HomeMy WebLinkAbout08-0628
I
MARK K. ADAMS,
Plaintiff
VS.
ROSE ANN ADAMS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:No. og - (pa B CA-V, t iPr r-A
: CIVIL ACTION - AT 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 at the Cumberland County Courthouse, 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 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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
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MARK K. ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 6 F- ,?o2.t C .? _d -Tu .-
ROSE ANN ADAMS, CIVIL ACTION - AT LAW - IN DIVORCE
Defendant
DIVORCE COMPLAINT
The Plaintiff, Mark K. Adams, by and through his attorneys, the Law Offices of Patrick F.
Lauer, Jr., L.L.C., makes the following Complaint in Divorce:
COUNT I - NO-FAULT DIVORCE - §§ 3301(c) or 3301(d)
1. The Plaintiff, Mark K. Adams, is an adult individual who currently resides at 68 B
Carlisle Road, Newville, Cumberland County, Pennsylvania 17241.
2. The Defendant, Rose Ann Adams, is an adult individual who currently resides at 14
Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania 17007.
3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for
at least six months immediately prior to the filing of this Complaint.
4. The parties were married on November 23, 2003, in 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. 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.
This action is not collusive.
WHEREFORE, the Plaintiff requests this Honorable Court enter a Decree of Divorce in this
matter.
Respectfully submitted,
-'Marlin arkley, Esquire
Law Offi s of Patrick F. Lauer, Jr., L.L.C.
2108 Market Street, Aztec Building
Z Camp Hill, Pennsylvania 17011-4706
Date: /-25 ID# 84745 Tel. (717) 763-1800
MARK K. ADAMS, .
Plaintiff
VS.
ROSE ANN ADAMS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No.
CIVIL ACTION - AT LAW - IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint 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: J -"Z-4-08 Signature:/
Mark K. Adams
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MARK K. ADAMS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS. :No. 08-628 Civil Term
ROSE ANN ADAMS, : CIVIL ACTION - LAW IN DIVORCE
Defendant
PRAF,CIPE TO REIFNSTATF, DIVORCE C OMPI,AINT
TO THE PROTHONOTARY:
Kindly reinstate the Divorce Complaint in the above-captioned matter.
Respectfully submitted,
Marlin . M kley, Esquire
Law Office of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
5 L L Ob? Camp Hill, Pennsylvania 17011-4706
Date: ID# 84745 Tel. (717) 763-1800
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MARK K. ADAMS,
Plaintiff
VS.
ROSE ANN ADAMS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-628 CIVIL TERM
CIVIL ACTION - AT LAW - IN DIVORCE
NOTICE TO THE DEFENDANT
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 § 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on April 24, 2006, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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: _S/_0 ' o
Mark K. Adams, Plaintiff
Vp
MARK K. ADAMS, : IN THE COURT OF COMMON PLEAS OF
PIalntW : CUMBERLAND COUNTY, PENNSYLVANIA
:
V. : CIVIL ACTION - LAW
NO. 08 - 0628 CAVIL TERM
ROSE ANN ADAMS,
Defendant : IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION
3301(d) OF THE DIVORCE CODE
1 • Check either (a) or (b):
X (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.
(ii) 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 or expenses if I do
not claim them before a divorce is granted.
X (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
In 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 Intention to Request Divorce Decree, the divorce decree may
be entered without further delay.
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.9 18 Pa.C.S. Section 4 4 rel;wish unsworn
falsification to authorities.
MAY 30 1 2008
SE ANN ADAMS
e ry of a divorce decree and you dNOTICE: If you do not wish to oppose the to make
a claim for economic relief, you need not file this
counteraffidavit.
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HAROLD S. IRWIN, 111, ESQUIRE
ATTORNEY ID NO. 29920
64 SOUTH PITT STREET
CARLISLE PA 17013
(717) 243-6090
ATTORNEY FOR PLAINTIFF
MARK K. ADAMS,
Plaintiff
V.
ROSE ANN ADAMS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008 - 0628 CIVIL TERM
CIVIL ACTION -DIVORCE
DEFENDANT'S CLAIM FOR ECONOMIC RELIEF
NOW, comes the defendant, ROSE ANN ADAMS, by her attorney, Harold S. Irwin, III, Esquire,
and makes the following claims for economic relief:
1. Defendant requests your Honorable Court enter an award for alimony as is just and
reasonable pursuant to Section 3701 of the Pennsylvania Divorce Code.
