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HomeMy WebLinkAbout01-6414Jodi M. Morgan, Vo PLAINTIFF, Herbert R. Morgan, DEFENDANT, (IN THE COURT OF COMMON PLEAS OE ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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. WHEN THE GROUND FOR THE DIVORCE ARE 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, PENNSYLVANIA, 17013. THE TELEPHONE NUMBER IS (717) 240-6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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. LAWYERS REFERRAL SERVICE 2 Liben'y Ave. Carlisle, PA 17013 (717) 249-3166 Jodi0~I. Morgan, Pro Se 195 Thorny Grove Lane Shippensburg, PA 17257 (717) 530-0850 Jodi M. Morgan, PLAINTIFF, Herbert R. Morgan, DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( COMPLAINT IN DIVORCE AND NOW COMES the Plaintiff, Jodi M. Morgan, bY FILING PRO SE, who files this Complaint in Divorce a statement of which is as follows: 1. The Plaintiff is Jodi M. Morgan, an adult individual currently residing at 195 Thorny Grove Lane, Shippensburg, County of Cumberland, Pennsylvania, 17257. 2. The Defendant is Herbert R. Morgan, an adult individual currently residing at 1219 13t~ Ave., Altoona, County of Blair, Pennsylvania, 16601. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of approximately fifteen (15) years. 4. The Plaintiff and Defendant were married on October 30, 1999 in Las Vegas, in the State of Nevada. 5. There are no children born or adopted of this marriage and Plaintiff is not pregnant. 6. Neither party is a member of any branch of the military. 7. The marriage is irretrievably broken. o The Plaintiff, Jodi M. Morgan, respectfully requests this Honorable Court to grant this divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce Code. Respectfully submitted: Jodi ~[I. Morgan, Plo Se 0 195 Thorny Grove Lane Shippensburg, PA 17257 (717) 530-0850 I verify that the statements made in the Complaint are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. Jodi M. Morgan, PLAINTIFF, Vo Herbert R. Morgan, DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( (NO: ~l'-~_.Oq It AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) ) SSi COUNTY OF CUMBERLAND ) Before me, the subscriber, a Notary Public in and for said Commonwealth and County, personally appeared Jodi M. Morgan, who being duly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of her knowledge, information, and belief, and that she is authorized to make this Affidavit. , Jodi~. Mor~, Pro'Se ' ~ ~~ Sworn to and subscribed before me this/__~ Day of ~~ ~., ~ / . Notary Public Jodi M. Morgan, PLAINTIFF, Vo Herbert R. Morgan, DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION c~ .... CERTIFICATE OF SERVICE ~i v~ PLAINTIFF, Jodi M. Morgan, of the Commonwealth of Pennsylvania, hereby affirms the following statement under penalty of perjury: 1. I am the plaintiff in this action, Iherebycertifythaton ff .] ,, t /,I caused a copy of the attached: Complaint in Divorce to be served upon Defendant Herbert R. Morgan 1219 13th Ave. Altoona, PA 16601 by depositing a true copy of the same enclosed in a post-paid addressed envelope, in a depository under the exclusive care and custody of the U.S. Postal Service within the Commonwealth of Pennsylvania. Date: organ, Plaintiff, Pro Se ~J 195 Thorny Grove Lane Shippensburg, PA 17257 (717) 530-0850 3o i R. ?rooC · Complete items I 2, and 3. Also complete item 4 f Restricted Delivery is desired. · Print your name and addmes on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front If space permits. 1. A.