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HomeMy WebLinkAbout08-6218 J2FA1,V1 FFR A 00R.4AI PLAINTIFF, v (nrm 3 • 183 (IN THE COURT OF COMMON PLEAS OF ( r- um8,SP14" ---COUNTY, PENNSYLVANIA (CIVIL DIVISION V (NO: ?.. a. I G •'v (?"`? DEFENDANT. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 CHILD(REN). WHEN THE GROUND FOR THE DIVORCE ARE 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 r.' a gj&g'R 1. A&A C am y2 y . PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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. LAWYERS REFERRAL SERVICE J,g rye r? / s,? r-?is /W 174/3 Telephone: 717 _e:,? ?tq - 3/6 For Petitioner Address: .S"3 ?Y>l LS>1>? G''0KI-JsLL P4 /70J-3 Telephone: 707 - 910 - 1 Q0 J?'?c/NiFE'? ??. L?l?l2An? PLAINTIFF, V. K }? .b©RA DEFENDANT. form 4 • 185 (IN THE COURT OF COMMON PLEAS OF ( eA'M,9-Rd A A/P COUNTY, PENNSYLVANIA ( (CIVIL DIVISION (NO: 00 - (pow b CND I 'f t.(M COMPLAINT IN DIVORCE AND NOW COMES, the Petitioner, JEN N / FER h. ZORII A/ by FILING PRO SE, who files this Complaint in Divorce a statement of which is as follow: 1. The Petitioner is T45"JF W /11 AORAW an adult individual currently residing ar S3 1111-L S/6E Ade 0,09 PI / fl.r 13Q /'7n l 2 The Defendant is /C I )'K /t DDRA)V an adult individual currently residing at .-5:3 hl /LL S?L>?` 1?R t!' IRZ ISLE PA J7,013 3. The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Petitioner and Respondent were married on dare:? a0t73 in the State of ?. 5. There (is)AO_ALO child(ren) born of this marriage. Name(s) Birthdate(s): 6. Neither party is a member of any branch of military. 7. The marriage is irretrievably broken. ` 8. The Petitioner, s% C*nV/ )'T e respectf* requests this Honorable Court to a grant this Divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce Code. YdTPr:tfitlly sub 'tied, A J I ri 7A acne: 1TEN.?/FE/2 i9, ?1 ol?A?t/ Full Address: ?3& .y/lLS/1?E 1AiP. c A.& 1.7D2 Telephone. 7/ 7 - '74, 0 I verify that the statements made in the Complaint are true and correct. I understand that false statements made herein are subject tto7 penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Dated: h) 1 C 0 I form 5 • 187 J-6NIV / F /tom AA1,V b (IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( Cl/??13F/?iUD COUNTY, PENNSYLVANIA (CIVIL DIVISION DEFENDANT. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) ) ss: COUNTY OF: C 64 M2e )?.Z,4 AIP ) Before me, the subscriber, a Notary Public in and for said Commonwealth and County, per- sonally appeared A4141 wDORa4& , who being duly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his/We knowledge, information, and belief, and that he/she is authorized to make this Affidavit. are Sworn to and subscribed before me this _ day of o c7"?g?ri 1200-2-- M01MIAt aft rm N OEM= r Wary wubft 1NR OfCff-M*lM OWNWApr f; ` NOTARY PUBLIC )OWTIC v Juop ^Aduo r sh7F' ?1iAR,J?1?!NARNIi? [ t?S .QS trrt?c?x3 noAo, moo) VO -y> o ca w ? d Rl) W farm io • 199 L7?e-A IAC,' A - b40)e 4A/ (IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( (i u tn, ,=,CL,4,oJ!J COUNTY, PENNSYLVANIA V. & ?,ek P. A0 R,9 / (CIVIL DIVISION (NO: DEFENDANT. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on / 0 / oZ '9 / 0 P. I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of fil- ing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to file with the e 41716-Okd A^?? County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlement Agreement documentation. IN WITNESS WHEREOF, I set my hand and seal this - day of Tan A A 200 4E: On this -,2?ei? day of 200, before me, a Notary Public, the undersigned officer, personally appeared E known to me to be the person whose name is 'bed t the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public COPR 0,NWEALTH OF PENNSYLVANIA Notarial Seal Shirley L. Boggs, Notary Pub!ic Carlisle Boro, Cumberland County My Commission Expires Sept 3, 2011 Pennsylvania Association of Notaries -10 C? ? c._ ? ?:, tz - .,,.? --1?" ;, ? ?C form 9 • 195 TEiVi(l it=ER A .(LORI AI (IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( COUNTY, PENNSYLVANIA (CIVIL DIVISION / I9k P 06RA/Y (NO: O?