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Home My WebLink About08-3318HAROLD S. IRMN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 24346090 ATTORNEY FOR PLAINTIFF JAMES R. WASHINGTON, 111 no IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2008 - 33 /7' CIVIL TERM KRISTINA L. WASHINGTON, 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 in 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 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, 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, Pennsylvania 17013 717-249-3166 JAMES R. WASHINGTON] 111 Plaintiff V. KRISTINA L. WASHINGTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008 - -33151" CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION SS01?c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is JAMES R. WASHINGTON, III, an adult individual residing at 446 1sT Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is KRISTINA L. WALKER, an adult individual residing at 898 Bistline Ridge Road, Loysville, Perry County, Pennsylvania 17047. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on June 26, 2003, in York, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. 14AY 21 2008 " 41 % JAMES R. WAS I GTON, III, Plaintiff HAROLD S. IRWIN, (11 Attorney for Plaintiffs 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 cl:D co ;3 R ? JAMES R. WASHINGTON, 111 Plaintiff V. KRISTINA L. WASHINGTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008 - 3 3 i 5r CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 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. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. - 7,7 , 2008 WT AMES R. WAS O N, III, Plaintiff cC`3 rv cr) U? CZ) HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF JAMES R. WASHINGTON,111 Plaintiff v. KRISTINA L. WASHINGTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - 3318 : IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT Please reinstate the attached complaint in divotce. May 6, 2009 ROLD S. IRWI , III Attorney for Plaintiff ,? FiLEi?:,t= ?c;F, OF TP" nR 01'€"`,`g0TARY 2009 MAY -7 PM 24 23 :$10.00 Pb AT'r/ -r I asai R JIA4 TO c?. HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF JAMES R. WASHINGTON, 111 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2008 - 3318 CIVIL TERM KRISTINA L. WASHINGTON, ; Defendant : IN DIVORCE U.S. Postal Setvwf? C3 CERTIFIED MAIL RECEIPT co (Domestic Mail Only: No InsLirance Coverage Provided) M Ln rul OFFICIAL USE r ' Postage $ '.1 Y ru Certified Fee C3 Return Receipt Fee Postmark O (Endorsement Required) Here Restricted Delivery Fee h O (Endorsement Required) V r =1 cD Total Postage & Fees $ t 1) 1 ru co Sent To ,..•.• C3 t t O. •• ` ` •. or PO Box tvo. f? ----•- ._...•...__. ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the tack of the mallpleoe, or on the front if space permits. 1. Article Addressed to: :RISTINA 4ASHINGTO.- RON "721 451 : 'rILLERTON WE CAMBRIDGF ST_ _2I:IG PA 16403 A X '#Agent 04 ? Addressee B. Received l 1 C a 1qwlwy 0176 D. Is delivery ad&ew different tram rem 1? es If YES, enter delivery address f Ww. ? No 1I ?d ;.P'5-roe 17z'p ? Express Malt 7' Re&WId ? Return Reoefpt for Merchandise ? insured Mar ? o.o.D. i 2. Article Hurte?er rn MA 28112, Q 02, 29 12 5 38 0 r rra?r, service _ i Ps Form 3811, February 2004 Dornwuo Rearm Rsoelpt I M595-02-M-150 RED-- 140-' OF THE PROTHI- .`OT,RY 7009 AUG 2a PM 2: l¢'b 110 JAMES R. WASHINGTON, 111 : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYI:VA* V. : CIVIL ACTION - LAW ` a e : NO. 2008 - 3318 CIVIL TERM KRISTINA L. WASHINGTON, Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce ender Section 3301(c) of the Divorce Code was filed in this matter on or about May 28, 2008 and reinstated on May 7, 2009. Service of the complaint was made upon the defendant on or about August 17, 2009 ( see signed receipts previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the 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 divorce. November 'ZQ 2009 Lk) J1 M-4k --n"qtT& MES R. WASHINGTON ill WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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. Section 4904 relating to unsworn falsification to authorities. November -`e? 2009 MES R. WASHINGTON, IF Z fili?:?t=rtwE OF THE #?OWOAAY 2W DEC -9 Pty 3• 18 `MY PENNSWAMA JAMES R. WASHINGTON, 111 : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2008 - 3318 CIVIL TERM KRISTINA L. WASHINGTON, : Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about May 28, 2008 and reinstated on May 7, 2009. Service of the complaint was made upon the defendant on or about August 17, 2009 ( see signed receipts previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the 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 divorce. KRISTINA L. WASHINGTON WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 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 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. herein are made subject to the penalties of 18 Pa.C.S. Section 4904 authorities. I understand that false statements relating to unsworn falsification to H E!' - : x Mid:. /l 2004 DEC 16 PH a: 4 8 CIS N ; r 1-j Al JAMES R. WASHINGTON, III Plaintiff V. KRISTINA L. WASHINGTON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - 3318 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: On or about August 17, 2009, defendant was served with a copy of the divorce complaint (see Affidavit of Service and signed receipt filed on August 20, 2009). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: On or about November 15, 2009 By the defendant: December 1, 2009 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 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 to transmit record, a copy of which is attached: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: December 16, 2009 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: December 16, 2009 6. There has been no prior action for divorce or annulment between the parties other than this action which commenced on May 28, 2008. December 16, 2009 HAROLD S. I Attorney for Fj? 1J.., 2009 DEC 16 PH 3: 4 6 IN THE COURT OF COMMON PLEAS OF JAMES R. WASHINGTON, III CUMBERI. AND COUNTY, PENNSYLVANIA V. KRISTINA L. WASHINGTON NO 2008 - 3318 DIVORCE DECREE AND NOW, eG , ZZ Zdo , it is ordered and decreed that JAMES R. WASHINGTON, III , plaintiff, and KRISTINA L. WASHINGTON , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, J. Prothonotary is-30) 'o? is - 30 '°y' ? Y?a? '? see