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Home My WebLink About04-1352Barry B. Wood, Plaintiff, V. Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland County Civil Civil Action-Law 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, if any. 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 1 Courthouse Square, Carlisle, PA. 1F 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE FOURTH FLOOR CARLISLE, PENNSYLVANIA 17013 (717)-240-6200 Barry B. Wood, Plaintiff, V. Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland County No. Civil Civil Action-Law In Divorce COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Barry B. Wood, who currently resides at 6 East Green Street, Shiremanstown, Cumberland County, Pennsylvania since December 2003. 2. Defendant is Angela A. Palmer, who currently resides at 314 Lewisberry Court, York County, Pennsylvania since May 2001. 3. Barry B. Wood and Angela A. Palmer have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiffand defendant were married on May 27, 2000 at York, York County, Pennsylvania. 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. Date: B. W'o ff Barry B. Wood, Plaintiff, V. Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland County No. Civil Civil Action-Law In Divorce VERIFICATION STATEMENT 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. Date Barry B. Wood-Plaintiff Barry B. Wood, : Plaintiff, : V. .. Angela A. Palmer, · Defendant. : In the Court of Common Pleas of Cumberland County Civil Civil Action-Law In Divorce ?AIVER OF SERVICE The undersigned, defendant in the above-entitled action now pending before the Cumberland County Court of Common Pleas, wherein the above named plaintiff seeks an absolute divorce, hereby consents that this appearance and waiver constitutes the appearance of the undersigned in this action, and the undersigned hereby submits personally to the jurisdiction of such court. Further, the undersigned hereby waives all time to answer or otherwise plead in such action and consent that her default may be entered therein and that such cause may be set down for trial at the convenience of the court, and waives notice of such setting or any and all other notices and process required by law in the premises. Dated.LJ !1~]6~ Barry B. Wood, Plaintiff, V. Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland County No.~ ~,4 - Civil Civil Action-Law In Divorce AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on December 12, 2003 and have continued to live separate and apart. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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: Angela ~k. Palmer-Defendant Barry B. Wood, Plaintiff, V. Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland County No. ~coq- Ciivil Civil Action-Law In Divorce AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on December 12, 2003 and have continued to live separate and apart. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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. ~l~ar~ ~. ~Vood-Plaintiff Barry B. Wood, Plaintiff, V. Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland Courlty No. -~ oo '~- Civil Civil Action-Law In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301( c ) of the Diw>rce Code was filed on 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 Pa. C.S. § 4904 relating to unswom falsifications to authorities. Date: -l~arry B .-'~,o~dZPl~in~h~f A~ge~t A. t;~lmer'-Defendant Barry B. Wood, Plaintiff, Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland County No. '~o~- Civil Civil Action-Law In Divorce WAIVER OF NOTICE OF INTENTION TO 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. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 tree 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: ~arry B.~Wood-Plaintiff Angela ~. Palmer2Defendant Barry B. Wood, Plaintiff, V. Angela A. Palmer, Defendant. In the Court of Common Pleas of Cumberland County No. 2~:~:a~'-- Civil Civil Action-Law 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 3301 ( c ) 3301(d)(1) of the Divorce Code. 2. Dat~andmannerofserviceofthecomplaint. qjiq/_O'/ 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 3301( c ) of the Divorce Code: byplaintiff_6-/x/2.~,o,,, ; bydefendmat y/z/zoo,-/ (b)(1) Date of execution of the affidavit required by -' 3301 (d) of the Divo{c'e Code: ~'/a4'2~° ¥ ; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: C~ot~[ 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 plaintiff's Waiver of Notice in 3301( c ) Divorce was filed with the' Prothonotary: _~/,ff /~ )/ Date defendant's Waiv ' · ' . . .~ . er of Notice ~n 3301( c ) Divorce rromonotary: ~5(./~ ~/oy' . was filed with the Date: ,It ~ ~'ood-Plaintifff INTHE COURT OF COMIVION PLEAS OF CUMBERLAND COUNTY STATE OF ~~, PENNA. Barry Wood No. 200~-01352 VERSUS An~ela Palmer DECREE IN DIVORCE AND NOW,~ DECREED THAT Barry Wood AND Angela Palmer ARE DIVORCED FROM THE BONDS OF MATRIMONy. ~_, IT IS ORDERED AND , PLAINTIFF, ., DEFENDANT, 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; PROTHONOTARY