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
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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
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SAXE)IS,
26 West High Street
Carlisle, PA
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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
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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
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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
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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
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