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
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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
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Postage $
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a Certified Fee
C3 Postmark
O Return Receipt Fee Here
(Endorsement Required)
C3 Restricted Delivery Fee
C] (Endorsement Required)
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Total Postage & Fees
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O Sent TO
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Street ilpt. No.;
or PO Box No.
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¦ 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
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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?-
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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
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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
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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
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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
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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
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