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Home My WebLink About08-0495JANE E. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA STEVEN R. JONES., : CIVIL ACTION-LAW Defendant : 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 of 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 the 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, PA 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, 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Respectfully Submitted, FOREMAN, FORWt N & CARACIOLO, P.C. Bruct D. Foreman,Esquire Attorney ID No. 21193 112 Market Street, 6U' Floor Harrisburg, PA 17101 (717) 236-9391 Telephone (717) 236-6602 Facsimile bruce@ffclaw.net Attorneys for Plaintiff Bruce D. Foreman, Esquire Attorney ID No. 21193 Foreman, Foreman & Caraciolo, P.C. 112 Market Street, 6'" Floor Harrisburg, PA 17101 (717) 236-9391 Telephone (717) 236-6602 Facsimile bruce@ffclaw.net Attorneys for Plaintiff JANE E. JONES, Plaintiff V. STEVEN R. JONES., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Jane E. Jones, by and through her attorneys, Bruce D. Foreman, Esquire and Foreman, Foreman & Caraciolo, P.C., and makes the following Complaint in Divorce and, in support thereof, avers as follows: 1. The Plaintiff, Jane E. Jones, is an adult individual who currently resides at 717 Colonial Court, Cumberland County, Mechanicsburg, PA 17050. 2. The Defendant, Steven R. Jones, is an adult individual who currently resides at 3000 South Chester Avenue, Space 46, Bakersfield, CA 93304. 3. The Plaintiff has been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married by formal ceremony on August 6, 2000 in Las Vegas, Nevada. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. At the appropriate time, Plaintiff will submit an affidavit alleging that the parties have been living separate and apart for a period of at least two years. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. This action is not collusive. 2 WHEREFORE, the Plaintiff, Jane E. Jones, respectfully requests this Honorable Court to enter a decree of divorce in this matter. Respectfully Submitted, FOREMAN, FOVXL?IAN & CARACIOLO, P.C. Bruce D. Forent-A, Esquire Attorney ID No. 21193 112 Market Street, 6 h Floor Harrisburg, PA 17101 (717) 236-9391 Telephone (717) 236-6602 Facsimile bruce@ffclaw.net Attorneys for Plaintiff 3 Bruce D. Foreman, Esquire Attorney ID No. 21193 Foreman, Foreman & Caraciolo, P.C. 112 Market Street, 66 Floor Harrisburg, PA 17101 (717) 236-9391 Telephone (717) 236-6602 Facsimile bruce@ffclaw.net Attorneys for Plain tiff JANE E. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. STEVEN R. JONES., : CIVIL ACTION-LAW Defendant : IN DIVORCE VERIFICATION I verify that the statements made in this Complaint 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. § 4904, relating to unworn falsification to authorities. Dated: JOXL ? ' (?V. 0 AL J E. Jones, Pl tiff Bruce D. Foreman, Esquire Attorney ID No. 21193 Foreman, Foreman & Caraciolo, P.C. 112 Market Street, 6`h Floor Harrisburg, PA 17101 (717) 236-9391 Telephone (717) 236-6602 Facsimile bruce@ffclaw.net Attorneys for Plaintiff JANE E. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. STEVEN R. JONES., : CIVIL ACTION-LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Danielle L. Leist, hereby certify that on the day of 2008 served a true and correct copy of the Complaint in Divorce upon the following named Defendant by hand delivering upon the person with address as follows: Steven R. Jones 3000 South Chester Avenue Space 46 Bakersfield, CA 93304 Respectfully Submitted, FOREMAN, FOREMAN & CARACIOLO, P.C. Danielle L. Leist, Secretary to Bruce D. Foreman, Esquire Attorney ID No. 21193 112 Market Street, 6 h Floor Harrisburg, PA 17101 (717) 236-9391 Telephone (717) 236-6602 Facsimile bruce@ffclaw.net Attorneys for Plaintiff 4 W G R1 ' . , a Bruce D. Foreman, Esquire Attorney ID No. 21193 Foreman, Foreman & Caraciolo, P.C. 112 Market Street, 6'" Floor Harrisburg, PA 17101 (717) 236-9391 Telephone (717) 236-6602 Facsimile bruce@ffclaw.net Attorneys for Plaintif j' JANE E. