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Home My WebLink About04-1227LAURA J. ARMSTRONG, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. CXI - 12 7 (21 vi L'L_ ? ANDREW A. ARMSTRONG, : CIVIL ACTION-LAW Defendant : 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 the divorce is indignities or irretrievable breakdow of the marriage, you may request marriage counseling. A list of marriage counselors is avlable in the Office of the Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LAURA J. ARMSTRONG, : IN THE COURT OF COMMON PLEAS Plaintiff : DAUPHIN COUNTY, PENNSYLVANIA vs. NO. C>4/ ANDREW A. ARMSTRONG, : CIVIL ACTION-LAW/ Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Laura J. Armstrong, by her attorneys, Purcell, Krug & Haller, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Laura J. Armstrong, an adult individual whose current address is 144 Wyoming Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Andrew A. Armstrong, an adult individual whose current address is 124 West Portland Street #32, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 5, 1999 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there is one child of the parties under the age of 18: Christian T. Armstrong, born July 8, 1999. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The Social Security Number of the Plaintiff is 592-58-3726 and the Social Security Number of the Defendant is 167-68-5989. 10. The marriage is irretrievably broken. 11. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 2 WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. PURCELL, KRUG & HALLER By q Jolty. Purcell, Jr., Esquire 719 N h Front Street H urg, PA 17102 Dated: (717) 234-4178 3 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. Dated: March 22, 2004 l/ILIA?bS , l/?/LI9?L!/(PYY Laura J. strong TJ ? '? ? ?? O ? w ? ?' C ° C -? ? ? LAURA J. ARMSTRONG, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-1227 CIVIL TERM ANDREW A. ARMSTRONG, : CIVIL ACTION-LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF DAUPHIN ss: I, Carol Masich, secretary to, John W. Purcell, Jr., Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 24"' day of March, 2004, I sent, by certified mail, return receipt requested, deliver to addressee only, a certified copy of the Complaint in Divorce, containing Notice to Defend and Claim Rights to Andrew A. Armstrong, the Defendant m the above action. The return receipt, duly signed by the Defendant is attached hereto and made a part hereof as Exhibit "A". Q? 0? Carol Masich Secretary to John W. Purcell, Jr. Sworn and subscribed to before" me this lday of IU?WLU l 2004. Public rvmrial Seal -? C?n S. Shaffer, lVWary Public MY ftbn b HavVSburg, Dauptgn Cou Member?? Expires Jan. 12, 2W8 eons Ivania U.S . Post al Ser vice,, , CE RTIF IED MAIL .„ RECE IPT r r (Do mestic M aii only ; No Ins urance Cov erage Provided) ? 'd"tl, Rerx .n u1 Postage $ .A Certified Fee C3 M Return Reciept Fee (Endorsement Required) O Restricted Delivery Fee cU (Endorsement Required) -0 r-q Totat Postage & Fees ; 8 "! xP Y t r,`. v 'LV t* " -rxx Postmark Here m C3 I' treat, APC NO.1.- ]rQ__________? arPo BOx NO. .YT _C) --I Stat ZIP+4 /? ??O ?- ?ec?r?av??csb?? ("r ri3tISM1111 ¦ 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 R space permits. A. X ? Agent 1. ilkrficle Addressed to: Yew ?.?VVY?rrcy )AA \A ?no55 B. Received by (Printed Name) I C. Date of Delivery D. Is delivery address different from item 17 ? Yes If YES, enter delivery address below: Ao 3. Service Typ MCertified ? Register, ? Insured 1 4. Restricted I Receipt for Merchandise (Extra Fee) 2. Article Number (I-ranter from service label) Y'\QO 73, \\c $ Q O Q mo 5 6?)$ 5q1(p PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-0835 Exhibit "All it" N T n ? N 'b LAURA J. ARMSTRONG, Plaintiff vs. ANDREW A. ARMSTRONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1227 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on March 23, 2004. 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. / v aura J. 6 rms ong WAIVER OF NOTICE OF INTENTION 1'0 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. 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 and Waiver 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: '4L / A'a " - Laura rmstron 9 N D O GC ? D '.a. 7Cl C ?n LAURA J. ARMSTRONG, Plaintiff vs. ANDREW A. ARMSTRONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1227 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on March 23, 2004. 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 of intention to request entry of the decree. /J .41 WAIVER OF NOTICE OF INTENTION i'O REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE of notice 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 and Waiver 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: 6 3a od ? ? 2 r", 'L! T'r A LAURA J ARMSTRONG, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v5. ANDREW A. ARMSTRONG, NO. 04-1227 CIVIL TERM CIVIL ACTION-LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 oO 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: March 27, 2004 by First Class U.S. Mail 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff. June 29, 2004 by Defendant: June 30, 2004 (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: No economic claims have been raised. 5. (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 Prothonotary: Filed contemporaneously herewith Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Filed contemporaneously herewi JOHN W. JR. ESQ. a Y r 1 ? `..Y . < N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF 10J-4 IPENNA LAURA J. ARMSTRONG, Plaintiff VERSUS Defendant No. __Qa_1997 2904 DECREE IN DIVORCE I.531.Ar. -. k? AND NOW, 2004, IT IS ORDERED AND DECREED THAT Laura J. Armstrong PLAINTIFF, AND Andrew A. Armstrong 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; 0.4)6 rr9tS!*nr eseeei - - -- i an or ATTEST: D J, PROTHONOTARY .rev'/° -"r AQt2 John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com LAURA J. ARMSTRONG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ANDREW A. ARMSTRONG, Defendant : NO. 04-1227 CIVILTERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the day of July 16, 2004, hereby elects to resume the prior surname of Laura J. Eyler, and gives this written notice pursuant to the provisions of 54 P.S. § 704. DATE: 5- Z S L 0C'8- Commonwealth of Pennsylvania : County of aura J A stro7g aura J. Ey4er On the y?'day of +A?f , 200?before me a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the written document and acknowledgment that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal Notary My Commission Expires 1vrotanal Seal Kimberly S. DeFaloo, Naary Pubic City Of Harrisburg, Dauphin Counjy MY commission Expires Jan. 1717 2009 Memher a .,• .c„ ??an;a ASSOCiatin? r -._ -- ? a GP