Loading...
HomeMy WebLinkAbout08-3637APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION :NO. ?}$ - 3(037 Ciivi -le rw? 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 at: Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANULLMENT 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 APRIL KATHLEEN MICHAEL Plaintiff, VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION BRADLEY ALAN MICHAEL Defendant NO. OP, 34,31 Ct;,e 7; tom.... COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is April Kathleen Michael, who currently resides at 1102 Market Street, Unit 16, New Cumberland, Cumberland County, Pennsylvania since approximately June 2007. 2. Defendant is Bradley Alan Michael, who currently resides at 945 A Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania since approximately January 2005. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least sik months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 8, 2001 at San Marcos, California. 5. There have been no prior actions of divorce or 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. 1? Date avid C. Anderson PA Attorney ID # 82573 Anderson & Gulotta, P.C. Attorney for Plaintiff 1110 North Mountain Road Harrisburg, PA 17112 Phone: (717) 635-7145 Fax: (717) 541-5434 VERIFICATION 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 unworn falsification to authorities. Q f \k (? ? ?? Date April Kathleen Michael Plaintiff . . • APRIL KATHLEEN MICHAEL IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION BRADLEY ALAN MICHAEL Defendant NO. ACCEPTANCE OF SERVICE I accept service of the "Complaint under Section §3301(c) of the Divorce Code." 611616) r Date erad1`ey-AIan Michael 945 A Bosler Avenue Lemoyne, PA 17043 t7 rte sa' z ??-" ,. c APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION : NO. 2008-03637 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 at: Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANULLMENT 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION : NO. 2008-03637 FIRST AMENDED COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is April Kathleen Michael, who currently resides at 1102 Market Street, Unit 16, New Cumberland, Cumberland County, Pennsylvania since approximately June 2007. 2. Defendant is Bradley Alan Michael, who currently resides at 945 A Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania since approximately January 2005. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 8, 2002 at San Marcos, California. 5. There have been no prior actions of divorce or 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. V12gilmi Date Xavid C. Anderson PA Attorney ID # 82573 Anderson & Gulotta, P.C. Attorney for Plaintiff 11 IO'North Mountain Road Harrisburg, PA 17112 Phone: (717) 635-7145 Fax: (717) 541-5434 VERIFICATION I verify that the statements made in this First Amended 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 unworn falsification to authorities. (:? 1 a<< /CSC Date ?h April athleen Michael Plaintiff APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION NO. 2008-03637 ACCEPTANCE OF SERVICE I accept service of the "First Amended Complaint under Section §3301(c) of the Divorce Code." 9 1 7 0) O ?' - - Date Brad `ey Alan Michael 945 A Bosler Avenue Lemoyne, PA 17043 ,d C7 rv ? . ?.' ? _:? ? n ,,,, ?-.. ?'..r, - ??- i r?? { C.r`7 r _ ? ? . ?? -z'i ......, ?4r ?? ??_ " r'tii ---? ?? APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNS'Y'LVANIA : CIVIL DIVISION NO. 2008-03637 AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 18, 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. 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 unworn falsification to authorities. Date April Kathleen Michael Plaintiff M s -?a M APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION : NO. 2008-03637 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 unworn falsification to authorities. Date April aMichael Plaintiff t E5 r APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION NO. 2008-03637 AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 18, 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 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 unworn falsification to authorities. D Ate Bradley Alan Michael Defendant t1a C=p fT r I APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION NO. 2008-03637 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 unworn falsification to authorities. Date Bradley Alan Michael Defendant - F r-? - M1a 'ma - c t APRIL KATHLEEN MICHAEL Plaintiff, VS. BRADLEY ALAN MICHAEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION NO. 2008-03637 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: The complaint was filed on June 18, 2008 and the Defendant accepted service on June 16, 2008 by signing an Acceptance of Service which was filed on June 18, 2008. 3. An amended complaint was filed on July 25, 2008 and the Defendant accepted service on July 3, 2008 by signing an Acceptance of Service which was filed on July 25, 2008. 4. Date of execution of the affidavit required by § 3301(c) of the Divorce Code: by Plaintiff September 10, 2008; by Defendant September 12, 2008. • 5. There are no related claims pending. 6. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: October 3, 2008; Date Defendant's Waiver of Notice was filed with the Prothonotary: October 3, 2008. 00 Date d C. Anderson PA Attorney ID # 82573 Anderson & Gulotta, P.C. Attorney for Plaintiff 1110 North Mountain Road Harrisburg, PA 17112 Phone: (717) 635-7145 Fax: (717) 541-5434 t "IF C-5 t N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY tr4k STATE OF PENNA. APRIL KATHLEEN MICHAEL VERSUS BRADLEY ALAN MICHAEL N O. 2008-03637 DECREE IN DIVORCE AND NOW, C9C4Vot-N--- Z` IT IS ORDERED AND DECREED THAT APRTT. KATHT.P.FN MT['!HAF.I, ,PLAINTIFF, AND BRADLEY ALAN MICHAEL 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 err ? ? 4qr-- j 'Sp- ??? .? ..?;??'? °??J .?o • ??- of