-ti~le,N:~,,~d to: C. Signature [] Express Mail [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? ,(,(Ex/fa F~e) [] Yes 2..Nticle Number (Copy from service lebel) PS Form 3811, July 1999 De~esc ~ Receipt JODI M. MORGAN, : Plaintiff : Vo HERBERT R. MORGAN,: Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6414 CIVIL TERM ORDER OF COURT AND NOW, this 6t~ day of March, 2002, upon consideration of Plaintiffs pro se Praecipe To Transmit Record, and it appearing that Defendant's affidavit of consent was not executed "ninety days or more after both filing and service of the complaint,'d a divorce decree will not be entered at this time, without prejudice to the parties' right to 'correct the deficiency and file a new praecipe to transmit record. BY THE COURT, .Moodi M. Morgan 195 Thomy Grove Lane Shippensburg, PA 17257 Plaintiff, Pro Se ~ ~t~erbe~ R. Morgan 1219 13th Avenue Altoona, PA 16601 Defendant, Pro Se J.)esley oler~, J. ' :rc ~See Pa.R.C.P. 1920.42(b)(1). Jefferson J. Shipnm~ Esquire I.D. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants, David L. Clugh, Ir., David L. Clugh, Sr. and Theresa ~. Clugh LEANNE HAYCOCK, Plaintiff V. DAVID L. CLUGH, JR., DAVID L. CLUGH, SR. and THERESA J. CLUGH, · Defendants ' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 01-6514 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Pule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, were mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice Of Intent, including the proposed subpoenas, are attached to this Certificate; (3) was waived. (4) Of Intent. No objection to the subpoenas has been received; the twenty day waiting period The subpoenas to be served are identical to the subpoenas attached to the Notice Date: Jefferson J. Shipman, Esquire Attorney I.D. #51785 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, on the (~ q4 day of fl//R)/ ,2002, addressed as follows: Clark DeVere, Esquire Metzger, Wickersham, Knauss & Erb 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 GOLDBER.~KATZMAN &:SHIPMAN, P.C. By ~ Jefferson J. Ship~ E.sq~* ~;' ;~ ~" ~:': ~'~:'"' ~ Attorney I.D. #51785 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 2344161 Counsel for Defendants Jefferson J. Shipman, Esquire I.D.//51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants, David L. Clugh, Jr., David L. Clugh, Sr. and Theresa J. Clugh LEANNE HAYCOCK, Plaintiff DAVID L. CLUGH, JR., DAVID L. CLUGH, SR. and THERESA J. CLUGH, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6514 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: LeAnne Haycock and Clark DeVere, Esquire METZGER, WlCKERSHAM, KNAUSS & ERB 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 PLEASE TAKE NOTICE that Defendant intends to serve six subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. Jefferson J. Shipman, Esquire Attorney I.D. #51785 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants Date: CERT~ICATE OF SERVICE I HEREBY CERT~Y that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, certified, postage prepaid, at Harrisburg, Pennsylvania, on the ! ~' day of fl'~ay ,2002, addressed as follows: Clark DeVere, Esquire Metzger, Wickersham, Knauss & Erb 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Jefferson J. Shipman, Esquire Attorney I.D. #51785 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants Le~nne Baycock ~ Plaintiff CC~TH OF PENNSYLVANI-g ~ OF OJMR~RLSJ~D David L. Clugh, Jr., David L. Clngh, Sr., ~d: ~eresa J. Clugh, : Defendants S~ TO PR~ ~S ~ ~1~ F~ DI~VERY P~A~ TO ~E 4009.22 File No. 01-6514 (Name of Person o~ Entity) Within twenty (20) days after service of this subpoena, you are omdered by the court~ence produce the following ~ts o~ things- any and all medical records, reports, corresponu · diagmostic test results pertaining to LeAnme ~aycock-~S; 203-58-5161 DOB 7/28/1~ at Goldberg, Katzman & Shipman, 320 ~arket Street, ~.o. Box 1268, (~ddress) You may deliver or mail legible co~ies of the doc~nents or produce things requested by this subpoena, tocjether with the certificate of c~,pliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the c~ies or producing the things sought. If you fail to produce the doc~nents or things required by this subpoena within twenty (20) days after i~s service, the party serving this subpoer~amay seek a count order cu,¢ellir;g you to co,ply with it. THIS St~POENAWAS ISSUED AT THE REGgJEST OF TME FOLLC~ING PERSON: NAME: Jefferson J. Shipman, Esquire ADORESS:]~J~arket Street, P.O. Box 1268 ~, PA..