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HomeMy WebLinkAbout04-0249 SEAN B. PAINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW : NO. 0"/-.;2'1'7 : IN DIVORCE CIVIL TERM PAMELA J. PAINTER, 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Streetf Carlisle, Pennsylvania 17013 (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEAN B. PAINTER, v. CIVIL ACTION - LAW PAMELA J. PAINTER, Defendant NO. pl.(- ;1.'-1"1 IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT I. Plaintiff is Sean B. Painter, an adult individual currently residing at 317 York Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Pamela J. Painter, an adult individual currently residing at 222 Marion Avenue, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 14,2003, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant is a member of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date ofthe filing ofthis Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, 'lt~lw?Y(~CtIJ Marylou ~as, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: !-/S-cL.{ c;., lJ/~'~- ....u~y1 [) ct...vrL.,,-IVl.. SEAN B. PAINTER, Plaintiff c--J ~~- ; (--,-' ....... ~ \ .-1 ~ "- "- t " ~ ~ I.J\.. .~ ~ '" \ 'J" '''.: ~ r , ",,- " .~ " lk \~\ I."~' .~ " ~ '-, " VI \ 1,"-",\. , "'" ~ 1::\ , ''\ " ~ ~ '" " '^ ',:\ ,. -, \-'! ~) . \ \~ 'IJ \~. ~ ~ ,,," " , \, ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEAN B. PAINTER, v. CIVIL ACTION - LAW PAMELA J. PAINTER, Defendant : NO. 04-249 : IN DIVORCE CIVIL TERM ACCEPTANCE OF SERVlCE ./ I, Robert J. Mulderig, Esquire, acknowledge that on r~ ,..3.-, 2004, I received a certified and true copy of a Complaint in Divorce in the above captioned action and further acknowledge that I am authorized to do so on behalf of my client, Pamela J. Painter. Date: r1 /7/0 t./ , / ~~ ~ Robert J. M erig, Esquire ~ Turo Law Offices 28 South Pitt Stre:et Carlisle, PA \70\3 Sworn and subscribed to before me this '1m day of FeB/2..J A , 2004 Notari,1 S"'~I James M. Rcbhb',on, NCtIry PIIIlIIo Carlisle Bom, Ct:-nbodad c::a.Ir , My Commission E:,:,,;fCI JuDe 6, 2005 n '"'-> !f: = c = .?" ..,.. !-' ;"1 ..." -::::f i-'I; rr, :J~_() ~,+- G:i rt'j=- , -rim - -66 ~:.::: -.J C) ::::- '" ..:;.:1-,+; " ~~ :!J ~i~ -""~ -'-"'0 ~tg "J :z: ;;,;~ -;J Cl :il -~ 0 -< Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA SEAN B. PAINTER, v. : CIVIL ACTION - LAW PAMELA J. PAINTER, Defendant : NO. 04-249 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on January 20, 2004, and served on February 9, 2004. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 5'-/0 -d L.( AHVVI i3 ~ SEAN B. PAINTER, Plaintiff ~ ?~;~ I.....'.., '.. r";' .<:'" ".:. ~- )'~~; =:;! o ,. ...., = <=> -"'" L.. S _. o TI --4 .. IT;:!) r- -om -"M r'. T s.~O ........:~. ().+i ,;,;=:M ......J .-,-.j 1.,," ~ I N :-:-~ _L.~ o Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA SEAN B. PAINTER, v. : CIVIL ACTION - LAW PAMELA J. PAINTER, Defendant : NO. 04-249 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: S~JO~Ol.-J -<) u.~'1 /3. ~~ SEAN B. PAINTER, Plaintiff (") c: :'\~. ,- \,...... ~~; :~ C" "> = = ..- <- fi o -... If rn;2:! ""'n"1 57 -::::!~r1 3f~ .-{ -" .::b -, I N :;! II SEAN B. PAINTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-249 v. PAMELA J. PAINTER, Defendant : CIVIL ACTION - IN DIVORCE NOTICE TO RESUME PRIOR SURNAME NOTICE IS HEREBY GIVEN that the Defendant in the above matter, having been granted a Final Decree in Di'iOrce on the 29th day of December, 2004, hereby elects to resume the prior surname ,)f Parnela .1. Michael, and gives this written notice pursuant to the provisions of 54 P.S 3704. -JJn los Da I COMMONWEALTH OF PENNSYLVANIA S8 C;~:jNTY OF G~;r'/5[,RL/\r~D On the 17-n-J day of ..Jt,..jvAR.'1 , 2005, before me, a Notary Public, I personally appeared Pamela J. Michael known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledge that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. .. - .'