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HomeMy WebLinkAbout04-0681 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA L. PROV ARD, Plaintiff . . CIVIL ACTION -LAW . . . . vs. NO.04- (:,fl CIVIL TERM NICHOLAS A. PROV ARD, 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 the 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,First Floor, Cumberland County Courthouse, Carlisle, Pennsylvania 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 32 South Bedford Street Carlisle, P A 17013-3302 Telephone number: (717) 249-3166 Toll Free (in PAl 1-800-990-9108 CHRISTINA L. PROV ARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW . . . . V8. . . NO. 04- CIVIL TERM NICHOLAS A. PROV ARD, Defendant . . IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE PENNSYLVANIA DIVORCE CODE 1. Plaintiff is Christina 1. Provard, who currently resides at 109 Locust Street, Borough of Shippensburg, Cumberland County, Pennsylvania since December 26,2003. 2. Defendant is Nicholas A. Provard, who currently resides at 1226 Mainsville Road, Shippensburg, Franklin County, Pennsylvania since October 2002. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on July 3, 2002 at Shippensburg, Cumberland County, Pennsylvania 5. There have been no prior actions of divorce or for annulment between the parties. 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 ~GcJ\G-"'~~\r(l-r0 \Shristina L. Pro~, Plaintiff Date: February 9, 2004 S)~ C.. ~ David P. Perkins Attorney for Plaintiff Attorney ID. No. 34342 4 James Circle Shippensburg, PA 17257-2165 Telephone: (717) 658-6531 ~f\ ..... ~ ~ ~ e. ........ ~ \ \ ~ "'\ <:;) C) ~.~ -, Co:; "" -:-:" c;:.> ~ ...., ....., c::.. o ., 7., ,0/(.;:_ ~'r-, :'"";1 ~;)i..J ~.) I., ___~r-, ... -r; 5;~;' '..>"", ',;rn --~i , .,~ "-< ~ -! S:) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA L. PROV ARD, Plaintiff CML ACTION -LAW V8. NO. 04-<:&~ I CML TERM NICHOLAS A. PROV ARD, Defendant IN DIVORCE ~ ACCEPTANCE OF SERVICE ~.~.& .. INIl.~ .,. _ acce~ervlce of the Complaint In Divorce In the above captioned matter. Date: 3}7 / .2004 :(/~:!:~lfh a1:l} ~ Address: 10,1-jG "D"uR 5 I<~p..t:. CJ.. E c:..'Wt. .sPR II'ol G "" D , '2..I"""1L..L U' ':'::1 ( ~ (~5 '\' r~:~:: "- o (rJ ___ L'__ (,:.') C'; :.:c .",.. <= 1.:= '''' ) () , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA L. PRO V ARD, Plaintiff CIVIL ACTION -LAW VS. NO. 04- 681 CIVIL TERM NICHOLAS A. PROV ARD, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on February 17, 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. 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. q 4904 relating to unsworn falsification to authorities. Date: ":'>-/0 -O:j PLAINTIFF .---- , c - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHRISTINA L. PROV ARD, Plaintiff CIVIL ACTION -LAW VS. NO. 04- 681 CIVIL TERM NICHOLAS A. PROV ARD, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER g3301(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 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. 1; 4904 relating to unsworn falsification to authorities. Date: S~ IO'O'S fh~~ cJ.i CHRISTINA L. PROVARD, PLAINTIFF ..----- " ~~.-.J ,. c: .><,' f"'l - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHRISTINA L. PROV ARD, Plaintiff CIVIL ACTION -LAW VS. NO. 04- 681 CIVIL TERM NICHOLAS A. PROV ARD, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(C) of the Divorce Code was filed on February 17, 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. 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. q 4904 relating to unsworn falsification to authorities. Date: 6lafr~ Mt#tY a ~ NICHOLAS A. PROVARD, DEFENDANT ~,-.- -,- ',..~ ~~".', ,.,' . r-::; <.} ~ - ------ " .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHRISTINA L. PROV ARD, Plaintiff CIVIL ACTION -LAW VS. NO. 04- 681 CIVIL TERM NICHOLAS A. PROV ARD, Defendant 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 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. I:; 4904 relating to unsworn falsification to authorities. Date: .; j ujl/f) --/t4'~t./L.b d ~./~ NICHOLAS A. PROVARD, DEFENDANT C"'". <".., ..... ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA L. PROV ARD, Plaintiff CIVIL ACTION -LAW VS. NO. 04- 681 CIVIL TERM NICHOLAS A. PROV ARD, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I Nicholas A. Provard accepted service of the Complaint in Divorce in the above captioned matter on March 17, 2004. Date: May 13 ,2005 ~I!~~ Nicholas A. Provard Address: 10692 Burkett Road Greencastle, PA 17225 ,,~- :.' ,--,' <: --~.,~~_.~'"~"-'""'~..-->.., , ,-' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA L. PROV ARD, Plaintiff CIVIL ACTION -LAW VS. NO. 04 - 681 CIVIL TERM NICHOLAS A. PROV ARD, Defendant 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: 1. Ground for divorce: irretrievable breakdown under S3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: March 17, 2004, acceptance of service by Defendant. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by S3301(c) of the Divorce Code: by Plaintiff on May 10,2005; by Defendant on May 13,2005. (b)(1) Date of execution of the affidavit required by S3001(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiffs affidavit upon the respondent: 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 a copy of which is attached: Not applicable. (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: May 18, 2005. Date Defendant's Waiver of Notice was filed with the Prothonotary: May 18, 2005. g~ c;~ David P. Perkins, Esquire Attorney for Plaintiff -- ---- r ( /~ ,~-~ .J..") :;.:"'" C'~ - . . . . . . . . . . . . . . . . . . . . . . . + . . + + + + . + . . . + + +:+' '+' ~ '+' . . . . . + . . + . . . . . . . . + . . + . . . . . . . . . . . If. :f.1f.:t::f.;+;;+; . H . ... .. H+ :+ :+++.+. :+:f. +.:f.+.+':++.+:+:+ ++.+.+.+. .+ . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY CHRISTINA L. PROVARD PENNA. STATE OF NO. 04-681 Civil Term Plaintiff VERSUS NICHOLAS A. PROVARD Defendant . . . . . . . + . + + . + . + . + . + . + . . + . + . . + DECREE IN DIVORCE 2005 ~Y'- may AND NOW, IT IS ORDERED AND --' CHRISTINA ~. PROVARD DECREED THAT , PLAINTIFF. NICHOLAS A. PROVARD AND , 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 . . . . . + . . . . . . . . J. : . . . + . PROTHONOTARY + . . . . ++.:++.:+ +.++++.:++.:+:++.+:+:++ + . . :+ +:+:+:+:++. +. +:++ :+:+:++.:+ ++:+:+::+:+:++:+:+:++ :+++ .'l'+.+ :+:+ +. +'+ + . . . . . + . . . . . . + . . . + . . . + . . + . . + + . . . . . . + . . . . + . . . + . . + + + + + + . + + . + + . . + . . . . + . . jp 'Z ft~,f /!'rvL. 4vrc ?- ~w 447 PI) ~:;r . )-t" - ,- <;0 ,n > _)0' ".::' ,':i ------.-.-- --..,....-."..-..