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Home My WebLink About08-5681n G, 4? JENNIFER L. DELL, V. LARRY R. DELL, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO.O P M1 CIVIL TERM 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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, Cumberland County, Pennsylvania, 17013. 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 Phone: (717) 249-3166 or (800) 990-9108 JENNIFER L. DELL, Plaintiff V. LARRY R. DELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0 S - 5t, CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE COUNTI NO FAULT 1. Plaintiff is Jennifer R. Dell, an adult individual currently residing at 96 Independence Drive, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Larry R. Dell, an adult individual currently residing at P.O. Box 83, Shade Gap, Huntingdon County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 1, 1997, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301(c) of the Domestic Relations Code. COUNT II ALIMONY PENDENTE LITE 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Plaintiff is unable to provide her basic needs during the pendency of this litigation. 13. Plaintiff is without sufficient property and otherwise unable to financially support herself despite being gainfully employed. 14. Defendant is presently employed and receiving a substantial income and benefits and is able to pay alimony pendente lite for the Plaintiff. s WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay alimony pendente lite to Plaintiff. Respectfully submitted, jepGrfffie, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. Q, , ,/,, , (Z , Q, & DATE: NNIF L. L, Plaintiff -CIlkN U r 0i v v fi. W o, G!+ ?I :02-1 _? JENNIFER L. DELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. LARRY R. DELL, Defendant TO THE PROTHONOTARY: : CIVIL ACTION -LAW NO. 2008-5681 CIVIL TERM IN DIVORCE PRAECIPE Please reinstate the Divorce Complaint filed in the above captioned action. Respectfully submitted, Date: 11 11 68' Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 4.x.1 w.9.. .. J ? r -I C'3 w? JENNIFER L. DELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION -LAW LARRY R. DELL, NO. 2008-5681 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE received a 4"? I, Barbara B. Townsend, Esquire acknowledge that on &cr ol I reinstated Complaint in Divorce in the above captioned action and acknowledge that I am authorized to do so on behalf of the Defendant, Larry R. Dell. Date: &&xk Barbara B. Townsend, Esquire Attorney for Defendant 32 West Queen Street Chambersburg, PA 17201 A JENNIFER L. DELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW LARRY R. DELL, NO. 2008-5681 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on September 25, 2008, reinstated on November 20, 2008, and served on December 1, 2008, by counsel's Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING 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: (4)jej- , AQIW- J Pifer Dell, laintiff ? p Pt F,, i 77 _ "x3 ?l? f i ? I- y Cn JENNIFER L. DELL, Plaintiff V. LARRY R. DELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 2008-5681 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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. ,71/fA Q ( a dL DATE: 9 J fifer . D aintiff C? N ?a r-z ras sew _ ?4rv? ?_ _ ® rT JENNIFER L. DELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW LARRY R. DELL, NO. 2008-5681 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on September 25, 2008, reinstated on November 20, 2008, and served on December 1, 2008, by counsel's Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING 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: 01 ?v? Larry R. Well, Defendant i. .? K? ?J -. -•. ? FF ~i ?? ? X41 t ?v a ? ...? m_ JENNIFER L. DELL, Plaintiff V. LARRY R. DELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-5681 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. 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 THE FOREGOING 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: 3 ((? d q Aef-ll-!2en ,dant 77 , ,_7 JENNIFER L. DELL, Plaintiff V. LARRY R. DELL, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2008-5681 CIVIL TERM : 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) (Strike out inapplicable section). 2. Date and manner of service of the Complaint: December 1, 2008, by service upon attorney of record, Barbara B. Townsend, Esquire, as indicated in Acceptance of Service. 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: March 9, 2009 by Defendant: March 18, 2009 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs 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 plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: March 12, 2009 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: March 25, 2009 riff' Esquire 4&cGiRz11FVFIEE A SOCIATES Attorney for Plaintiff FILE i 'I E NOT)m OF THE Rr-rT 2009 APR -6 PH 2: 13 GUMS t V, I fly IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. DELL V. LARRY R. DELL NO. 2008-5681 DIVORCE DECREE AND NOW, Y"1 7 , "AMP 'k , it is ordered and decreed that JENNIFER L. DELL , plaintiff, and LARRY R. DELL , 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 arel as follows: (If no claims remain indicate "None.") The parties' Postnuptial Property and Separation Agreement, dated November 3, 2008, is incorporated herein, but not merged. By Attest: '4 - 1 J. wt?" i