insferfn>m__
PS Form 3811, Auguat 2001
7001 2510 0006 2853 68~3
DomestIc Return ReceIpt
l02595-01.M-2509
g ~ ~
Sc ~ ;\
..,-"'0.:- ~
CPC," c:>
~~,;: I
CP Q
~(" ~-1"~
~ .., ~.;: ~
~') .-e'
~c ~Q
$(j <:? 0(11
C..::. :A
z ~
~ <J'.
<J'.
TAMMIE J. ANDERSON
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 03-6420 CIVIL TERM
JAMES E. ANDERSON
Defendant
: CIVIL ACTION - LAW
: 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:
I. Ground for divorce: irretrievable breakdown under Section
() 3301 (c) (X) 3301 (d) ofthe Divorce Code. (Check applicable section.)
2. Date and manner of service of the Complaint: December 23, 2003
by Certified Mail.
3. Complete either (a) or (b).
(a) Date of execution of the Affidavit of Consent required by
Sectiott 3301(c) of the Divorce Code:
(b) (I) Date of execution of the Plaintiff's Affidavit required by
Section 330I(d) of the Divorce Code: June 24, 2005.
(2) Date of service of the Plaintifif's Affidavit upon the
Defendant: July 14,2005.
4. Related claims pending: Notte.
5. Complete either (a) or (b).
(a) Date and manner of service of Notice of Intention to File
Praecipe to Transmit Record, a copy of which is attached: July 14, 2005, by Certified
Mail.
(b) Date Plaintiff's Waiver of Notice itt g3301(c) Divorce was
filed with the Prothonotary:
Date Defendant's Waiver ofNotic:e in g3301(c) Divorce was
filed with the Prothonotary:
6, Social Security Numbers:
(a) Plaintiff: 210-60-6161
(b) Defendant: 239-94-9098
~--:a~ ~
Attorney for Plaintiff
--
Cl
c.
~~~
.-J{:'
nl'; 1
::::..;-'
(j~
M< "
~~-
~?,'i'- ,
5-<0:
"
::.:~
-<.:
~
~
~
G">
-
-
~
~
~"J:J(%
-I)
b
~-~
-::'C':'-1
0-,
7-~\
g
~
-0
~
i9
'"
CT'
-
TAMMIE J. ANDERSON,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
JAMES E. ANDERSON,
DEFENDANT
03-6420 CIVIL TERM
AND NOW, this
ORDER OF COURT
l ft day of August, 2005, the request for the entry of a
final decree in divorce IS DENIED at this time.1
:sal
v/tlGrk T. Silliker, Esquire
For Plaintiff
v<ffimes E. Anderson
31 Betty Nelson Court, Lot 128
Carlisle, PA 17013
I Pa. Rule of Civil Procedure 1920.72(d) requires that a Section 3301 (d) affidavit
notify the other party to file a counter-affidavit within twenty (20) days of service,
or the statements in the affidavit will be admitted. Rule 1920.73, providing for a
notice of intention to request the entry of a Section 3301 (d) divorce decree,
requires that it include a statement that, "You have failed to . . . file a counter-
affidavit to the ~ 3301 (d) affidavit. Here, the notice of intention to request the
entry of a Section 3301 (d) divorce decree was served on defendant on July 14,
2005, the same date as the Section 3301 (d) affidavit. Because defendant has
twenty days from service of the Section 3301 (d) affidavit to file a counter-
affidavit, defendant cannot be notified on the same day it is served that there has
been a failure to file a counter-affidavit.
fr;
<c
o
~~
~~
6'-'c
WO-
~:...JlL.l
a:F
u...
o
o
M
6
::s::
.a:
f::
2:
:J.:;r:
f~~f
-"
_.)~
>~
_,,-JUJ
'In...
r-
<-!)
=>
"'"
.r.>
=
=
......
"'--:.:
~
(.)
TAMMIE J. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-6420 CIVIL TERM
JAMES E. ANDERSON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff in the above matter,
v" prior to the entry of a Final Decree in Divorce
or
after the entry of a Final Decree in Divorce dated
hereby elects to resume the prior surname of Hartford, and gives this written notice
avowing her intention pursuant to the provisions of 54 P.S. 704.
Date: 'i; /2.2.JCJ=;
~r;;;: .~~-"'
Tirmll).ie~derson
c'
}~r
Tam . . artford
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
On th~~y OfQ/WAd- ,2005, before Ille, anotat)' public,
personally appeared the above affiant known to me to be the person whose name is
subscribed to the within documettt and acknowledged that she executed the foregoing for
the purpose therein contained.
In Witness Whereof, I have hereunt
NOTARJAL SlIAL
-- DNlIlNloII, N-.y .......
.!-CommI~ Ttrp., n .'''- Ceaatr
my l!xphw New. 30, 200f
~ (::l ~
1t '"
c
- C> (") ,....,
"'"- \:) = 0
ll- C' = -n
~ ~ ..,- <.r'
~ V"J :1
~ l"lj rn::!l
-0 -0 fTi
--.::> N -09
~ ~ Cl S-lC)
-~--r;
"""tl -" ," -r~
-,,,. r ~
-''''' ~~...C)
-'-- :~jm
-C N -~
~
Cl ~
.JAall JAiAATOlf
oItcfu'l '(W01of ,d:)Cd.i>nCl O!O....q
'(llUlo:) Didqu.o ,.qwT tIOI~.'1 ,,,..,.,t
aoot ,Ot .Y-1H' '~'!fq:t'"-l ~?~~~2~~'1.v\~
TAMMIE J. ANDERSON,
Plaintiff
: IN THE COURT OF COMMONN PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-6420 CIVIL TERM
JAMES E. ANDERSON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF SECTION 3301(D) DIVORCE DECREE
TO: James E. Anderson, Defendant
You have been sued in an action for divorce. You have failed to answer the
Complaint or file a Counteraffidavit to the Section 3301(d) Affidavit. Therefore, on or
after September 16, 2005, the Plaintiff can request the Court to ettter a final Decree in
Divorce.