2. Defendant requests your Honorable Court enter an order requiring plaintiff to reimburse
to defendant reasonable counsel fees, and expenses as are just and reasonable pursuant to
Section 3702 of the Pennsylvania Divorce Code.
WHEREFORE, the defendant bequests the Court to enter a Decree:
A. Dissolving the marriage between the parties;
B. Awarding alimony as the Court deems just and reasonable;
C. Ordering reimbursement of counsel fees and expenses as the Court deems just
and reasonable; and
D. For such further relief as the Court may deem equitable and just.
-.
er" I verify that the facts contained herein are true and correct. I understand that false statements
herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
2008
ROS AN ADAM
IRWIN LAW OFFICE
By: (v v? v
HAROLD S. IRWIN, III
Attorney for Defendant
Supreme Court ID No.:
64 South Pitt Street
Carlisle, PA 17013
717-243-6090
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MARK K. ADAMS,
Plaintiff
V.
ROSE ANN ADAMS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:No. 08-628 CIVIL TERM
CIVIL ACTION -DIVORCE
AND NOW COMES, the Plaintiff, Mark K. Adams, by and through his attorneys, The Law
Offices of Patrick F. Lauer, Jr., LLC, and moves the Court to appoint a Master with respect to the
following claims:
(X) Divorce
( ) Annulment
(X) Alimony
( ) Alimony Pendente Lite
and in support of the Motion states:
( ) Distribution of Property
( ) Support
(X ) Counsel Fees
( ) Costs and Expenses
1. Discovery is not complete as to the claims for which the appointment of a master is
requested.
2. The Defendant has appeared in the action by counsel Harold S. Irwin, III, Esquire.
3. The statutory grounds for divorce are 3301(c) and 3301 (d).
4. The action is contested with respect to Divorce, Alimony, and Counsel Fees.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take half of a day.
Date: August 26, 2008
Respectfully
2108 Market
Camp Hill, Pf
ID# 84745 Tel. (717) 763-1800
, Aztec Building
vania 17011-4706
I
MARK K. ADAMS,
Plaintiff
V.
ROSE ANN ADAMS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-628 CIVIL TERM
CIVIL ACTION - DIVORCE
CERTIFICATE 0 USE 1XICE
I, Marlin L. Markley, Esquire, hereby certify that on the below-noted date s d
Harold S. Irwin, III, Esquire
64 South Pitt Street
Carlisle, PA 17013
e, postage prepaid, in the United States Mail, addressed as follows:
correct , %'A VU a true and
copy of the foregoing Motion for Appointment of Master upon the following named counsel
by depositing Barn
Date: August 26, 2008
1"IZU-11 ey, Esquire
2108 Mark Street, Aztec Building
Camp Hil Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
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MARK K. ADAMS,
Plaintiff
V.
ROSE ANN ADAMS,
Defendant
IN THE COURT OF C
CUMBERLAND COI
No. 08-628 CIVIL TI
CIVIL ACTION - DI`
AUG 2 7 2008
6
4ON PLEAS OF
, PENNSYLVANIA
ORDER
AND NOW, this R day of 2008, E ROBERT
FLICKER, II, is hereby appointed Master in Divo e.
BY THE F ?
1
Distribution:
Varlin L. Markley, Esq., 2108 Market St., Camp Hill, PA 17011
Xarold S. Irwin, III, Esq., 64 South Pitt Street, Carlisle, PA 17013
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MARK K. ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
NO. 2008 - 0628 CIVIL TERM
ROSE A. ADAMS, ;
Defendant : IN DIVORCE
PETITION FOR RULE TO SHOW CAUSE
NOW comes Harold S. Irwin, III, Esquire, attorney for plaintiff, and presents this petition for a
rule to show cause, representing as follows:
1. Petitioner is HAROLD S. IRWIN, III, attorney for plaintiff, with offices at 64 South Pitt
Street, Carlisle, Cumberland County, Pennsylvania 17013.
2. Respondents are MARK K. ADAMS, an adult individual, whose attorney of record is
Marlin L. Markley, Esquire, with offices located at 2108 Market Street, Camp Hill, Cumberland
County, Pennsylvania 17011, and ROSA A. ADAMS, an adult individual residing at 14 Shirley
Lane Boiling Springs, Cumberland County, Pennsylvania 17007..