~7108-1268 ~ELEPH~E ~17-?~&-4161 SUPREME OOURT ID ~ 51785 AT-fORNEY FOR: Defendants DATE: _ 'S~I of-the Cb~.~t - BY ~ COURT: ~ Prothonotary/C I erk ,/~i 1 O ivi s ion .... ( - - ~Deputy (Eff. 7/97) OOM~ONWEgLTH OF PENNSYL~ ~ OF : LeAune ltaycock, : Plaiutif f : : ~le ~o. 01-6514 David L. Clugh, Jr., David L. Clugh, Sr., and · Theresa J- Clugh, Defendants SUBPOENA TO PRODOCE DOO3~NTS OR TH I FOR DISCOVERY PL~SUANT TO RULE 4009.22 TO: C,~mherland Valley EMS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you a~e ordered by the count to produce the following doccrne~ts or things: any and all medical records, reports, correspondence, di__agnostic test results pertaining to LeAnne Haycock TS# 203-b~-)161 DOB 7/28]78 at Goldberg. Katzmnn & Shipmmn, 320 Market Street, P.O. Box 1268, 9arrisburg, ~A~-YlGC ~v8 (Address) You may deliver o~ n~il legible cooies of the doc~n~qts or produce things requested by this subpoena, together with the certificate of c~,uliance, to the party making this request at the addrmss listed above. You have the right to seek in advanc~ the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the doctm~nts o~ things required by this subpoen~ within twenty (20) days after its service, the party serving this subpoermmay seek a court c~der c~,¢ellir;g you to co~uly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Jefferson J. Shipmnu, Esquire AOOR5SS: 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 TELEPHONE: 717-234-4161 SL~REb~ COORT ~D ~ 51785 AI-fO~NE¥ FOR: Defendants DATE: ~ea~ of l~he Cx~Jrt ~ BY,~ CO JRT: Prothonotary/Clerk, C;i~r~Oivision [~uty (Eff- ~/S?) LeA~ne Haycock, Plaintiff ~T~OF PENNSYL~ CCYJNTYOFCUM~WRLAND V. : File No. David L. Clugh, Jr., David L. Clugh, Sr., and: Theresa J- Clugh, : Defendants : 01-6514 SUBPOENA TO PRODUCE DCCLI'IE~S O~ THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Hospital (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are o~dered by the court to produce the lot]owing ~ts or things: any ~ic test results pertainimg to LeAmne Haycock, SS~ at r~ldherg~ Katzmmn & Shipman, 320 Market Street, P.O. Box 1268, Harrisburg, ¥A/7i08-1268 (~dd~ess) You may deliver o~ mail legible co~ies of the docun~qts or produce things requested by this subpoena, tcx3ether with the certificate of cu,~liance, to the party n~ing this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its sarvice, the party serving this subpoermn~y seek a court order cu~ellir:g you to cu,oly with it. THIS SUBPOENA WAS ISSUED ATT HE REQUEST OF THE FOLLC~INK~PERSON: NAME: Jefferson J. Shipman, Esquire ADORESS: 320J4arket Street, P.O. Box 1268 Harrisburg, PA 17108-1268 TIELEPH(~E: 717-234-4161 SUPREME OO3RT ID ~ 51785 AT/ORNEY FO~: Defendants DATE: _ S~rl o~-the OO6.~t - ~ BY THE OOURT: Prothc~otary/C~Le~k,/e~i 1 Division - - ( - - Deputy (Eff. ~/ST) LeA~ne Bmycock, Plaintiff ~TH OF PENNSYLVANIA David L.Clugh, Jr., David L. Clugh,Sr.,.and Theresa J. Clugh, Defemdants File No.01-6514 SUBPOENA TO PRCOJ(~ DOCt..