Loading...
HomeMy WebLinkAbout01-6412DAVID C. LASHER, Plaintiff VS. YOLANDA M. LASHER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No.O[~' ~ lo~ Civil Term : : ACTION 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. Where the ground for the divome is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 DAVID C. LASHER, Plaintiff VS. YOLANDA M. LASHER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. dP l~ (_V L///o,~ Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is David C. Lasher, a competent adult individual, who has resides at 405 Meadowbrook Road, Carlisle, Pa. 17013. 2. Defendant is Yolanda M. Lasher, a competent adult individual, who resides as 9829 Love Road, Box #2348, Fort Meade, Maryland, 20755. 3. Defendant has been a bona fide resident of thc Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on April 3, 1996 in San Diego, California. 5. There have been no prior actions of divorce or for annulment between thc parties. 6. Plaintiff has been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. The Plalntiffavers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are tree 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. David C. Lasher, Plaintiff Date: Respectfully submitted, Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF DAVID C. LASHER, Plaintiff YOLANDA M. LASHER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 6412 Civil Term 2001 : : ACTION IN DIVORCE ACCEPTANCE OF SERVICE PURSUANT TO PA.1LC.P 4 02(B) AND PA.R.C.P. 1920.4 I, Yolanda M. Lasher, Defendant in the above-captioned matter, hereby accept service of the Complaint in Divorce filed under the above-captioned number which was served upon me via first-class mail, certified, restricted delivery, on November 26, 2001. Date:/~ ~'~fl pt2. oY~Oanda M. Lashcr~D~.~ndant DAVID C. LASHER, Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 6412 CiviITerm 2001 YOLANDA M. LASHER, ' ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 13, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. David C. Lasher, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE; UNDER 63301;ct OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2· I understand that I may lose rights concerning alimony, division of property, lawye¢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. David C. Lasher, Plaintiff DAVID C. LASHER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 6412 CiviITerm 2001 YOLANDA M. LASHER, : ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 13, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~' ~ ' 0 ~ (,,~'olandaMLasher. Defer~t WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301~c~ OF THE DIVORCE CODE 1. I consent to entry of a final decree of divome 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: ' 5 "0~, ~ o~nda M. Lasher, De~j~lant DAVID C. LASHER, 'Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA YOLANDA M. LASHER, Defendant · NO. 6412 Civil Term · ACTION IN DIVORCE 2001 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 _63301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery_, return recei_Dt reauested, delivered on: November 26, 2001. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: April 5, 2002 By Defendant: April 5, 2002 4. Related claims pending: None· 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 9, 2002. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 9, 2002. (~Adams, Esquire o. 79465 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff STATE OF David C. Lasher, INThe COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. Plaintiff VERSUS Yolanda M. Lasher, Defendant NO. 6412 Civil 2001 DECree IN DIVORCE AND NOW, ~ ~0,; ! I ~7 DECREED THAT DaYid C. Lasher Yola~da M. Lasher AND , ~O~, IT IS ORDERED AND __, PLAINTIFF, , DEPENDANT, 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; ATTE~/~ J- ~ROTHONOTAR¥ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : Vs : : Defendant.' FileNo. 0 ,t -&z~ IZ civil' IN DIVORCE NOTICE TO RESUME PR/OR SURNAME Notice is hereby given that the Plaintiff/defendant in the above matter, [select one l~y marking "x"] prior to the ~ntry of a Final Decree in Divorce, or ~ after the entry of a Final Decree in Divorce dated ~ ~ i [ 1'7 :~o2~ hereby elects to resume the pri.or surname of *Yo [ clr~d6t Mg 1302. , and gives this written notice avowing his / her hatention pursuant to the provisions of 54 P.S. 79~. L Signature / COMMONWEALTH OF PENNSYLVANIA COUNTY OF .~ o',¢),7 ) gnature of name being r~umed ~,/ Onthe /5'~ dayof~e a,-~,-- ,200_T:>,beforeme, thc Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the w/thin document and acknowledged that l~e'/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official Notary Public ~ LAURETTA 8. JOHNSON ~ ~ C~r~. E~. Ua~ 28, 2006