3. Petitioner has represented the defendant in this matter since sometime in 2006.
4. At plaintiff's request, the Master has scheduled a conference for February 12, 2010
regarding defendant's request for alimony.
5. Irreconcilable differences have arisen between the defendant and petitioner, defendant
has suspended the payment of fees due fro her to the petitioner and, despite repeated requests
by the petitioner, nothing has been paid by or on behalf of defendant since December, 2008.
6. Petitioner believes and therefor avers that neither party will be prejudiced by petitioner's
withdraw, should this Court grant petitioner's request.
7. No judge has been involved in this case to date.
WHEREFORE, petitioner requests your Honorable Court to enter a rule upon the respondents
to show cause why petitioner should not be permitted to withdraw from this case as counsel for
plaintiff.
December 23, 2009
HAROLD S. IRWIN, III t
Petitioner \ J
64 South Pitt Street
Carlisle, PA 17013
717-243-6090
Supreme Court ID No. 29920
VERIFICATION
The foregoing petition is true and correct to the best of my knowledge, information and belief. I
understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A.
Section 4094, relating to unsworn falsification to authorities.
December 23, 2008
HAROLD S. IRWIN, III
Petitioner
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HAROLD S. IRWIN, 111, ESQUIRE
SUPREME COURT ID NO. 29920
64 SOUTH PITT STREET
CARLISLE, PA 17013
717-243-6090
ATTORNEY FOR DEFENDANT
MARK K. ADAMS,
Plaintiff
V.
ROSE A. ADAMS,
Defendant
: IN THE COURT OF COMMON
: CUMBERLAND COUNTY, PEN
: CIVIL ACTION - LAW
: NO. 2008 - 0628 CIVIL TERM
: IN DIVORCE
DEC 3 0 20Uy(7
ORDER OF COURT
NOW, this day of I , 2Qa, on petition of Harold S. Irwin, 111, E
rule is hereby issued upon the parties, MARK K. ADAMS and ROSE A. ADAMS, to
why petitioner should not be permitted to withdraw as counsel for plaintiff.
Rule returnable days after the date of this order. Service to be by cri
upon plaintiffs attorney of record and upon defendant.
By the Co ,
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OF THE PRO ffU40TARY
HAROLD S. IRWIN, 111, ESQUIRE
SUPREME COURT ID NO. 29920
64 SOUTH PITT STREET
CARLISLE, PA 17013
717-243.6090
ATTORNEY FOR DEFENDANT
2010 FEB -S PM 3: 13
C MDSE IA' ND CQIJW" '
PaASYLVANIAMARK K. ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
NO. 2008 - 0628 CIVIL TERM
ROSE A. ADAMS, .
Defendant : IN DIVORCE
PETITION TO MAKE RULE ABSOLUTE
NOW comes petitioner, Harold S. Irwin, III, Esquire, attorney of record for the defendant and
presents this petition to make the rule absolute, representing as follows:
1. On January 4, 2010, petitioner obtained a rule upon the parties to show cause why
petitioner should not be permitted to withdraw as counsel for defendant.
2. Said rule was made returnable twenty (20) days of service by certified mail upon
counsel for the plaintiff and upon defendant.
3. Service of said Rule was made upon the plaintiff's new counsel, Patrick F. Lauer,
Esquire, on January 14, 2010, by certified mail addressed to him at 2108 Market Street, Camp
Hill, PA 17011. A copy of the signed receipt is attached hereto as Exhibit "A".
4. Service of said Rule upon the defendant was made upon the defendant on January 7,
2010, by certified mail addressed to her at 14 Shirley Lane, Boiling Springs, PA 17007. A copy
of the signed receipt is attached hereto as Exhibits "B".
5. More than twenty (20) days have elapsed since service of the petition and rule as
aforesaid, but neither party has filed a response to the petition and rule.
WHEREFORE, petitioner requests that your Honorable Court make the rule issued upon the
parties absolute and in accordance therewith permit petitioner to withdraw as counsel for the
defendant..
iJ
February 5, 2010
HAROLD S. IRWIN, III
64 South Pitt Street
Carlisle, PA 17013
717-243-6090
Supreme Court ID No. 29920
VERIFICATION
I verify that the statements made in the above petition are true and correct. I understand that
false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unswom falsification to authorities.
February 5, 2010
64'4-0;??