If you do not file with the Prothonotary of the Court an answer with your
signature notarized or verified, or a counteraffidavit by the above date, the Court can
enter a final Decree in Divorce. A COUNTERAFFIDA VIT WHICH YOU MAY FILE
WITH THE PROTHONOTARY OF THE COURT IS A TT ACHED 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 the divorce and you will forever
lose the right to ask for economic relief. The filing of the form counteraffidavit alone
does not protect your economic claims.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, P A 17013
Telephone: (717) 249-3166
v.
IN THE COURT OF COMMONN PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-6420 CIVIL TERM
TAMMIE J. ANDERSON,
Plaintiff
JAMES E. ANDERSON,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
DEFENDANT'S COUNTERAFFIDA VIT
UNDER SECTION 330HD) 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.
_ (2) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_ (a) I do not wish to make any claims for ecottomic relief. I understand that
I may lose rights concerning alimony, division of property, lawyer's
fees and expenses if! do not claim them before a divorce is granted.
_ (b) I wish to claim economic relief, which may include alimony, division
of property, lawyer's 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!
fail to do so before the date set forth on the Notice of Intention to Request Entry of a
Divorce Decree, the Divorce Decree may be entered without further delay.
I verify that the statements made in this counteraffidavit are true and COITect. I
W1derstand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to W1swom falsificatiott to authorities.
Date:
James E. Anderson, Defendant
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A
DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR
ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTERAFFIDA VIT.
::V,'/"
"":1
~/~ :f:,
(")
(:
~
c="
0"
%
-0
'"
--
q.
-'
-r.~
frI""'"""
",,\J:l
~.;} '-,)
()\~f
"-':::-n
<:r-
;"...~1
;'....- ~ ' ,
9,
~
-'0
:>
N
o'
J::'
()"1
-
-----
.
<;:,c
:',-?'.c
",:~. (::
PC
~i
-c.
TAMMIE J. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-6420 CIVIL TERM
JAMES E. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned, Renee Dreisbach, hereby certifies that a copy of a
Notice ofIntention to Request Entry of Section 3301(d) Divon;e Decree and Defendant's
Counteraffidavit Under Section 3301(d) of the Divorce Code was served upon James E.
Anderson, on September 24, 2005, by certified mail, return receipt requested, addressed
as follows:
James E. Anderson
31 Betty Nelson Court, Lot 128
Carlisle, P A 17013
I hereby certify that the aforegoing is true and COITect to the best of my
knowledge, information and belief. I understand that false statements herein are made
=~~:'" """"';" of;' PaC.5. i~to "'ii fu
Date: -10 II tj/OC;- . 'L{ A.. ~ .'.
I , enee Dreisbach
. Complete "ems 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
- s04'18t we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
1. Artjcl~ressed to:
James E.~
3/ &11)1 A/eJ~f)f\ CIMYI-;
-0 Lo+/~
Car/(sfL Rt /70/3
3. Service Type
~Certif\ed Mail
o Registered
o Insured Ma"
o Express Mail
o Return Receipt for Merchandtae
DC.CI.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
2. Article Number
(Transfer from service 1abtII)
PS Form 3811, August 2001
7001 2510 OOOb 2853 ~794
Domestic Return Receipt 102595-01-M-2509
o
,-)
--1
r','
CJ
"..-.,
~_.)
-n
:::<1
ii'
1"0
4:"
TAMMIE 1. ANDERSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-6420
JAMES E. ANDERSON,
Defendant
: CIVIL ACTION - LAW
: 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:
I. Ground for divorce: irretrievable breakdown under Section
() 3301 (c) (X) 3301 (d) of the Divorce Code. (Check applicable section.)
2. Date and manner of service of the Complaint: December 23,2003.
by Certified Mail.
3, Complete either (a) or (b).
(a) Date of execution of the Affidavit of Consent required by
Section 3301(c) of the Divorce Code:
(b) (I) Date of execution of the Plaintiff s Affidavit required by
Section 3301(d) of the Divorce Code: June 24, 2005.
(2) Date of service of the Plaintiff's Affidavit upon the
Defendant: July 14, 2005.
4. Related claims pending: None.
5. Complete either (a) or (b).
(a) Date and manner of service of Notice ofIntention to File
Praecipe to Transmit Record, a copy of which is attached: September 24,2005, by
Certified Mail.
(b) Date Plaintiffs Waiver of Notice in g3301(c) Divorce was
filed with the Prothonotary:
Date Defendant's Waiver of Notice in g3301(c) Divorce was
filed with the Prothonotary:
6. Social Security Numbers:
(a) Plaintiff: 210-60-6161
(b) Defendant: 239-94-9098
-----==-~--- -=--
~.. "~l orPlamtiff
L.---~<~
:'-')
--{i
CI :::"'J
("",\ ;",-,
;....~,
c:;
r<'
-
-
c~ $ ~~ ~r:?2L, _Sc?-,,<>ro/
).-.r~. . (,~ /' /
F .t/t/ -- /7' r .:J nzr-!'?YP ~Ol) /,'V52? _?-c:', (1/
..
....
'..
~ .... ,. ..
-"' ....:..
'. .
.?w' ~t;4:> -0 ' ~'Yr_c;:) nrcJ
5a?C" 'Ie J?rN{) f~ n-0' ~(J