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HomeMy WebLinkAbout04-0564Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BRYAN D. PRITCHARD, Plaintiff MICHELLE L. PRITCHARD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 'NO. aY4-- ..Ct.q : 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BRYAN D, PRITCHARD, Plaintiff MICHELLE L. PRITCHARD, D~fendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : so. oq- 3'/.t/ : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Bryan D. Pritchard, an adult individual residing at 906 Newville Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Michelle L. Pritchard, an adult individual residing at 27 Mount Rock Road, Newville, Cumberland County, Pennsylvania 17241. 3. Both Plaintiff and Defendant have been bona fide residents in the Conunonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. York. The Plaintiff and Defendant were married on August 17, 2001 in Watertown, New 5. There is one (1) minor child born of this marriage, being Gavin Pritchard born November 10, 2001. 6. The parties separated on January 25, 2004. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff`nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiffhas been advised that counseling is available and that Plaintiffhas the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiffrequests entry of a divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Bryan D. Pritchard, prays this Honorable Court to enter judgment: 2 A. Awarding Plaintiff a decree in divorce; and B. Awarding other relief as the Court deems just and reas able. Dated: February 5, 2004 ~ Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BRYAN D. PRITCHARD, Plaintiff MICHELLE L. PRITCHARD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, BRYAN D PRITCHARD, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are tree and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: ~/.~-~_~ BR~RN D. PRITCHARD Barbara Sumple-Sullivan. Esquire Supreme Court//32317 549 Bridge Street New Cumberland. PA 17070 (717) 774-1445 BRYAN D. PRITCHARD, Plaintiff MICHELLE L. PRITCHARD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. O'/.,Ct¢ : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. BR D. P Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BRYAN D. PRITCHARD, : IN THE COURT OF COMMON PLEAS Plaintiff V. MICHELLE L. PRITCHARD, Defendant · CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-564 : CIVIL ACTION - LAW ' 1N DIVORCE ACCEPTANCE OF SERVICE I, Michelle L. Pritchard, hereby accept service and acknowledge receipt of the above- captioned Complaint in Divorce, having received said Complaint on the fa)9 day of February, 2004. ichelle L. Pritc~ ' Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BRYAN D. PRITCHARD, Plaintiff MICHELLE L. PRITCHARD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-564 : CIVIL ACTIQN - LAW : 1N DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(¢) of the Divorce Code was filed on February l0,2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. BI~i~N D. PRITCHARD Barbara Sumple-Sullivan, Esquire Supreme Coua #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BRYAN D. PRITCHARD, : IN THE COLrRT OF COMMON PLEAS Plaintiff V. MICHELLE L. PRITCHARD, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-564 : 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 ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 statement herein are made subject to the penalties of 18 Pa. CS. §4904 relating to unsworn falsification to authorities. N D. PRITCHARD Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 : IN THE COURI OF COMMON PLEAS ~RYAN D, PRITCHARD, Plaintiff MICHELLE L. pRITCHARD, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-564 : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSEN2l' A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 10, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce alter service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning; alimony, division of property, lawyer's fees or expenses ifI do not claim them before a diw>rce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. / MICgtELLE ~r txt Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 : IN THE COURT OF COMMON PLEAS BRYAN D. PRITCHARD, Plaintiff MICHELLE L. pRITCHARD, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO 04-564 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 ifI 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 alter it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S §4904 relating to unsworn falsification to authorities. ~MICHELLE L p~I~TCHARD COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared MICItELLE L. pRITCltARD, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §:}301(c) OF THE DIVORCE CODE arc: true and correct to the best of her knowledge, information and belief. Affirmed and subscribed to before me this /~ g4fday of ff~ 2004. I.~BLIC My Commission Expires: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BRYAN D. PRITCHARD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE L. PRITCHARD, Defendant · NO: 04-564 _. · CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 2004. 1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service &the complaint: Acceptance of Service dated February 12, 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff: May 21, 2004; by Defendant: May 13, 2004. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §33011 May 27, 2004. Date Defendant's Waiver of Prothonotary: May 27, 2004. Dated: May ,2004 (c) Divor/m~as filed with Prothonotary: Notice ~/{;3~c/~<~l)Jy~orce was filed with 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 ~717) 774-1445 BRYAN D. PRITCHARD, : 1N THE COURT OF COMMON PLEAS Plaintiff V. MICHELLE L. PRITCHARD, Defendant : CLrlVlBERLANI) COUNTY, PENNSYLVANIA NO: 04-564 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: DATED: May ~:~2004 Ms. Michelle R. Pritchard 18 W. Big Spring Avenue Newville, PA 1724,~,// / omoiaia *il p e-Sullivan, Esquire // 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS BRYAN D. PRITCHARD, Of CUMBERLAND COUNTY STATE Of PENNA. Plaintiff VERSUS MICHELLE L. PRITCHARDt Defendant 04.-564 NO. AND NOW, DECREED THAT AND DECREE IN DIVORCE 2004 BRYAN D. PRITCHARD MICHELLE L. PRITCHARD ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLIOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD iN THIS ACTION FOr WHICH A FINAL ORDER HAS NOT YET been ENTERED; None. PROTHONOTARY IN TI:W, COURT OF COMMON FLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : Vs : File No. Defendant : : IN DIVORCE NOTICE TO RESUME PRIOR SU~RNAME Notice is hereby given that the Plaintiff/defendant in the above matter, [select one l{y marking "x"] prior to the entry of a Final Decree in Divorce, or ~ aftertheentryofaFinalDeereeinDivorcedated ~!/~V. hereby elects to resume the prior surname of ~C~I[~ L.~vi Il('2 , and gives this written notice avowing his / her intention pursuant to the provisions' o£ 5~P.S. 704 Jtll_,-~ [tZ,O0~ / Signatfre Date: ~' Signature ofname'~be~mg resumed /,4~bl~.llc /--. 5~iu/'ll~.. com oNwnA ra oF P ,NNS VAN A ) COUNTY OF Onthe/'~4~ dayof 0(~-~, ,200_f-{beforeme, the Prothonotary or the__ notary public, personally apPeared tlle above affiant known to me to be the person whose name is subscribed to the w/thin document and acknowledged that he / 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 NOTARIAL SEAL CLAUDIAA BREWBAKER, NOTARY PUBLIC Carlisle Berm Cumberland County My Commission Expires April 4, 2005