HAROLD S. IRWIN, III
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2108 MARKET STREET
CAMP HILL PA 17011
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EXHIBIT "B"
HAROLD S. IRWIN, III, ESQUIRE
SUPREME COURT ID NO. 29920
64 SOUTH PITT STREET
CARLISLE, PA 17013
717-243-6090
ATTORNEY FOR DEFENDANT
110IDFEB 9 ply 4; 04
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FEB 082010,
MARK K. ADAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
: NO. 2008 - 0628 CIVIL TERM
ROSE A. ADAMS,
Defendant : IN DIVORCE
ORDER OF COURT
NOW this j?ty of February, 2010, on petition of Harold S. Irwin, 111, Esquire, the rule
issued upon the parties to show cause why petitioner should not be permitted to withdraw as
counsel for defendant is hereby made absolute and leave to petitioner to withdraw as counsel is
granted.
J.
C o-? -s , LAC
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MARK K. ADAMS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNVLVAIIA_?
NO. 08 - 628 CIVIL _.l 2
s.?
-77
ROSE ANN ADAMS, r.j -i t
Defendant IN DIVORCE
NOTICE OF FILING MASTER'S REPORT •• `-'mss
The report of the Master has been filed this date ands
copies have been sent with this notice to counsel of record and
the parties.
In accordance with P.R.C.P. 1920.55 within twenty (20)
days after the mailing of this notice and report exceptions may
be filed to the report by any party. If no exceptions are
filed within the twenty (20) day period, the Court shall
receive the report, and if approved, shall enter a final decree
in accordance with the recommendations contained in the report.
Date: 4/29/10
E. Robert Elicker, II
Divorce Master
NOTE: If exceptions are filed, file the original with the
Prothonotary and a copy with the Master's office. At
that time, the party filing the exceptions should
notify the court reporter in the Master's office so
arrangements can be made for a transcript. Upon
completion of the transcript and receipt of payment,
the entire file will be returned to the
Prothonotary's office for transmittal, to the Court at
time of argument on the exceptions.
If no exceptions are filed, counsel shall prepare an
order of Court consistent with the recommendations
and provide a proposed order of Court. to the Master.
Counsel shall also prepare and provide with the
proposed order of Court a praecipe* to the
Prothonotary directing the Prothonotary to submit the
case to the Court for final disposition. The Master
will then transfer the file with the proposed order
of Court and praecipe to the Prothonotary's Office
for docketing and transmittal by the Prothonotary to
the Court.
* Form available in the Prothonotary's office and the
Master's office. (NOT the praecipe to transmit the
record form as set out in P.R.C.P. 1920.73(b).)
MARK K. ADAMS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
C7 a ;
VS. NO. 08 - 628 CIVIL
ROSE ANN ADAMS, 111F=
Defendant IN DIVORCE '
MASTER'S REPORT -°
Today is Wednesday, April 28, 2010. Thi-s S
v
the date set for a hearing in the above-captioned divorce
proceedings.
Present in the hearing room are the
Plaintiff, Mark K. Adams, and his counsel Patrick F. Lauer,
Jr. The Defendant, Rose Ann Adams is not present.
The complaint in divorce was filed on January
29, 2008, raising grounds for divorce of irretrievable
breakdown of the marriage. No economic claims were raised
in the complaint.
On May 7, 2008, an affidavit under Section
3310(d) was filed averring a separation in excess of two
years, since April 24, 2006. The Defendant, wife, filed a
counter-affidavit on May 30, 2008, indicating that she did
not oppose the entry of a divorce decree; however, she
stated that she wished to raise economic claims.
On July 11, 2008, wife filed a claim for
alimony and counsel fees and expenses. Neither party
raised a claim for equitable distribution.
On January 5, 2009, the Master had a
1
conference with counsel for both parties. At that time the
issue regarding wife's health was raised along with her
ability to work. Counsel discussed having wife evaluated.
The Master heard nothing further until an
order was entered on February 9, 2010, allowing counsel for
wife to withdraw. Counsel for husband in the meantime asked
the Master to schedule another conference.
On February 12, 2010, the Master had a
conference with counsel for the Plaintiff, and present at
that conference also was the wife. Wife indicated at that
time that she wished to pursue her claims raised for
economic relief and the Master advised wife to inform the
Master's office as to evidence that she wished to present
regarding her alleged disability claims and evidence
regarding her inability to obtain employment. The Master
had suggested at one point in the process that wife perhaps
be evaluated by a vocational expert.
