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HomeMy WebLinkAbout04-0438COLLEEN A. MCCOURT, :IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CYRIL PATRICK MCCOURT, JR., 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 at 1 Courthouse Square, Carlisle, PA 17013. 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 Ave. Carlisle, PA 17013 (717) 249-3166 or 1(800) 990-9108 COLLEEN A. MCCOURT, :IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CYRIL PATRICK MCCOURT, JR., Defendant : In Divorce · No. COMPLAINT IN DIVORCE DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE Plaintiff, by her attorneys, Laws, Staruch & Pisarcik, respectfully represents: 1. The Plaintiff is Colleen A. McCourt, who currently resides at 300 Park Avenue, New Cumberland, Cumberland County, Pennsylvania, for more than two years. 2. The Defendant is Cyril Patrick McCourt, Jr., who currently resides at 2200 Wilson Boulevard, Arlington, VA 22201, since February, 2003. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on January 23, 1993, at Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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 counseling. 8. Plaintiff requests the court to enter a decree of divorce. 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. Colleen A. McCourt Atty I.D. 23887 Laws, Staruch & Pisarcik 20 Erford Road, Suite 305 Lemoyne, PA 17043 (717) 975-0600 COLLEEN A. MCCOURT, Plaintiff :IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CYRIL PATRICK MCCOURT, JR., Defendant · In Divorce · No. 04-438 AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 2, 2004. 2. The marriage of plaintiff and defendant is irretrievable 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 the decree. 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: -~/-~/~4~ ~' Colleen A. McCourt, Plaintiff COLLEEN A. MCCOURT, :IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CYRIL PATRICK MCCOURT, JR., Defendant · In Divorce ' No. 04-438 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 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. § 4904 relating to unswom falsification to authorities. Date: Colleen A. McCourt, Plaintiff COLLEEN A. MCCOURT, :IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CYRIL PATRICK MCCOURT, JR., Defendant · In Divorce · No. 04-438 AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 2, 2004· 2. The marriage of plaintiff and defendant is irretrievable broken and ninety days have elapsed from the date of filing and service of tl;~e complaint. 3. I consent to the entry of a final decree of dlivorce after service of notice of intention to request entry of the decree. I verify that the statements made in this atfidavit 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 ~/J.7-~'.~ ~Cyri~Patrick McCourt, Jr., Def/efldan~'"---- COLLEEN A. MCCOURT, :IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLANID COUNTY, PENNSYLVANIA CYRIL PATRICK MCCOURT, JR., Defendant : In Divorce · No. 04-438 WAIVER OF NOTICE OF INTENTI'ON TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of 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. § 4904 relating to unsworn falsification to authorities. Date:~-//~//~,/Z-~Z~" ~...~fil Patrick McCourt, Jr.~Defen COLLEEN A. MCCOURT, Plaintiff :IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA CYRIL PATRICK MCCOURT, JR., Defendant : In Divorce · No. 04-438 Civil Date: 2/19/04 ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. Cyril Patrick McCourt, Jr., ~endant COLLEEN MCCOURT V. CYRIL P. MCCOURT, JR. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2004 - 438 CIVIL TERM : : CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 9TM day of JUNE, 2004, based upon the proposed decree it appears that there may be certain economic claims outstanding and leave of court to bifurcate the proceedings has not been requested, the parties request for the entry of a divome decree leaving open the resolution of economic issues, including alimony pendent elite, is DENIED. By the ard E Guido, J ~. Scott Staruch, Esquire Mariann L. Stiely 20 Erford Road, Suite 305 Lemoyne, Pa. 17043 ,~atrick McCourt 2200 Wilson Blvd. 102-194 Arlington, Virginia 22201 :sld COLLEEN A. MCCOURT, Plaintiff V. CYRIL PATRICK MCCOURT, JR., Defendant :IN THE COURT OF COMMON PLEAS ! CUMBERLAND COUNTY, PENNSYLVANIA : In Divorce · No. 04-4318 Civil PRAECIPE TO TRANSMIT RE!CORD 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)) (3301(d)) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: _2/19/04 - Acceptance of Service by Defendant 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 5~20/04 ; by defendant 5/20/04 . Divorce Code: (b) (1) Date of execution of the affidavit required by §3301 (d) of the N/A ; (2) Date of filing and service of the plaintiff's affidavit upon t~ee 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: prothonotary: (b) Date plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the _ 6/1/04 Date defendant's Waiver of Noti~ ' rce · the prothonotary: 6/1/04 , ~ce was filed with W. Scott ~taruct~Esq. Attorney for Plaintiff COLLEEN A. MCCOURT, Plaintiff V. CYRIL PATRICK MCCOURT, JR., Defendant :IN THE COIL.JRT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA · In Divorce : No. 04-438 Civil PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divome decree: 1. Ground for divorce: irretrievable breakdown under s/3-~nl ~'~-~/'~'~ [-~ of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: .2/19/04 - Acceptance of Service by Defendant 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 5/20/04 ; by defendant 5/20/04 (b) (1) Date of execution of the affidavill 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: (b) Date plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: 6/1/04 the prothonotary: Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with 6/1/04 :"~'W.~. Scott Staruch, Esq. Attorney for Plaintiff IN The COURT OF COMiVlON Colleen A. McCourt Plaintiff OFCUMBERLANDCOUNTY STATE OF PENNA. VERSUS Cyril Patrick McCourt, Jr. Defendant NO. 438 PLEAS 2004 DECREE IN DIVORCE AND NOW,_ DECREED THAT AND Cyril Colleen A, McCourt Patrick McCourt, Jr. , IT IS 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; None ATTEST: PROTHONOTARY