The URL can be used to link to this page

Home My WebLink About08-4562JOSHUA R. MARTIN, Plaintiff VS. AMBER MARTIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. f - 4T to ;2 414 IN DIVORCE 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 Cumberland County Courthouse, 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, 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania _ (717) 249-3166 eAu4ire An ony L. D ca, 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 JOSHUA R. MARTIN, Plaintiff VS. AMBER MARTIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 0?- SISL a2 CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is JOSHUA R. MARTIN, who currently resides at 548 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, since June 18, 2008. 2. Defendant is AMBER MARTIN, who currently resides at 103 West Butler Street, Mt. Holly Springs, Cumberland County, Pennsylvania, since September 29, 2003. 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 October 14, 2003 at Kingswharf, Bermuda. 5. There have been no prior actions of divorce or for 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. 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 unswom falsification to authorities. OSHUA R. MARTIN, Plaintiff Date: Anthony L. De u Esquire Attorney for Plamtiff 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 (717) 258-6844 ID# 18067 s r? J7 SZ ??; F ,E, >>? Y 2010 JUN -7 N 4: J2 JOSHUA R. MARTIN, : IN THE COTUTU. 1~. COMMON, AS OF Plaintiff CUMBERL , r YLVANIA VS. CIVIL ACTION -LAW AMBER MARTIN, NO. 08-4562 Civil Defendant : IN DIVORCE 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on duly 29, 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: C> Amber Martin, Defendant JOSHUA R. MARTIN, Plaintiff VS. AMBER MARTIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 08-4562 Civil IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) OF THE DIVORCE CODE I . I consent to the entry of a final decree of divorce without notice. y .. ° t C7 _J cv N .`j NIP j .r 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. 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. § 4904 relating to unworn falsification to authorities. -- Date: T it, Amber Martin, Defendant J• j OSHUA R. MARTIN. Plaintiff VS. AMBER MARTIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 08-4562 Civil IN CUSTODY STII'CI.I?ATTnN t'- N AATHTFR Fa S, the pa ties 1-r- kZ,- nt ac to "l a cult; dy ark a vici? ?fW,? ^? C1'1 tb - Karlie Paige Martin and Logan Tyler Martin born to the parties, and wish a Court Order to reflect that Agreement; THEREFORE, with due consideration for the welfare of said children, both parties hereby agree as follows to wit: Majority physical custody of said children, Karlie Paige Martin and Logan Tyler Marvin, and visitation of said children shal? be detennined by an Agreement executed by the parties hereto, attached hereto as Exhibit "A", and made a. part hereof and incorporated herein by reference. 2. It is contemplated and requested by the parties hereto that this Agreement be adopted by Order of Court. WITNESS: oshua R. Martin Amber Martin JOSHUA R. MARTIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW AMBER MARTIN, NO. 08-4562 Civil Defendant IN DIVORCE 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 29, 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 unsworn falsification to authorities. Date: ? "JJ I u . ?_ - o/J shua R. Martin, Plaintiff r? ' % ?.^ . JOSHUA R. MARTIN, Plaintiff VS. AMBER MARTIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-4562 Civil IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) 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 unswom falsification to authorities. Date: i - /;, n oshua R. Martin, Plaintiff , i7-:! n? u ,-t v:? JOSHUA R. MARTIN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMBER MARTIN, VS. CIVIL DIVISION Defendant NO. 08-4562 CIVILTERM 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) =074OXyof the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: August 6, 2008 by certified mail, restricted delivery. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff June 30, 201 0 ; by defendant May 5, 2010 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: ?Yy(y /-?.4'/d Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 7, 2010 for Plaintiff /•Bef t- (T E 2 (' >> UNITED STATES POSTAL SERVICE 111111 First-Class Mail Postage & Fees Paid USPS Permit No. G-10 • Sender: Please print your name, address, and ZIP+4 in this box • Al TXo/7 be-Z&,,CoV I S 446(1. T 0". ?, 4?CSc? -If f 1111111,111Ito 111„ I I I Ili I h Id IJ<< I t lilt fill IIIJ JOSHUA R. MARTIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. AMBER MARTIN NO. 08-4562 DIVORCE DECREE AND NOW, <IL4 If, zoi o , it is ordered and decreed that JOSHUA R. MARTIN , plaintiff, and AMBER MARTIN , 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, - zv-4 J. Prothonotary x•15• )O 7.15.10 ?Vo?'ri cA, M a % ,Q?O) 4-0 f?H-? ?) e.L Lkcc`, rna, (ki AAcaZl .-.4- ~AU6 05 Y910 JOSHUA R. MARTIN, IIV THE COURT OF COMMON PLEAS OF Plaintiff ;CUMBERLAND COUNTY, PENNSYLVANIA VS. :CIVIL ACTION -LAW AMBER MARTIN, NO. 08-4562 Civil Defendant IN CUSTODY AND NOW, to wit, this ~~day of 2010, the Court ado is the A Bement of the P ~ parties concerning the custody and visitation of the children, Karlie Paige Martin and Logan Tyler Martin, as the Court's own Order. A copy of that Agreement is attached hereto and made a part hereof as fully as if entered specifically by the Court. We direct that a copy ofthis Order be furnished to both parties. Y _ COURT, J. - o~~_ _~ _ - _ i/ ~h~ph ~ .'_ . y L- ~~-uea Esy.- ~ , .,A ~._ lJ ~ CDpieS itlrti, ltGi~ g~~~G ~~~