The URL can be used to link to this page

Home My WebLink About08-5245Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 DOUGLAS EARL, V. CAROL EARL, Plaintiff 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 breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. t8- 5Qgg CIVIL TERM CIVIL ACTION - LAW Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I. D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 DOUGLAS EARL, Plaintiff V. CAROL EARL, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. n u - 9.)-K CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, DOUGLAS EARL by and through his attorneys, Johnson, Duffle, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, CAROL EARL: 1. The Plaintiff is Douglas Earl, an adult individual, residing at 822 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The Defendant is Carol Earl, an adult individual, residing at 11C Richland Lane, Apt. 209, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant were married on June 11, 2005, in Hummelstown, Dauphin County, Pennsylvania. 4. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The parties separated on or about March 2008. 7. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a Decree of Divorce. JOHNSON, DUFIf IE, STEWART & WEIDNER Greevy VERIFICATION I, DOUGLAS EARL, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unswom falsification to authorities. Date: (? 2? IMo-?r 0 O LE Q DOU EARL :342124 ((?? 7?i ? V ?. P1 ? I ? ( W + I co t Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I . D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 DOUGLAS EARL, Plaintiff V. CAROL EARL, Defendant Attorneys for Plaintiff IN THE COURT OF COMM014 PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5245 CIVIL TERM CIVIL ACTION - LA IN DIVORCE RETURN OF SERVICE AND NOW, this Lb"day of September, 2008, the undersigned does hereby certify that on September 11, 2008, the Divorce Complaint filed September 3, 2008 in the ab ve (captioned action was served upon on Defendant, CAROL EARL, via certified mail return receipt requested, restricted delivery, addressed to 11C Richland Lane, Camp Hill, P 17011, the Return Receipt evidencing service upon Defendant is attached hereto as Exhibit A. JOHN ", FFIE, STEWART & W IDNER Melissa Peel Greevy T. J-No. 77950 Johnson, Duffie, Stewart & We dn? 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Plaintiff I I CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoi g Return of Service upon all parties or counsel of record by depositing a copy of same in th nitod States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the day o September, 2008, addressed to the following: Carol Earl 11 C Richland Lane Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER Melissa Peel Greevy :344655 Ey'k,6(f A p'-,V+ M SENDER :0P.Mij- FE THIS SECTION ¦ Complete Items 1, 2, and 3. Also complete A. Signature 0 Item 4 If Restricted, Delivery is desired. X ¦ Print your name and address on the reverse 0 so that we can return the card to you. Name) B. Received by CLDate ¦ Attach this card to the back of the mailpiece, 1 Pr L ? G ? l/ ermits ace n t[ront if ?6 ! . p sp or o different from Ite dd D I li d m 17 ? Y ress . s e very a ressed to: 1. Article If YES, enter delivery address below: 0 N ,? ^ t 3. Service Type XCwttfled Mail 0 E Mail 0 Registered 0 Retum Receipt for M Ise j 0 Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 2. (rArticle mns Number spa rates 7007 3020 R, ; ' _ - - - ---- - - 0001 1090 6527 PS Form 3811, February 2004 Domestic Return Receipt 10255 1540 ! .. o 5 7 ) A!' Johnson, Di By: Melissa I. D. No. 77i 301 Market P. O. Box 1 Lemoyne, F (717) 761-4 no, Stewart & Weidner ,eel Greevy, Esquire 0 treet a nnsylvania 17043-0109 40 Attorneys for Plaintiff DOUGLAS CAROL ARL, Plaintiff V. L, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 08 -55245 N098-524$ 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 September., 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapse 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 r quest entry of the Decree. 1. 2. lawyer's WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce with out notice. I understand that I may lose rights concerning alimony, division of property, or expenses if I do not claim them before a divorce is granted. ..t 3. 1 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 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 authorities. C;El? DOUGLAS EARL, Plaintiff :366783 -HE 20D9 MAY 28 PM : 52 C;L, t ' i ` Johnson, Di By: Melissa I.D. No. 77S 301 Market P. O. Box 1 Lemoyne, F (717) 761-4 DOUGLAS CAROL Stewart & Weidner Greevy, Esquire Attorneys for Plaintiff is 17043-0109 =ARL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff 0s - 5a4s NO.48 TERM V. L, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September .3, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapse from the date of filing and service the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to equest entry of the Decree. 1. 2. lawyer's WAIVER OF NOTICE OF INMTI? ON T4 REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce with out notice. I understand that I may lose rights concerning alimony, division of property, 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 Prothonota . 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 authorities. Date: CA OL EARL, Def dant :366783 1ARY THE 2009 VIAY 2 141; Johnson, D , Stewart 11 Weidner By: Melissa eel Greevy, Esquire I.D. No. 7795 Attorneys for Plaintiff 301 Market reet P. O. Box 10 Lemoyne, Pennsylvania 17043-0109 (717) 761-45,40 DOUGLAS EARL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO.08-5245 CIVIL TERM V. CAROL EARL, CIVIL ACTION - LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: it the record, together with the following information, to the court for entry of divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: September 11, 2008 via Certified Mail 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff: May 26, 2009, by Defendant May 22, 2009. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Filed herewith. Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Filed STEWART & WEIDNER Date: Me issa Peel Greevy :366790 i lLE k. I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS EARL V. CAROLEARL NO. 08-5245 CIVIL TERM DIVORCE DECREE AND NOW, / L^-. 9 , "01 , it is ordered and decreed that DOUGLAS EARL plaintiff, and CAROL EARL , 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, 1 /4 Attes \ J. thonotary ? - // • ter' ? ,???, ? ?? }