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HomeMy WebLinkAbout04-1125 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA TAMMY 1. HERR. vs. No. 0 '1- 112~ Civil Tenn WILLIAM A. BOYCE, Defendant ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in COUl1. If you wish to defimd 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. Where 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 at the Office ofthe Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A T 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 S1. Carlisle, Pa. 17013 (717) 249-3166 Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TAMMY 1. HERR, vs. No. Civil Term WILLIAM A. BOYCE, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Tammy 1. Herr, a competent adult individual, whose address is 41 BeachcliffDrive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is William A. Boyce, a competent adult individual, who resides at 3741 Canyon Lake Drive, Apt 2-305, Rapid City, SD, 57702. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on April 15, 2002 in Rapid City, South Dakota. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Plaintiff is not a member of the Armed Forces of the United States of any of its allies; Defendant is employed full-time by the Air Force and is currently working in South Dakota. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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 unsworn falsification to authorities. T~~"t'Pif) Date: JIofth I (JIb d(jf{ J e Adams, Esquire .D. No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~r\ .......... ~ "'" '''';.'', 1)' " ~, ~. --- /' ~ c J1 ~ -...., -.!) C u' \ <::" 1"".) ~'-.J s.~ .-4 -.., ~. .J ii, _..1 C.~l TAMMY 1. HERR, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 04 - 1125 Civil Term WILLIAM A. BOYCE, Defendant ACTION IN DIVORCE ACCEPTANCE OF SERVICE PURSUANT TO PA.R.C.P 4 02(8) AND PA.R.C.P. 1920.4 I, William A. Boyce, Defendant in the above-captioned matter, hereby accept service of the Notice to Defend and Complaint in Divorce. I hereby waive any and all defects in service of the aforementioned Complaint or any amendments hereto. Date:/3..if.rclo '-/ ~/L~ William A. Boyce, Defend (') ~; ~:u: ,--. .; 0iS~ ~.: I~~ (' ~~ ;;::; _.~ -< ....., = c::> .e- X ~. ;;;0 w o o ...., ~:rJ :J:lfn ?39 ;~~ o:D z~ 9 ,", <~ :< ?~ ...;;: <? ... o Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TAMMY L. HERR, VS. No. 04 - 1125 Civil Term WILLIAM A BOYCE, Defendant ACTION IN DlVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 17,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: '\ . 0'1' 05 I / tl.:ltiU Tammy L. Hcrr /~l WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(0) AND &3301ld) OF THE DIVORCE CODE I. I consent to 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 rel~ to unswom falsification to authorities. // (~""'/hIJ.il -) ../ /(.&UA.<-<-<v cA '~" Tammy L. H~ Plaintiff Date: d. c 0'1' oS- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TAMMY L. HERR, VS. No. 04 - 1125 Civil Term WILLIAM A BOYCE, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under section 3301(c) ofthe Divorce Code was filed on March 17,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service ofthe Complaint. 3. I consent to the entry ofa 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 also understand that false statements herein are made subject to the penalties of] 8 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: :;2,,' I go. O.s- dd /-f'~--" William A. Boyce, Der. ant WAIVER OF NOTICE OF INTENnON TO REOUEST ENTRY OF A DIVORCE IlECREE UNIlER &3301(.) AND &330Hd) OF THE DIVORCE CODE 1. 1 consent to 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 Prothonotar:y. 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.e.S. ~4904 relating to unsworn falsification to authorities. Date: ), I g -oY- -aP~~ William A. Boyce, dant Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA TAMMY L. HERR, vs. : No. 04 - 1125 Civil Term WILLIAM A BOYCE, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RE:CORD TO THE PROTHONOTARY: Transmit the record, together with the following infonnation to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under .s.330J(c) of the Divorce Code. 2. Date and marmer of the service of the Complaint: Delivered by Federal EX{lress. on: March 18, 2004. (Defendant signed an Acceptance of Service). 3. Date of execution of the affidavit of consent required by 3301(c) ofthe Divorce Code: By Plaintiff: February 9, 2005. By Defendant: February 18, 2005. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divon:e was filed with the Prothonotary: February 23,2005. Date Plaintiff's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: February 23, 2005. Date: ap~06- Respectfully Sl.!J>mitte<;l: C~?U!___{_ LQ (/ J e Adams, Esquire , - .D. No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. ;+:,+;;j; 't: Of. +. :+ if +; Of.:I: 'f. 'Ii ;to Of:+ "';!' :f. +.:t' +. 'f. +. Of.:+ :f. 'f:+ ~ 'f. Of. OJ':t;+::+ ... . . .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Tammy L. Herr, Plaintiff No. No. 04 - 1125 Civil Term VERSUS William A. Boyce, Defendant DECREE IN DIVORCE AND NOW, fVl~~ ~ ~:!"A.~ )ooS , IT is ORDERED AND DECREED THAT Tammy L. Herr . PLAINTIFF. William A. Boyce AND , 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 YET BEEN ENTERED; None. By ATTEST: ,t~~ ~ .- OTHONOTARY 0< . . . '+' 'l' +. :f Of "I' :+:+"10 +. + '+' +. +. 'f++.'<' +'f:+:+:+ . . 'f +. +. Of Of' + +.++++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . +. +. +. ++ . pip ~ ~ ~JCl,eI" ~ jff 12 ~- ~.p7) yr?" eI . . .