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HomeMy WebLinkAbout04-0260RICHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. ~9~-dd>~ CIVIL TERM CIVIL ACTION - 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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. CUMBERLMND CO UNTY BAR ASSOCIATION 32 SO UTH BEDFORD (777) 249-M66 OR (S00)990-9108 RICHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. Oq -,t?ec, CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT Plaintiff is Richard William Olon, who currently resides at 522 Harding Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Jill Renee Olon, who currently resides at Street, New Cumberland, Cumberland County, Pennsylvania 17070. 522 Harding 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 24, 2001, at Carlisle, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. the parties. 7. ~3301(c) in that: There have been no prior actions of divorce or for annulment between Divorce is sought pursuant to the provisions of the Divorce (]ode, a. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Jason P. Kutulakis 36 ~outh Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 80411 VERIFICATION I, Richard William Olon, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. [ 4904 relating to unsworn falsification to authorities. RICHARD WILLIAM OLON RICHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-260 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Jason P. Kumlakis, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted Pennsylvania, addressed as delivery, postage prepaid, on January 21, 2004, at Carlisle, follows: fill R. Olon 522 Harding Street New Cumberland, PA 17070 Return card acknowledging receipt on January 26, 2004, is attached as Exhibit Date: ABOM & KUTULAKIS, LLP JasOn P. Kumlakis, Esquire 36~3outh Hanover Street Cal4isle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 80411 7003 EXHIBIT ".4" RICHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-260 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under [3301 (c) of the Divorce Code xvas filed on January 21, 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. 1 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. RICHARD WILLIAM OLON RICHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-260 CIVIL TERM CIVIL ACTION - LAW 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 untJi 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. 94904 relating to unsworn falsification to authorities. Date: RICHARD WILLIAM OLON RICHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-260 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under [3301(c) of the Divorce Code was fried on January 21, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of friing 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 this affidavit: are true and correct. I understand that false statements herein are made subiect to the penalties of 18 Pa. C.S. [4904 relating to unsworn falsification to authorities. L RENEt?OLON PdCHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-260 CIVIL TERM CIVIL ACTION - LAW 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 d!Worce without notice. 2. I understand that I may lose rights concerning alimony, division of property, la,wer'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 ~vill 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. 94904 relating to uns~vorn falsification to authorities. J~LL RENEE OLON RICHARD WILLIAM OLON, Plaintiff JILL RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUN'IX, PA NO. 04-260 CIVIl, TERbl CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME_ Notice is hereby given that the Defendant in the above matter, prior to the entry of a Final Decree in Divorce, hereby elects to resume the prior surname of Jill Renee Albright, and gives this written notice avowing her intention pursuant to the proviskms of 54 P.S. 704. Date: xnaU.lre ~ature of nCame being resumed COMMONWEALTH OF PENNSYLVANIA : :SS COUN~iX OF CUMBERI.AN On the j_0t/~ . day of ~~ ,20 ~:, before me, a Nota~ PubBc, pezsonally appeared the above affiant kno~vn to me to be the person ~vhose name is subscribed to the ~tl~n document and acknowledged that he/she executed the foregoing for the pu~ose therein contained In Wimess Whereof, I have hereunto set my hand and of~ RICHARD WILLIAM OLON, Plaintiff JILl. RENEE OLON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-260 CIVIL TEP~M CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground(s) for chvorce: irretrievable breakdown under 83301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail on January 26, 2004. 3. Date of execution of the Affidavit of Consent required by 83301 (c) of the Divorce Code: by Plaintiff'.' June 3, 2004; by Defendant: June 10, 2004. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in ~3301 (c) Divorce was fried with the Prothonotary: June 10, 2004 Date Defendant's Waiver of Notice in 83301(c) Divorce was filed with the Prothonotary: June 17, 2004 Respectfully submitted, ABOM O KUTULAKIS, L.L.P DATE 36 South Hanover Street Carlisle, Pennsylvania 1701'3 (717) 249-0900 Attorney for Plaintiff ID #86914 CERTIFICATE OF SERVICE AND NOW, this ~,1 ~ day of ~51J'L~2004, I, Kara W. Hag, gert),, Esquire, hereby certify' that I did serve a true and correct copy of the foregoing Praecipe to Transmit Record upon the Defendant by depositing, or causing to be deposited, same in the U.S. ma/l, postage prepaid, addressed as follows: Jill R. Olon 248 S. West Street Carlisle, PA 17013 Respectfully submitted, ABOM ~ KUTULAKIS, L.L.P Kara W. Haggerty,(~uire 36 South Hanover Street Carlisle, Pennsylvania 1701 (717) 249-0900 Attorney for Plaintiff ID #86914 IN THE COURT OF COMMON PLEAS RICHARD WILLIAM OLON, Plaintiff OF CUMBERLAND COUNTY STATE OF .¢~~ PENNA. 04-260 NO. CIVIL VERSUS JILL RENEE OLON, Defendant AND NOW, DECREED THAT AND DECREE 1N DIVORCE t~ARD WILLIAM OLON JILL RENEE OLON ORDERED AND PLAINTIFF, 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; Nolle PROTHONOTARY