~-' .' ,.-. ..' '(.,\..,,' . . / , ' Notarial Seal . L ~ JIlJIlCI M. Robinson, Notary Public CIIIItle Boro, Cumberland COunty ...- ."~ - "'.. f);" PO"?/, ' ....--;-, ',:.--, ~ ~ ~:o cr~~~ * -..J ~ ---J _ ~ -C.. ~ ~\ ~ ~ t '~.,':.) :--..... .- (".J - SEAN B. PAINTER, : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYL V NIA Plaintiff v. : CIVIL ACTION - LAW PAMELA J. PAINTER, Defendant : NO. 04-249 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 1 consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of pr perty, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorce until a divorce decree is entered y the Court and that a copy of the decree will be sent to me immediately after it is files w' h the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFID ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS H ARE MADE SUBJECT TO THE PENALTIES OF i8 Pa.C.S. ~4904 RELATIN UNSWORN FALSIFICATION TO AUTHORITIES. DATE: -1l} Is-jOY ~ r.::> (c:.~ Ci ~:~ .-C( ~:':i:\ ,-") c...' (......"J .----- SEAN B. PAINTER, Plaintiff : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYLV NIA v. : CIVIL ACTION - LAW PAMELA J. PAINTER, Defendant : NO. 04-249 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT I. A. Complaint in Divorce under 93301 (c) of the Divorce Code was fi d on January 20, 2004, and served on February 9, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and njnet (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 no ce of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFlD VIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS H IN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATIN TO UNSWORN F ALSIFICA TION TO AUTHORI S. DATE: ~-) -:: (...) c..:;. "-0 C;'::l CJ ~.I;;:- C') "",'I t Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V A IA SEAN B. PAINTER, v. CIVIL ACTION - LAW ,;1t.{q : NO.04-J94" CIVIL TERM : IN DIVORCE PAMELA 1. PAINTER, 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: I. Ground for divorce: Irretrievable breakdown under ~3301(c) 33QI(d)(I) eftlle Dh'eree Cede. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Acceptance of Service on February 9, 04. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by !l3301 (c) ofthe Di rce Code: by Plaintiff: May 10,2004 by Defendant: November 5,2004 (b) (I) Date of execution of the affidavit required by !l3301 (d) of the Divorce Cod: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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 Tran mit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: June 2, 2004 Dale defendant's Waiver of Notice III ~3301 (c) Divorce was filed with the Prothonotary: December 1,2004 ;f."';f."" "':of. ~:+.~:+=:+=:+=:+=:+= '+' "':+. "'~:+= '" '+':+= "';f.:of. "':+=:+. '+':+=:+= '" '+':+= +:+.:+=:+.:+=:+.+:+.+:+. ~:+: :+= :+. :+= '" + :f. + :+= :+. :+= :+. :+= . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~+++""+:+=:f.:+=+:+=:+=+:+=:f.:+=+ :+=:f.:+=:+=:+=:+::+= + IN THE COURT OF COMMON PLEA STATE OF ~P.l\N R paTNTER, Plaintiff VERSUS PAMELA J. PAINTER. Defpnn:=lnr AND NOW, DECREED THAT Sean B. AND P:=lm~l::<i OFCUMBERLANDCOUNTY PENNA. No. 04-249 Civil T~rm DECREE IN DIVORCE 7)~ Z7~ , z<>o'f, IT IS ORDERE Painter , PLAINTIFF, J Painter , DEFENDAN ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIC YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA .. ~ '" ... PROTHONO ARY Alnu.. By THE COURT'd ++:+::+=:f.++++++:+=+++++++:+=:+='+':+=+:+=++++++:f.+:f.+:f.+ +++;+::f.++++++ . ;+:++:+'++++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - . . . . . . . . . . . . . . . . ++++++++ AND HAVE NOT J. ~' fn_ <1: "...._~!If, ,0.'.' / -T/ r;: J,Lf Y , 7/ - _ C _ hr-,Mv - pi) 50-5.1 /pr# r?~ ' t/ ' *" ..Jl' " . ".... .