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HomeMy WebLinkAbout08-1375r flu ORIGINAL Barbara R. Cotton IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08-13'7N5 CIVIL TERM Anthony J. Cotton 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 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, 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 i .,-" ? - ft Barbara R. Cotton Plaintiff V. Anthony J. Cotton Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- CIVIL TERM : IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is J? rn k?, O .Olt, who currently resides at 1 h „ i._ j. Cumberland County, Pennsylvania. 2. Defendant i _ n n/ D- (SJ'L+Q(\-, who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on I r b h /3 -G-W ) at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. ? •t ar 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plaintiff, Pro Se 1, P, C t&\-Verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Q- 2'7- 0S Date: Plaintiff, Pro Se Assisted by: Diane Radcliff, Esq. Law Firm of Diane Radcliff 3448 Trindle Road Camp Hill, PA 17011 (717) 737-0100 ORIGINAL Barbara R. Cotton Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 1' 57) CIVIL TERM Anthony J. Cotton Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Barbara R. Cotton, Plaintiff, to proceed in forma ap uperis. I, Diane Radcliff, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. ttorne?for??ti7i Law Firm of Diane Radcliff 3448 Trindle Road Camp Hill, PA 17011 (717) 737-0100 „IQ ?} "?N s BARBARA R. COTTON : Plaintiff . V. ANTHONY J. COTTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1375 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on March 7, 2008, 1 served a true and correct copy of the Complaint in Divorce upon Anthony J. Cotton, the Defendant, by Certified Mail, Restricted Delivery, addressed as follows: Anthony J. Cotton 59 Conrad Drive Carlisle, PA 17013 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. RA CLIFF, ESQUIRE 3 e Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff d 1k T4.1.1 ... 1-1. 1 ... I .. f. i.. I. I. I.It...... at f ¦ Complete ltern 1, 2, and 3. Also complete 'item 4 If Restricted Delivery Is desired. ¦ Print your name and address on'" reverse so that we Gan return the card to; you. ¦ Attach this card to the back of the malipiece, or on the front if space permits. 1. Article Addressed to: ?y ,5_9 C'o?rZ-4-b 04. ?i L? SIB Aq lqQ/-3 A. S re / ' 1/ 171 Agent X 1'7 I WI-1 (, ?i%b anaW ?tfoel (Ai ) of DaNvVy DN 7 C. Dar i-°S is delivery address(cimarent from Item 1? ? Yes If YES. enter delivery address below: ? No 3/BGC?errifleType Mall ? Express Mail d ? Registered ? Return Receipt for Merchandise ? insured Mail ? C.O.D. +4. . 2. Article Number 7005 0390 0003 2641 5599 (liansAl? flan serrlce Aet?,. PS Form 3811, February 2004 Domsedc Retrxn Receipt 102595-02-M-1 sac EXHIBIT "A" CERTIFIED MAIL RETURN RECEIPT CARD c? '`? ?? i ?,., J'?- r Lw ? + 7 ? ?t' ?, 1 ?r '"'? s-? ?"' r ? - -_'.7 -? , ? 1 .?, - >a '`. ?... Barbara R. Cotton Plaintiff V. Anthony J. Cotton Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08-)3?) CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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 - Signature: ?0/7a,? 6 ©/? Anthony J. Cott V, Defendant c=+ ,?. ?. ",.?„ ..? ? <4? . -y c., ?? ?' ? ..? .., Barbara R. Cotton Plaintiff V. Anthony J. Cotton Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08-/3 75 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 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: Signature: ??07 Anthony J. Cotto , Defendant C? `"'' C c. 71, ;; _ ..' j'TA Barbara R. Cotton Plaintiff V. Anthony J. Cotton Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- / 37 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on a 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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 unswom falsification to authorities. Date: ('? l 40E? Signature: Barbara R. Cotton, Plaintiff w ? ?, ??: c:- ?? , x ? ' ?- x r- r? ; t_ -?s =? ?} -' €t "=` r? Barbara R. Cotton IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.08-/ 37 j CIVIL TERM Anthony J. Cotton Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 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 V Signatur? ? E- ?&JtQcoy?- Barbara R. Cotton, Plaintiff L BARBARA R. COTTON Plaintiff V. ANTHONY J. COTTON TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-1375 CIVIL TERM : IN DIVORCE PRAECIPE OF TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: 3/3/2008 b. Manner of Service of Complaint: Certified Mail/Restricted Delivery C. Date of Service of Complaint: 3/7/2008 3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: a. Plaintiff: 6/14/2008 b. Defendant: 6/10/2008 4. RELATED CLAIMS PENDING: No issues are pending. No issues have been raised in this case, and there are no issues outstanding. 5. DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE PROTHONOTARY: a. Plaintiff's Waiver: 6/19/2008 b. Defendant's Waiver: 6/17/2008 DIANE G.AfDCLIFF, ESQUI 3448 Trindle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 A .. 41 T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BARBARA R. COTTON, Plaintiff VERSUS ANTHONY J. COTTON, N O. 08-1375 CIVIL TERM Defendant DECREE IN DIVORCE AND NOW, c? 444 1 - '2008 , IT IS ORDERED AND DECREED THAT BARBARA R. COTTON , PLAINTIFF, AND ANTHONY J. COTTON 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; No issues have been raised in this case, and no issues are outstanding. BY THE(COURT: ATTEST: y J. PROTHONOTARY ,?7 .. r- L. gyp.. r sL..