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HomeMy WebLinkAbout08-4164.ti Erika R. Burdick Plaintiff V. Jonathan C. Burdick Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : NO. 08- )//b 41 CIVIL TERM : IN DIVORCE 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 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, 1 Courthouse Square, Carlisle, Pennsylvania. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 F Erika R. Burdick Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. Jonathan C. Burdick Defendant : NO. 08- CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is , who currently resides at 10 g s A N Cumberland County, Pennsylvania. 2. Defendant is - - ? LRIL ,C A who currently resides at Z L4 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on I UU JL'R Y-- ? at MT-"OLLY2-2? LNC?? IAA 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between.the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. V 4 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. JIa-'-R at Plaintiff, Pro Se I, A 'P,)uk0ZC verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. JGl ? at Plaintiff, Pro Se Assisted by: Melissa P. Greevy, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 (717) 761-4540 Erika R. Burdick IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- CIVIL TERM Jonathan C. Burdick Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you. that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute'a waiver of your right to request counseling. N C: ? G ? -'? e., ? i rc? r a ? ? s't `', ,_ _ ??? ?" ? {? ? ? - ?" -! ?' i... ??. r?'9 ? ?....' f`y ,..' y? 4 ' -` u? {'?J y Y? ? "'"?- 4C} Erika R. Burdick IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- ?/? ?f CIVIL TERM Jonathan C. Burdick Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Erika R. Burdick Plaintiff, to proceed in forma au eris. I, Melissa P. Greevy, attorney for the party proceeding in forma au eris, certifythat7I believe the party is unable to pay the costs and that I am providing free legal services to the party. Attorney for Plaintiff Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 (717) 761-4540 t ?.. , . _ -73 ?r --C Erika R. Burdick Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. Jonathan C. Burdick Defendant NO. 08- CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE I, ?c' t cl ie- bbeing duly sworn according to law, depose and say that on - ?- Q (Date of signing of the green card by spouse), I served a true and ,; correct copy of the Divorce Complaint upon the Defendant, by Certified Mail, Restricted', Deliver, addressed as follows: The Certified Mail Return Receipt Mailing Card ("Green Card"), for the foregoing is attached hereto and made a part hereof. ,?F ri Ala- Name Printed Sworn to and subscribed before me a Notary Public in and for Cumberland County, Pennsylvania this day of , 20. NOTARY PUBLIC My commission expires: a. 14 ATTACH GREEN RETURN RECEIPT CARD HERE i 9 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 back of the mailpiece, or on the front if space permits. 1, Article Addressed to: ?a C?•? mean 1????h.?-? { l\?etn , N y 1LI?I1?C A. Signature s f;?i /?f> ( X - 0 43 Agerit Addressee ?B. " yy?nted fYarne) C. Date of Delivery 'J an:1 u i,?rd 7'A'141-609" D. Is delivery address different from kern 1 ? 0 Yes If YES, enter delivery address below: 0 No 3. Service Type 9 Certified man 0 Ewsas Mail _ Ali agistetvd _-IXAetum Receipt for Merchandise 0 Insured mail 0 C.o.D. 4. Restricted Delivery? p" Fee) or Yes 2. Article Number 7006 2760 0002 7408 7204 Mansibrfrom spmce h PS Form 3811, February 2004 Domeatic Retrxn Receipt 102595.02-M-1540 A E, • ru ? delivery For t C +?ii,5 {111F_,?i Postage $ Certified Fee $2.70 r ^ •-? ti P t lu Return Receipt Fee $2.20f os m H,em C3 (Endorsement Required) 4 Restricted Delivery Fee {{ j {{3 1 C:3 (Endorsement Required) .A Total Postage & Fees $ 45.49 a 424-211.38 , oT???c.ri-lrss?c°Ah------..----- p Street, Apt. No.; 1 or PO Box No. t? a C r nnnon---)N.aQ ?k C'a r ?. .?., ._ _ . r° ? ?: , r-` r _• _ ERIKA R. BURDICK Plaintiff vs. JONATHAN C. BURDICK Defendant AFFIDAVIT OF CONSENT No. 08-4164 CIVIL ACTION - LAW IN DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 14, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce with out 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: 1- ERIKA R. BURDICK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA i > l__._) 1dT7 „? ERIKA R. BURDICK Plaintiff VS. JONATHAN C. BURDICK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4164 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 14, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3309(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce with out 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 above 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: / 0 - A9 - 08 NATHAN C. B DICK CTI ? W ? y Erika R. Burdick Plaintiff V. Jonathan C. Burdick Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : NO. 08- Af 1(a'- 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: Defendant signed Acceptance and Acknowledgment of Service form on 2.00$ 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, ?06Vr31o ZO4; by Defendant, bd4er2wmg. 4. Related claims pending. There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: NON k,6e r 3I zooR (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: NOW-Akjber 7h0$ Plaintiffs Social Security Number: 09-7•72- I8'-Lt8 I75-i04-4•384- Defendant's Social Security Number: Erika R. Burdick "-/a ?/'' CIO `4_ r ERIKA R. BURDICK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JONATHAN C. BURDICK NO 08-4164 DIVORCE DECREE 1AAJA d$ %01 -, it is ordered and decreed that AND NOW, ERIKA R. BURDICK plaintiff, and JONATHAN C. BURDICK 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. e Court, Attest: J. a ry ??? ? ??? `?' ?? ?? ?? ? ?c?? ? /?' ? 1?