~ENTS OR THIN(~ FO~ DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Imaging Associates (N~oe of Person o~ Entity) Within twenty (20) days afte~ service of this subpoena, you a~e ordered by the court to produce the following do~ments o~ things: any and all medical records,_ reports, correspondence, _di~~_t_r~sults pertaining to LeAnne Haycock SS~ 203-58-5161 DO~ 7/28/73 at C~!m~r5: ~mtzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisburg, MA i2i06--i268 (Ack~ress) Yo~ nmy deliver or mail legible cooies of the d0ctm~qts or produce things requested by this subpoena, tc~ethe~ with the certificate of c~,~liance, to the party making this request at the address listed above. You have the ri~ht to seek in advam, ce the reasonable cost of preparing the copies or ~moducing the things sought. If you fail to produce the doc~nents or things required by this subpoen~ within twenty (20) days after i~s service, the party serving this subpoena may seek a court order cu,~ellir:g you to c~',~ly with it. THIS SUBPOeNA WAS ISSUED AT THE REQUEST OF' THE FOLLONING PERSON: NAN~: Jefferson J. Ship-mn, Esquire ADORE$S: 320 Market Street, P.O. Box 1268 ~arrisburg, PA 17108-1268 TELEP~E: 717-234-4161 SUPREP~ CCORT ID ~ 51785 ATTORNEY FOR: Defendants DATE: Se~l of ~he-C~u?t ~ BY ]~HE OOURT: Prothonotary~Cler~,-~Divi l Division (Elf. ~/97) ~TH OF P51,~SYLV'AN/_A LeAnne Haycock, : Plaintiff : : David L. Clugh, Jr., David L. Clugh, Sr., an~ Theresa J. Clugh, : Defendants SUBPOENA TO PRO0(.,IO~ ~NTS OR 'I'HI FOR DISCOVERY PURSUANT TO RULE 4009,22 File No. 01-6514 TO: Dr. David P. Albright, Belvedere Medical Center (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the followimq doc~nents or things: any and all medical records, reports, correspondence, diagnostic test results pertaining to LeAnne Haycock SS# 203-58-blbl DOB 7/2~/7~ at Goldberg, Kat~mmu & Shipmmn, 320 Harket Street, P.O. Box 1268, Harrisburg, (~ddress) You may deliver or mail legible co~ies of the documents or produce things requested by this subpoena, together with the certificate of CoT~liance, to the party making this request at the address listed ~bove. You have the right to seek in adva~ce the reasonable cost of preparing the copies or ~roducing the things sought. If you fail to produce the c~nts or things required by this subpoena within twenty (20) d~ys after i~s service, the party serving this subpoerm may seek a court order cu,~ellir;g you to co,~ly with it. THIS SUBPOENA WAS ISSUED AT THE RE(~JESTOF THE FOLLOWIN~PERSON: NAME: Jefferson J. Shipmmn, Esquire ADORESS: 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 YELEP~K~E: 717-234-4161 SUPRHMECOURT ID ~ 51785 ATTORNEY F(]~: Defendants Se~l of the C z~urt - BY ~ (X)URT: ( Deputy (Elf. 7/97) ~TH OF PI~'/N.5~LVANIA LeAnne Haycock, Plaintiff David L. Clugh, Jr., David L. Clugh,Sr. and Theresa J. Clugh, Defendants File No. 01-6514 SUBP(~NA TO PRODUCE DO3UF'~NTS OR TH I ~ FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Alexander Spring Rehab Center (N~me of Person or Entity) Within twenty (20) days afte~ service of this subpoena, you a~e o~de~ed by the court to prc~Juce the fol]owinq doctrnents o~ things: any amd ali medical records,_reports, correspondence, diagnostic test results pertaining to LeAnne Maycock SS~ 203-58-5161 DOE at Goldberg, Kat~man & Shipman, 320 Market Street, P.O. Box 1268, ~arrisburg, MAiXi06--i268 (Ad~Jress) You may deliver o~ n~il legible cooies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the pa~ty making this request at the address listed above. You have the ri~fnt to seek in advan, ce the reasonable cost oF prepa~ing the copies or producing the things sought. If yo~ fail to produce the doctrnents o~ things required by this subpoena within twenty (20) days after its service, the pa~ty serving this subpoermmay seek a court o~de~ co,~ellir;g you to co~ply with it. THIS SU~POENAWAS ISSUED ATT HE REC~JESTOF ~ FOLLC~IN~PER~ON: NABS: Jefferson J. Shipmmu, Esquire AOORE$S: 320 Market Street, P.O. Box 1268 Barrisburg, PA 17108-1268 TELEPH~4E: 717-234-4161 SL~PRE]'~COURT ID ~ 51785 ATFC~RNEY FCR: Defendants DATE: Se~l of the Co, Jrt BY/,~ COURT: Protbonotary/Cierk,}2i~il Division C~puty (Elf. ~r/97) JodiM. Morgan, Vo PLAINTIFF, Herbert R. Morgan, DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND CO01qTY, PENNSYLVANIA. ( (CIVIL DIVISION ( AFFIDAVIT OF CONSENT 1. A eomolaint in Divorce under Section 3301(e) ofth~ 2. The marriage of Plaintiff and Defendant is irretrieval have elapsed from the date of filing and Complaint. 