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HomeMy WebLinkAbout08-0520FRIEDMAN & KING, P.C. John F. King, Esquire ID #61919 3820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 Attorney for Plaintiff RICHARD J. CORISH, JR. Plaintiff V. ANGELA DIANE CORISH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. b$ - ab Civil term CIVIL ACTION -LAW : 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 Respectfully submitted, FRIEDMAN & KING, P.C. B J LFK ing, Esquire 3820 Market Street Camp Hill, PA 17011 (717) 236-8000 FRIEDMAN & KING, P.C. John F. King, Esquire ID #61919 3820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 RICHARD J. CORISH, JR. Plaintiff V. ANGELA DIANE CORISH Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. v F - S Cush ?i`"'" CIVIL ACTION -LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Richard J. Corish, Jr. who currently resides at 395 N. 19th Street, Cumberland County, Camp Hill, PA, 17011. 2. Defendant is Angela Diane Corish, who currently resides at 395 N. 19`h Street, Cumberland County, Camp Hill, PA 17011 / 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 20, 2006, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Date: c? FRIEDMAN & KING, P.C. John 'T. King, Esquire 3820 Market Street Camp Hill, PA 17011 (717) 236-8000 VERIFICATION I, Richard J. Corish; hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 45chard J. C '&-, Dated: January 2-1 , 2008 (l r--) 7 ) n t.7 } ? a , c FRIEDMAN & KING, P.C. John F. King, Esquire ID #61919 3820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 RICHARD J. CORISH, JR. Plaintiff V. ANGELA DIANE CORISH Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS: Personally appeared before me, a Notary Public, in and for said Commonwealth and County, John F. King, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, by Certified Mail, Restricted Delivery, on January 26, 2008, as evidenced by the attached Certified Mail card. / Sworn and subscribed to before me this t day of , 2008. Notary Pub COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL. SHARR`( 0. SEMANS, Notary Pubfic City of Harrisbu , Dauphin County a _. CERTIFICATE OF SERVICE I hereby certify that I am this 25th day of January, 2008 serving the foregoing divorce complaint upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by Certified Restricted Mail addressed as follows: Angela Diane Corish,\ 395 N. 19th Street, Camp Hill, PA 17011 S arry Semans I CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Providec h1110 6. L M Postage $ Ln a Certified Fee C3 Postmark O Return Receipt Fee Here (Endorsement Required) C3 Restricted Delivery Fee C] (Endorsement Required) r- O Total Postage & Fees ..D O Sent TO Q tti Street ilpt. No.; or PO Box No. C-- Stet-. ZI-P+4 ----°°--°°------------------------°°------------ ity, ¦ Complete ibeme 1, 2, and 3. Also oomplete iten 4 If Restricted Dellmy Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. s Attach this card to the back of the mailplaw, or on the front H apace pemllits. 1. Amide Addressed to: 395`` 1 ` Sff P14 1-7011 A. Sipnaarre X •, i ? _?n u- )-- 19 Rscelved by jPdnW Name) c? , ddo D. Is daIlmy address di(feren Tram Item 1? U Yer if YEs. enter dsuvery address below: ? No a Ssrvios lype @'Earlflsd Mal O Bpm Mau ? Repistered ? Retrun Reoelpt for Merctwtdlaa ? hwxed Mal ? C.O.D. 4. Reatrictsd Deutbry? (Exfra Fee) trYas 2. 7006 0100 0005 104'0 3249 t>twtalrAan++n?._. PS Form 3811, February 2004 Do rwuc Ra4rn Rsodpt 1025WW-W1W f =) _71 i._., RICHARD J. CORISH, JR. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-520 ANGELA DIANE CORISH CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 23, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 of Notice of Intention to Request Entry of the Decree. 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. § 4904 relating to unworn falsification to authorities. DATED: C) G Richard J. C , Jr., Plaintiff T?- CD w RICHARD J. CORISH, JR. Plaintiff V. ANGELA DIANE CORISH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-520 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) OF THE DIVORCE CODE 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 correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date:_f r, C? ?- ?.? ? j ?' --, --? ? ` ? -?-` ?.? ti? :a ? ? ? ... ?. - i ?? ?,....? E?.? ..? RICHARD J. CORISH, JR. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-520 ANGELA DIANE CORISH CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 23, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed_ rom the date of 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. 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. § 4904 relating to unsworn falsification to authorities. DATED: Ll g Angela Diane Corish, Defendant ?;!t ? 3i '- _ 1?? 4? ?.J .t?c+ 1 `? - .. ?ti' .N? ;`+.? krF -4, RICHARD J. CORISH, JR. Plaintiff V. ANGELA DIANE CORISH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-520 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) OF THE DIVORCE CODE 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 correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: q,/ /,-) k Angela Diane Corish, Defendant py rO l V FRIEDMAN & KING, P.C. John F. King, Esquire ID #61919 3 820 Market Street Camp Hill, PA 17011 Tel.: (717) 236-8000/Fax: (717) 236-8080 Attorney for Plaintiff RICHARD J. CORISH, JR. Plaintiff V. ANGELA DIANE CORISH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-520 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: Code. mail 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of the complaint: January 26, 2008, certified restricted 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff April 28, 2008; by Defendant April 28, 2008. 4. Related claims pending: There are no related claims pending. 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: (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: April 29, 2008 Date Defendant's Waiver of Notice was filed with the Prothonotary: April 29, 2008 rtto F.King, Esquire rney for Plaintiff f?"7 ^a r`- ^.? c?? ?J _ .... Ct? ! ? 'r ?+'? ? r. _ ?, A 3`?s ?? -? .°?7 -. -? f,.,,??.? ?1 " i 1 ? ... ,. -. C?.? :: ?? <:J.3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Richard J. Corish, Jr. ii VERSUS Angela Diane Corish No. 08-520 DECREE IN DIVORCE AND NOW, l'1 Z $ X11 IT IS ORDERED AND DECREED THAT Richard JT Corish Tr_ PLAINTIFF, AND Angela Diane Corish 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; BY THE CO PROTHONOTARY -, 0 4 e ----> / V- ? , P, W-4 .} 4b 4. - -" '