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HomeMy WebLinkAbout08-0561Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Harry I. Morris, Jr., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. /r NO. © S _ .56 1 c?c ?n? ? ?• Janice Morris, 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 Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Harry I. Morris, Jr., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. . NO. Ok- S& t CZL1Y -T-ell Janice Morris, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, Harry I. Morris, Jr., by and through his attorney, Anthony J. Foschi, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, Janice Morris, upon the grounds hereinafter set forth. 1. Plaintiff is Harry I. Morris, Jr., an adult individual, who currently resides at 590 Lucinda Lane Mechanicsburg, PA 17055. 2. Defendant is Janice Morris an adult individual, who currently resides at 6336 Galleon Drive, Mechanicsburg PA 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 19, 1988, in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that he/she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. 2 WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce dissolving the marriage between the parties. DATE: a??v Respectfully submitted, ANTHONY J. FOSCHI, ESQUIRE Supreme Court I.D. No. 55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff 3 • VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce 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: 24 Harry I. Morris, Jr., Plai :207301 4 ?_ti rya o ? Oj \ Lk) LU ' { -.. G t'.. V 5 it 1% Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 7634121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Harry 1. Morris, Jr., Plaintiff V. Janice Morris, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. D ?(o G J ?i° ?tra. IN DIVORCE AFFIDAVIT OF SERVICE OF DIVORCE COMPLAINT I, Anthony J. Foschi, Esquire, being duly sworn according to law depose and say that on January 26, 2008, 1 served a Complaint In Divorce upon Defendant Janice Morris by depositing a true and correct copy of same in the possession of the United States mail, certified mail, return receipt requested, addressed at 6336 Galleon Drive, Mechanicsburg, Pennsylvania 17050. A copy of the signed return recej# card is attached hereto. DATE: May 5, 2008 ANTHONY J. FOSCHI, ESQUIRE Supreme Court ID # 55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff :210726 ¦ Complete items 1, 2, and 3. Also complete nature item 4 if Restricted Delivery is desired. Agent ¦ Print your name and address on the reverse 11 Addressee so that we can return the card to you. B. by (Printed Name) C. of Delivery ¦ Attach this card to the back of the mailpiece, or on the front If space permits. Af AF D. Is delivery adds atfrtini item`fi't 1. Article Addressed to: If YES, ent dress below:_,4, l Janice Moms 6336 Galleon Drive 3 Service T Mechanicsburg, PA 17050 scertitied mail ? Registered NO Return Receipt for Merchandise ? Insured Mail (7 C.O.D. 4. Restricted Delivery? (Extra Fee) O Yes 2. Article Numbed 7006 215 ? 0 3 854't 1417 , (rmnsfer from service laben PS Form 3811, February 2004 Domestic Return Receipt 102595-02-Wl540 ?? `rs ?..? ? ? u ` j ?r V? A t ? ? '` .: s'r ?? Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Harry I. Morris, Jr., Plaintiff V. Janice Morris, Defendant : IN THE COURT OF COM : CUMBERLAND COUNT CIVIL ACTION - LAW NO. 08-561 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the D January 24, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably days have elapsed from the date of filing and service of the Com 3. 1 consent to the entry of a final Decree In Divorce after NON PLEAS OF ', PENNSYLVANIA Code was filed on and ninety (90) ice of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and that false statements herein are made subject to the penalties of 18 relating to unsworn falsification to authorities. DATE: April 28, 2008 Harry I. Mo Drrect. I understand 'a.C.S. §4904 w?wcc ?a Jr. 1 :207294 ?` ? s??:.-; s. ` N ??'.. : _"' =' : ,yG Q t -4 r-" .,` Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Harry I. Morris, Jr., : IN THE COURT OF COM : CUMBERLAND COUNT' Plaintiff CIVIL ACTION - LAW V. . NO. 08-561 Janice Morris, Defendant IN DIVORCE /ER OF NOTICE OF INTENTION TO REQUI ENTRY OF A DIVORCE DECREE UNDER 1. I consent to the entry of a final Decree In Divorce MON PLEAS OF (, PENNSYLVANIA notice. 2. 1 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 ranted. 3. 1 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 immediat ly after it is filed with the Prothonotary. f I verify that the statements made in this Waiver of Notice are understand that false statements herein are made subject to the §4904 relating to unsworn falsification to authorities. DATE: April 28, 2008 1. Morris, Jr. and correct. I Ries of 18 Pa.C.S. :207299 C? -77 _ ..F CD ' 4 Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakervAlliams.com Attorney for Plaintiff Harry 1. Morris, Jr., Plaintiff V. Janice Morris, Defendant : IN THE COURT OF COMI : CUMBERLAND COUNTN CIVIL ACTION - LAW NO. 08-561 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divo January 24, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably days have elapsed from the date of filing and service of the Complai 3. 1 consent to the entry of a final Decree In Divorce after se ON PLEAS OF PENNSYLVANIA Code was filed on and ninety (90) of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and that false statements herein are made subject to the penalties of 18 relating to unsworn falsification to authorities. DATE: April 28, 2008 rris I understand C.S. §4904 :207298 n rv !? ! I 4 ` I Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Harry I. Morris, Jr., : IN THE COURT OF G : CUMBERLAND COU Plaintiff CIVIL ACTION - LAW V. NO. 08-561 Janice Morris, . Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUI ENTRY OF A DIVORCE DECREE UNDER 1. I consent to the entry of a final Decree In Divorce NON PLEAS OF r, PENNSYLVANIA ut notice. 2. 1 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 ranted. 3. 1 understand that I will not be divorced until a divorcedecree 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. y. t L I verify that the statements made in this Waiver of Notice are e 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: April 28, 2008 Jan :207300 :4-? ?' ?=.? ?? _n ... , -r i ? ? -„? rl' :;::„? r???rq -T `I_-? { ?.Z ':7 a. ;?? _:. ,, a :? CJ ? `w"3 -».:. Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Harry I. Morris, Jr., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . CIVIL ACTION - LAW V. NO. 08-561 Janice Morris, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to he Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Secti n 3301(c) or 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: January 6, 2008 by certified mail. See attached signature card. 3. Date of execution of the Affidavit of Consent required b Section 3301(c) of the Divorce Code: By Plaintiff on April 28, 2008; by Defendant on Ap it 28, 2008. 4. Related claims pending: None 5. Date Plaintiffs Waiver Of Notice was filed with the 2008. 6. Date Defendant's Waiver Of Notice was filed with the P 2008. ly submitted DATE: H- Z&-ag ANTHONY J. FOSCHI Supreme Court ID # 5! 3425 Simpson Ferry R Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwillk Attorney for Plaintiff April _, ry: April _, ESQUIRE s.com :207303 :_CJ f`J ` ? t3 LT' rrt i? ? ?'?? Ul IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff No. os-561 VERSUS Janice Morris Defendant DECREE IN DIVORCE AND NOW, IM ?" t' , 2008, IT IS ORDERED AND DECREED THAT Harry I. Morris, Jr. , PLAINTIFF, AND Janice Morris , 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; None. BY THE COURT: PROTHONOTARY ,???s '?'"?' .? . -? ?..