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Home My WebLink About08-2268 JESSE RANDOLPH SMITH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ANGELA MARIE SMITH : NO.69 • ;J2L 0 CIVIL TERM Defendant : IN DIVORCE NOTICE 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 JESSE RANDOLPH SMITH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ANGELA MARIE SMITH : NO.C,e -.?.?`$ CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Jesse Randolph Smith, who currently resides at 1624 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania, since February 2008. 2. Defendant is Angela Marie Smith, who currently resides at 116 Big Spring Terrace, Newville, Cumberland County, Pennsylvania, since December 2004. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 11, 1999, at Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto 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. ti 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. Date: !- Q- 0?- Jesse BAKO&lph Smith, Plaintiff ANDREWS & JOHNSON By: Donald E. Jo n, Esq. Attorneys for aintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 Xj d --cz CD rQ jr -1u. JESSE RANDOLPH SMITH V. ANGELA MARIE SMITH Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 08-2268 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AND NOW, this dt"" day of April 2008, I, Ronald E. Johnson, Esquire, attorney for Jesse Randolph Smith, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at her residence at 116 Big Spring Terrace, Newville, PA 17241, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on April 16, 2008, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: Swo and subscribed to before me this day of April 2008. Public SHELLY SEXTON, Notary Public Carlisle Bbro, Cumberland County v C mrrussion Expires April 26, 2011 ;; 'fi'r .?_.. it ¦ Compote iteiris 1, 2, and 3. Also complete A. 13 Agent Rem 4 ff Restricted Delivery is desired. X ¦ Print your name and address on the reverse 13 Addressee so that we can return the card to you. . Recall ) C. Date of Delivery ¦ Attach this card to the back of the maiipiece, of on the front If space permits. D. Is eddrmms ? ? Yes 1. /Article Addressed to: If YES, enter del 0 No *jyi?5 --rerrue-c // //i j t C? Q•' lP ?/ 3 '%DeeRf leType d Mail a Ewen Mail (/?W ? Registered ? Return Receipt for Merchandise ? Insuwd ma O C.O.D. 4. 'Reshicted Delivery? (Ends Fee) Yes 2. Article Number 7007 1490 Goal 7953 7 817 (Tnvk%* nom servto Jebel) - -0 snap Ps Form 3811, Fdmmy 2w4 DOrrnstic Return SWW '°2'96'°2-M-1640 w Exhibit A r-° c° r JESSE RANDOLPH SMITH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ANGELA MARIE SMITH Defendant CIVIL ACTION - LAW NO. 08-2268 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 10, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: l s ?? - I ;t ?"e? Jes dolp mith, Plaintiff C'? G ? ? Via, ` f ?y'ts. ?-? ?"' `-?tc? ?? --? ,? : - t -rx : ? ?: =:? .;. (:? :? ?` ?_`, ?'- c.,? .-?. :? JESSE RANDOLPH SMITH V. : CIVIL ACTION - LAW ANGELA MARIE SMITH : NO. 08-2268 CIVIL TERM 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. §4904, relating to unsworn falsification to authorities. Date: _-1 DO k?? Ange Marie Smith, Defendant : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA G ?a w f w, ? tt v f.,, 4f f T}, ty . 1 i -7, 3 yy M ^ 6 ,. 3 JESSE RANDOLPH SMITH V. ANGELA MARIE SMITH Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-2268 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Aptil 10, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: Angel arie Smith, Defendant " ° ? C ? ? c?+ ? r? -' ? ?' 5 ? .•? c.r"` ? ? ?,. •; ? ?? a ? ^^c? ?? ?q . '! y?G ? ? < JESSE RANDOLPH SMITH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ANGELA MARIE SMITH : NO. 08-2268 CIVIL TERM 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. §4904, relating to unsworn falsification to authorities. Date: 7?1S - -0 Smith, Defendant G ?' JESSE RANDOLPH SMITH Plaintiff V. ANGELA MARIE SMITH Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-2268 CIVIL TERM 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 Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: April 18, 2008 by restricted certified mail return receipt requested 3. (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff July 14, 2008 ; by Defendant July 14, 2008 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 7/ ANDREWS & JOHNSON Date: July ?, 2008 Ronald E. J son, Esq. 78 West P fret Street Carlisle, PA 17013 (717) 243-0123 c, z- ? - ' ? c ? ? ? ? ?.. s,. ??; -? ??? ?, ?? ?' r? ? ?? ? ?w. L",, ' ?'? ;??, " ` ? .S ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JESSE RANDOLPH SMITH Plaintiff No. 08-2268 VERSUS ANGELA MARIE SMITH Defendant DECREE IN DIVORCE AND NOW, Z00$ , IT IS ORDERED AND DECREED THAT JESSE RANDOLPH SMITH PLAINTIFF, AND ANGELA MARIE SMITH ,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; Nd-Ar jr- BY THE COURT: ATTEST- J. PROTHONOTARY ?4v A `,