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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