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Home My WebLink About08-0989r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE VS. NO. 9Fq Grf, l f c?M ROBERT L. MASK, , Defendant , 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, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE VS. NO. 6g'- 9 ?y L? ?' ?`cinn ROBERT L. MASK, Defendant COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DOMESTIC RELATIONS CODE AND NOW, comes Plaintiff, BEVERLY K. MASK, by and through her attorney, Fiona K. Line, and files the following Complaint in Divorce, and in support thereof avers as follows: 1. Plaintiff is Beverly K. Mask, an adult individual, who currently resides at 1550 Yorkshire Place, Enola, Cumberland County, Pennsylvania 17025 since December 16, 2006. 2. Defendant is Robert L. Mask, an adult individual, who currently resides at 153 North East Street, Carlisle, Cumberland County, Pennsylvania since November 12, 2007. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 9, 1990 Sharon, Pennsylvania. 5. The Plaintiff and Defendant were separated on or about November 12, 2007. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The Plaintiff and Defendant are not members of the armed forces of the United States or any of its allies. 8. The Plaintiff avers that the marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. The Plaintiff does not desire counseling. 10. Plaintiff requests the Court to enter a decree of divorce. Dated: 2-10-09 f-'X F 0NA KIMBERLY-'LINE Attorney ID 65283 Attorney for Plaintiff 184 Virginia Ave. Carlisle, PA 17013 (717) 991-1382 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE VS. NO. 0?- qS LNtI ???? ROBERT L. MASK, Defendant VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. This Verification is made only as to the factual averments contained herein, and not to legal conclusions and averments authorized by counsel in her capacity as attorney for the party or parties hereto. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 7)( 4?? k B VERLY K. SK ? W ol? C ? ,.I w A e, } C) Po o O r Cp ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE VS. NO. 08-95Q Civil ROBERT L. MASK, Defendant CERTIFICATE OF SERVICE AND NOW, this 12TH day of March, 2008, I, Fiona K. Line, Attorney for Plaintiff, hereby certify that I have this day served the following person with a copy of the foregoing Complaint, by depositing same in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, and one United States Mail, First Class Mail, Postage Prepaid addressed as follows: Robert L. Mask 153 N. East Street Carlisle, PA 17013 Fiona'K. Line Attorney for Plaintiff 184 Virginia Ave. Carlisle, PA 17013 (717) 991-1382 a ? .?, r°" m? r 7 '= m f CO .{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE VS. NO. 08-94 Civil ROBERT L. MASK, Defendant ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint under Section 3301(c) or 3301(d) of the Domestic Relations Code. I certify that I am the Defendant named in the above-captioned action in Divorce. " '?". I- L DATE ' ROBERT L. MASK, Def ndant 215-5 L MAILING ADDRESS C ° N -? -Cl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE 9 ?`l VS. NO. 08-9zA Civil ROBERT L. MASK, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on February 11, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce. 4. 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. 5. I understand that the costs of these proceedings will be paid for by Plaintiff. 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. Section 4904 relating to unsworn falsification to authorities. Date: (IL 11.2 Aut,,t? 'e- / X"C.• I VERLY K MASK C C .... " R Co -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE 9 VS. NO. 08-9?5$ Civil ROBERT L. MASK, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) 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. 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. Section 4904 relating to unsworn falsification to authorities. Date: Q VERLY K. TASK r-j C C=p q?{ 9 C'?C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE VS. NO. 08-4,5$ Civil ROBERT L. MASK, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on February 11, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce. 4. 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. 5. I understand that the costs of these proceedings will be paid for by Plaintiff. 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. Section 4904 relating to unsworn falsification to authorities. Date : o /. ROBERT L. MASK N ?? 4 7 3 f ,;3 ("` s ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE VS. 909 NO. 08-F-5t Civil ROBERT L. MASK, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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. 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. Section 4904 relating to unsworn falsification to authorities Date :? _0 9 Aof T -T ROBERT L. MASK C) o cz '?-- [T? r"` Tyr MM i: ,.. ,:.. _T ? M? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY K. MASK, CIVIL ACTION--LAW Plaintiff IN DIVORCE 4° l VS. NO. 08-96f Civil ROBERT L. MASK, . Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c)(1) of the Divorce Code. 2. Date and manner of service of the complaint: United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, and one United States First Class Mail, Postage Prepaid addressed as follows: Rober L. Mask, 153 North East Street, Carlisle, PA 17013. Signed Acceptance of Service dated June 09, 2008. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff: June 20, 2008; by defendant June 9, 2008 v' , • (b)(1) Date of execution of the affidavit required by 3301(d) of the Divorce Code: N/A; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: N/A. 4. Related claims pending: NONE 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: N/A (b) Date plaintiff's Waiver of Notice was filed with the prothonotary: July 2, 2008 Date defendant's Waiver of Notice was filed with the prothonotary: July 2, 2008 C Date: 47 2 d H- Iona K mberly Line Attorney for Plaintiff ID # 65283 184 Virginia Ave. Carlisle, PA 17013 (717) 991-1382 ?- 71 C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BEVERLY K. MASK -?` PLAINTIFF No. 08-9.8'9 CIVIL TERM VERSUS ROBERT L. MASK DEFENDANT DECREE IN DIVORCE AND NOW, 2008 , IT IS ORDERED AND DECREED THAT BEVERLY K. MASK PLAINTIFF, AND ROBERT L. MASK 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: -'?f ?" / ATTEST /1 PROTHONOTARY 5a `hl-Z- 47 /;./ a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff n , Vs File No. Q g - q N '(jV'k, IN DIVORCE (Z o b?.r ? ?a s ? Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of l CZ , and ',gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 7704. Date: -U - I Ei - 09 9L-r-;? Si ure c?c Cf? Signature of n e being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF 6a .bcr/"d ) On the /5- day of , 200 q, before me, the Prothonotary or the 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 hereunto set my hand and official seal. Notary Public N ARUIL SEAL PROTHONO ARY, NOTARY PUBLIC CARLISLE CUMBE D COUNTY COURTHOUSE MY COMMISSION' EXPIRES JANUARY 4, 2010 FILED--A '-iU"E OF THE P ?rE'?'?7ARY 2009 JUH 15 AN 11: 4 0 I"Li YtViJC?u^.4 C?sG ,eA I ,? ? ( YS No C-0 °Ce G? j