3. I consent to the entry of a final decree of Divoroe intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TG ENTRY OF A DIVORCE DECRE~ U] SECTION 3301(c) OF THE DIVORCE 1. I consent to the entry of a final decree of Divorce with~ 2. I understand that I may lose rights concerning alin lawyer's fees, or expenses ifI do not claim them befor I understand that I will not be divorced until a Dive Court and a copy of the decree will be sent to me imm the prothonotary. I verify that the statements made in this affidavil understand that false statements herein are made subject to Section 4904 relating to unswom falsification to authorities. I, Herbert R. Morgan, certify that a copy of the fore was forwarded by US Mail, postage prepaid, on this dat~ Morgan, at her address of record. Herbert 1~. Morgan ' Divorce Code was filed on ,ly broken and ninety days after ser~4ee of notice of REQUEST qDER CODE ,ut notice. ony, division of property, a Divorce is granted. ge decree is entered by the xtiately after it is filed with are true and correct. I he penalties of 18 Pa. C.S. iorgan, Pro-~e- going Affidavit of Consent , to the Plaintiff, Jo& M. Jodi M. Morgan, Vo PLAINTIFF, Herbert R. Morgan, DEFENDANT, (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION ( ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: I, Herbert R. Morgan, Defendant in the above-c acknowledge receipt of the Compla~t in Divorce and Notice to in the matter of Jodi M. Morgan v. Herbert R. Morgan, Civil I and I hereby waive formalities of service and any objections to, Herbert R. Morgar 1219 13th Ave. Altoona, PA 166¢ (814) 943-4903 I, Herbert R. Morgan, certify that a copy of the forego has been forwarded on this date by US Mail, postage prepak Morgan, at her address of record. Date:/~ ~ ~ ,~, (~..~.. H~er~~ iptioned matter, hereby Defend and Claim Righ~ livision No:01 - ~ ff I/4, tefects thereto. Defendant / tg Acceptance of Service ., to the Plaintiff, Jodi M. / ori or1 : vs. : : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION .o. ©14Gqlq CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court fo~ 1. Ground for divorce: Irretrievable breakdown ~f the Divorce Cod .~------'-'~ (Strike out inapplicable section). 2. Date and manner of service of the complaint: 3. Complete either paragraph (a) or (b). (a) Date of execution of theaffidavit of consent required by §33£ by plaintiff ~'~(9¢/02~ ; by defendant (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon 4. Related claims pending: Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file copy of which is attached: (b) Date of plaintiff's Waiver of Notice in . §3301 (c) Divorce was f the Prothonotary: ~. ~- ~'Z~ ~ ~ Date defendant's Waiver of Notice ir) §3301 (c) Divorce was fi the Prothonotary:~ entry of a divorce decree: (c) of the Divorce Code: respondent: p~ aecipe to transmit record, a ed with ed with Attorney for P atntiff / Defe~an'~'l~' - IN The COURT Of COMMON PLEAS ~JOD~ M. MCRG~ ~;~RBERT R. MORG~2~ OFCUMBERLANDCOUNTY' I STATE OF ~. PEN NO. DEcree iN DIVORCE AND NOW, DECREED THAT J~Di M. ~=0.~G-~:N IT iS ORDERED AND PLAINTIFF, DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWIN BEEN RAISED OF RECORD IN THIS ACTION FOR WhiCh A Yet BEEN ENTERED; · ' .... 1S 20 3E PAID BY PI~Ii ~i~IPP. NONE. e~o ~. CLAIMS WHICH HAVE NAL ORDER HAS NOT BY THE COURT: II, ST: PROTHONOTARY