The direction to wife to provide evidence
regarding her inability to work was
conference on January 5, 2009, and
on February 12, 2010. This action
considerable period pending receipt
regarding her employment status and
to present at a hearing.
stated to counsel at the
Later at the conference
languished for a
from wife of information
evidence that she wished
At the conference on February 12, 2010, the
2
Master set a hearing date for April 28, 2010, as the time
and place where wife should appear to present testimony
which she wished to offer on the record regarding her
economic claims.
We have convened the hearing and have waited
until approximately 9:20 a.m. to begin the proceedings
today. The hearing was scheduled and notices were provided
stating that the hearing was to be held on April 28, 2010,
at 9:00 a.m. At the time that wife appeared at the last
conference, she was handed a copy of the notice by the
Master's office, so there was no question as to whether or
not she received notification of the time and date of the
hearing for today.
Wife has not provided any of the evidence
which the Master and counsel and wife had discussed
previously at the conferences held, nor has she appeared
today to pursue any claims raised in the proceedings.
RECOMMMATION
The Master finds that the parties have been
separated for a period in excess of two years and that based
on husband's affidavit under Section 3301(d), husband is
entitled to a divorce.
The claims raised by wife for alimony and
counsel fees and expenses are denied for the reasons set
3
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forth in the above statement of the proceedings as they
occurred in the Master's office and because of wife's lack
of appearance for the hearing on April 28, 2010.
A notice of the filing of the Master's report
will be sent to Mr. Adams at 50 Oxford Road, Gardners, PA
17234 and to his counsel, and to the Defendant, Rose Ann
Adams. The address we will use for wife is the address that
we have previously used as 14 Shirley Lane, Boiling Springs,
PA 17007.
Respectfully submitted,
E. Robert Elicker, II
Divorce Master
4
1
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
l CIVIL DIVISION
. ?L ?? I?L1?{} lY1 NO. CIVIL TERM
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 § (3301(c)) and
t? s
§ (3301(d)(1)) of the Divorce Code. oz?
out inapplicable section.)
Date and manner of service of the complaint:
IT)A
Y
Complete either paragra h (a) or (b).
(a) Date of execution of the affidavit of consent required by § 3 301(c) of thy;
Divorce code:
by plaintiff ; by defendant
(b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code:
(2) Date of filing and service of the plaintiffs § 3301(d) affidavit upon the
respondent opposing arty: M
4. Related claims pending:
- m c
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file praec:ipe to transmit
record, a copy of which is attached:.? 2 i I 7c y/0
(b) Date plaintiff's Waiver of Notice was filed with the Prothonotary:
Date defendant's Waiver of Notice was filed with the Prothonotary:
`? Attorney Tor Plain iff/Deferidant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MARK K. ADAMS
V.
ROSE ANN ADAMS
NO. 08-628
DIVORCE DECREE
r, 3'03f
AND NOW, it is ordered and decreed that
MARK K. ADAMS , plaintiff, and
ROSE ANN ADAMS
bonds of matrimony.
defendant, are divorced from the
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
?NJ E
By the ,
Attest: J.
joy
(? ZD t. UIELL, rothonotar
• t o oh-re A 'r°ef
vr?a'?A? 1`v
:": T. 1i C S%. OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IMARI<
K ?Id??ns
Plaintiff
vs.
"'-Wosc A fidfts
Defendant
FILE NO.
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
20
a
6. ? 0
w
Notice is hereby given that the Plaintiff/Defendant in the above matter, having
been granted a Final Decree in Divorce on the 0 day of r -.e- 02
hereby elects to resume the prior surname of /DOSE A u u OA f oAl ,
and gives this written notice pursuant to the provi ' P.S. 04.
l kA
DATE: 143 bp ?
5 Signature °Z d /S7? y
? / v ' (/1?
name being resumed
COMMONWEALTH OF PENNSYLVANIA :
. SS.
COUNTY OF CUMBERLAND
On the
/-? day of Fi /??? y , 20 J? , before me, a
Notary Public, personally appeared the above affiant known to me to be the person whose name
is subscribed to the within document and acknowledged that he/she executed the foregoing for the
purpose therein contained.
In Witness Whereof, I have hereunto set my hand and official seal.
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