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HomeMy WebLinkAbout08-2670GLENN E. FITTING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYVLANIA V. CIVIL ACTION - LAW NO. MOLLY FITTING, Defendant IN DIVORCE NOTICE TO DEFEND 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWE" LJAIPSAY SAIDIS, FLOWER & LINDSAY A WINEYS•AT.IAW 26 West High Street Carlisle, PA Carol J. Li sa Esquire Attorney 14. 44603 26 West HI treet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff GLENN E. FITTING, Plaintiff V. MOLLY FITTING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYVLANIA CIVIL ACTION - LAW , NO. Of- Z & 76 8,,u 7. --- IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Glenn E. Fitting, an adult individual, residing at 19 Otto Avenue, Carlisle, PA 17013. 2. The Defendant is Molly Fitting, an adult individual, residing at 1550-A Holly Pike, Carlisle, PA 17013. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 25, 1994 in Mount Holly SAMIS, FLOWER &z LINDSAY ATI VW.S-AT•uw 26 West High Street Carlisle, PA Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, FLOWER & LINDSAY t Carol J. LiWdquire Attorney I26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY ATTOMBSS•AT IAw 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. Glenn . Fitti" Date: ?-. ??-0g SA MILS, LINDS n?LAW 26 West High Street Carlisle, PA _., ?? ;? L!?) r?; r z?. ('_ c r ? e eht h.J ,` ? ` r? `? ? (,?? r' GLENN E. FITTING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYVLANIA V. CIVIL ACTION - LAW NO. 70 civil hvm- MOLLY FITTING, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on April 30, 2008, 1 served a true and correct copy of the Complaint in Divorce upon Defendant, Molly Fitting, by mailing those documents to the her address at 1550-A Holly Pike, Carlisle, PA 17013 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Molly Fitting. Respectfully submitted, Dated: May 8, 2008 F? RR & LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY Carol J. d y, Esquire Attorn . 4693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff R r SAXE)IS, 26 West High Street Carlisle, PA ¦ Complets Alm 1, 2. and 3. Also Cortlpiste it am 4 N Anhtotsd DWWay Is de.ked. ¦ PrW yow nsnisand address`o l the reverse so that we ow Helium the card to you. ¦ Attach this card to the back of the maViece, or on the front N apaos permits. 1. Article Adk seed to: C,a_, Its X7013 ? AQSW Adft R,/lr by i?+M???9?/ /?c.- , of Del 0. le dsfvely iddieee diterrt aem l? ? Yee 0 YES, ~ d@lWwy 14 1 below. fX No 3. Service lype O C~ Mid O 6cgeee and 17 Registered O R•ttan Reoelpt for mimidterwhe O mand Affil 13 G.o.D. 4. ReeAeict•d DeNvery? Xft Fee) rie 2. 7004 1350 0003 7286 2460 (ihengbr Aonr souks ?!4 re Form 38110 Feenrery JIM Dearwre Raft ftsm" >oeess?saFmro C3 CERTIFIED M AIL, R ECLIP I (Domestic Only; No Insuranc e Coverage Provided) ru . deliver m y I OFFI CIA L USE I ti r? Poette $ 52 M C3 Certilled Fee C3 Q (Endoraenrerrt eqRearm R RWW Fee urem v1 o Postinark Here 0 m Restricted Delivery Fee (Endorsement Required) a 10 rl Total Postage & Fees $ '7 R C3 SON T OL0 i6 64-11 -n - - - 3 -- ----------------------- ------------------ ---- j orPOBoxNa 1i1- FAG-- -(----- ?t 1-7-D! -- --- - air, ik, b ,t fills y > GLENN E. FITTING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYVLANIA V. CIVIL ACTION - LAW MOLLY FITTING, NO 0? b2 (0 Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on April 25, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsifica ' to au n ies. Date: U 2 Zf?C?g Glen E. Fitfin - 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, la%Tees fees or expenses if I do nct clair± there before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the SAIDIS, FWNVER & LINDSAY ATIOINE15•AT1Aw 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to gives Date: tit E. Fittin .., -, ? ?-? i ?.. ' ? .. r„; ?. '? " ? ? , , ` 3 r ? t,.i __.. ,. _ .. ?.,? C..7 GLENN E. FITTING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYVLANIA V. CIVIL ACTION - LAW NO. of, aU74 MOLLY FITTING, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on April 25, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsifi ti n to authorities. Date: XP M ly Fittin DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY DECREE UNDER-4 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a Divorce Decree is entered by the FLOWER & LINDSAY 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties f 18 Pa.C.S. 4904 relating to unswom falsification to authorities. Date: 01 Molly Fittin Sv "'G R { ? ^ r^ l.?l ,J^ t ' 1 q.?3 ? GLENN E. FITTING, Plaintiff V. MOLLY FITTING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYVLANIA CIVIL ACTION - LAW NO. 08-02670 IN DIVORCE PRAECIPE TO TRANSMIT RECORD By Plaintiff: August 2, 2008 and tiled with Prothonotary on August 5, 2008 By Defendant: August 11, 2008 and filed with Prothonotary on August 18, 2008 4. Related claims pending: None. SAMWER ?IS ? LINDSAY 26 West High Street Carlisle, PA To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on April 30, 2008, via certified mail. Proof of service was filed with the Court on May 9, 2008. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: August 2, 2008 and filed with Prothonotary on August 5, 2008 By Defendant: August 11, 2008 and filed with Prothonotary on August 18, 2008 SAIDIS, FLOWER & 1-1150SAY Carol J. Linds struire Supreme CouttZ No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 I r } Fil _ 3 _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. GLENN E. FITTING NO 08-02670 No. VERSUS MOLLY FITTING DECREE IN DIVORCE AND NOW,- IT IS ORDERED AND GL NN E. FITTING DECREED THAT AND MOLLY FITTING ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD )THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Qkg.- -i+,*- BY THE CVURT: ATTEST: J. S C??z /f ?a ?. Ce?P THONOTARY ..v