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. STEVEN R. JONES., : CIVIL ACTION-LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, STEVEN JONES, Defendant in the above-captioned matter, do hereby certify that I have accepted service of Plaintiff's Divorce Complaint, on the ?Q day of 2008, filed to the above-captioned term and number. A?_j '442-? STEVEN JONE 5 t? •`' ` C31 t7 ? N ...c JANE E. JONES, Plaintiff, V. STEVEN R. JONES, Defendant IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 08 - 495 CIVIL ACTION -LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code 2008. 2. The marriage of the Plaintiff and the Defendant is irretrievably filed on January 23, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service o notice of intention to request entry of the decree. 4. 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. 5 4904 relating to unsworn falsification to authorities. Date: ?_.. czrz, - ? 1 S- ' j 1 't i JANE E. JONES, IN THE COURT OF COM ON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN R. JONES, Defendant No. 08 - 495 CIVIL ACTION -LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INI TO REQUEST ENTRY OF A DIVORCE DE 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. 4. I verify that the statements made in this affidavit are true and co ect. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 5 404 relating to unsworn falsification to authorities. Date: - ?- d STEVEN R. J Mi -ra JANE E. JONES, Plaintiff, V. STEVEN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA i No. 08 - 495 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code ?vas filed on January 23, 2008. 2. The marriage of the Plaintiff and the Defendant is irretrievably brol en and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I verify that the statements made in this affidavit are true and co? ect. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4004 relating to unsworn falsification to authorities. Date: C19 I mi ry7 caz? t JANE E. JONES, Plaintiff, V. STEVEN R. JONES, Defendant IN THE COURT OF CO ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08 - 495 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF IN7 TO REQUEST ENTRY OF A DIVORCE D 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 I'IProthonotary. 4. 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. § 404 relating to unworn falsification to authorities. Date: JA E E. JONES 07 r.? rW" c? "t'7 --?' r'-- !? ? ? G."7 r . .?' t?' ?...; ?. ? ?- JANE E. JONES, IN THE COURT OF COON PLEAS OF Plaintiff, CUMBERLAND COUN , PENNSYLVANIA V. STEVEN R. JONES, Defendant. No. 08-495 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(d)(1) of the Divorce Code. Court for entry of a 3301(c) or 2. Date and manner of service of the Complaint: Served by U.S. M on January 23, 2008. Acceptance of Service signed on January 28, 2008 and filed February , 2008. 3. Complete either Paragraph A. or B. A.1 Date of execution of the Affidavit of Consent required by Sec 'on 3301 (c) of the Divorce Code by Plaintiff: April 29, 2008 by Defendant: April 30, 2008 A.2 Date of filing of Plaintiff's and Defendant's Waiver of Notice of Intent: by Plaintiff: Contemporaneously he ewith by Defendant: Contemporaneously he ewith 4. Related claims pending. Please, incorporate without merging the attached Marital Settlement agreement of the parties into the Divorce Decree. B.1 Date of execution of the Plaintiff's Affidavit required under Suction 3301(d) of the Divorce Code: B.2 Date of service of Plaintiff's Affidavit upon Defendant: Date of service of Notice to Intention to Enter: Date: FOREMAN, FOREMAN & C-ARACIOLO, P.C. Bruce D. ForeHian, Esquire Attorney ID No. 21193 112 Market Street, 6"' Floor Harrisburg, Pennsylvania 17101 Tel. (717) 236-9391 bruce@ffclaw.net Attorney for Plaintiff 21 tti? rr ? s ?""` ctn. IN THE COURT OF COMMON PLEAS + + OF CUMBERLAND COUNTY + + STATE OF PENNA. + + + JANE E. JONES + NO 08 495 + Plaintiff + + + VERSUS STEVEN R. JONES + Defendant DECREE IN + DIVORCE + + + + + + `?? ! IT AND NOW, IS ORDERED AND DECREED THAT Jane E. Jones PLAINTIFF, + + AND Steven R. Jones DEFENDANT, + ARE DIVORCED FROM THE BONDS OF MATRIMONY. + THE COURT RETAINS JURISDICTION OF THE FOLLOWING C LAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT + YET BEEN ENTERED; + BY THE COURT: ?? + i ', 64 + A E T: J. + + . " l PROTHONOTARY + + + + +' 47