- ?p r2./ DEFENDANT. MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this oZoZ n'? day of D C f 0 Se r- , 200 8 , between PLAINTIFF, TENWIAFCR A 00RAW , residing at .53 11LLs1.0'r AR (city) eRXA /SLF , Pennsylvania / M13 (zip), hereinafter called =4abane / "Wife," and DEFENDANT, .Dd RAA/ , residing at ?.? ?f l L L S/1JE ,DR, (city) ?.'A?P1 /SLE Pennsylvania / 70/Z (zip), hereinafter called "Husband" / WITNESSETH WHEREAS, the parties were married on: (date) ?e f T o?003 WHEREAS, the parties filed for 3301(c) Divorce on: (date) Oct e2O. c?0109 WHEREAS, the parties hereto desire to settle their property rights; WHEREAS, both parties agree to relinquish any and all claims which either may have against any prop- erty now owned or belonging to the other or which may hereinafter be acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants, and agreements con- tained herein; and, WHEREAS, both parties each have had opportunity to seek the benefit of competent and independent legal advise by separate counsel. NOW, THEREFORE, the parties, intending to be legally bound, do covenant, and agree as follows: 1. INCORPORATION OF RECITALS The recitals on Page 1 of this Agreement are incorporated herein as if set forth in full. Each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 2. APPLICABLE LAW This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 396 • 3. PROPERTY TO BE RETAINED BY WIFE. Husband and Wife agree that, unless otherwise indicated in this agreement, the Wife shall keep all of _ own personal clothing and effects; and that the following property shall also be retained by the Wife: &RANb 1IOT11FR'S 7 RBLA;:5 ANO i/AN / TY 9 77 -57A TOR Al U T0nl 4. PROPERTY TO BE RETAINED BY HUSBAND. Husband and Wife agree that, unless otherwise indicated in this agreement, the Husband shall keep all of his own personal clothing and effects, and that the following property shall also be retained by the Husband: ,01,010 J In 11V6 GAIg?NET 50"A , 01AIIA16- Rooln TABLE Hy COMPPMR, 50NY f/d -rV bVP P44WR, 57Z-REOS x005 PRI41S 604b W E Do/A16 RINGS 5. DEBTS TO BE PAID BY WIFE. Husband and Wife agree that the Wife shall pay the following debts and will not at any time hold the Husband responsible for them: /Vbnlr 6. DEBTS TO BE PAID BY HUSBAND. Husband and Wife agree that the Husband shall pay the following debts and will not at any time hold the Wife responsible for them: PSEGN 41J7b L0,9A1 FOR a003' PRIkS *R/03/0/039/a. "(8l Ja?D77f?? S0YERR-16-A ' BA.v rl IMORrGAG.F- c?gsE rr?oRTGAGE' .?- ?a?3a9o9??2 • 197 7. PENSION AND/OR PROFIT SHARING PLANS, BANK ACCOUNTS, STOCKS, BONDS, SECURITIES, CREDIT UNION ACCOUNTS, AND INDIVIDUAL RETIREMENT ACCOUNTS Husband and Wife distribute the respective accounts as follows: l-? USBA?Q S?fA1 L J?ETAr?f ?fiS -6A' -F 4eC0&.,V7-Y W /F? S/?Al.L ETi?>.? /,tE/? -'rA0?-C'XCF 14C eow4j ' 7-#t 911S,6AWb S-44,g4L RCr.9rN 7W,6 1>SE6q > 4fZ,9V /r5 7- W/Fr .SyALL TA','.J /VC-Al .D / S.t/? STOGt? 8. REAL ESTATE 14 415B4 Nd S)VAU XeT,41AI REAL E-574M 1 Dc'9 rV-v '4r .33 iV>L1 rlbe- AQ dog&L/SLE X99 ?7'D/3 , ?1G- LL A4r W)FL' $5000 AOY M6, oZ00, 14ND ?NoTVICR ?5J000 9. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL MARITAL RIGHTS Each of the parties hereto release the other from subsequent claims for alimony, alimony pendente lite, or spousal support, except as set forth as follows: N4NLr r rte, Fi form 12 • 203 ?J,C IAIIr4W 4. bo.CAI/ (IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( (? i f I?7 +B€/e'? Ada COUNT1, PENINSYLVANIA V. (CIVIL DIVISION Rk (NO: o p " 67 9 ? g DEFENDANT. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly 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 3301(c) or-MaQ4* of the Divorce Code. (Strike out applicable section.) 2. Date and manner of service of the Complaint: on or about GIVE DATE: f C? O via (circle one) Personal Service o Certified Ma' . 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit of Consent/Consent Waiver required by Section 3301(c) of the Divorce Code: by Plaintiff ( / /.?6 / OF); by Defendant ( / /•Z(p / 019). (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit requited by Section 3301(d) of the Divorce Code: 4. Related claims pending: None. Og'u (Liff Address: 700 G /? ?? V ? k/ Un D URRAM N G a 7 703 Phone. ( / / 7) 3 S 6 - o,2 -7 5. Date and manner of service of the Notice of Intention to file Praedpe to Transmit Record, a copy of which is attached, if the Decree is to be entered under Section 3301(d) of the Divorce Code. -eo I i' JENNIFER A. DORAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KIRK P. DORAN, Defendant NO. 08-6218 CIVIL TERM ORDER OF COURT AND NOW, this 20'' day of February, 2009, upon consideration of Plaintiff's praecipe to transmit record, a divorce decree will not be entered at this time because (1) no poof of service of the complaint has been filed and (2) the proposed divorce decree does not indicate whether jurisdiction is being retained on any issues. This denial is without prejudice to the parties' rights to correct the deficiencies and file a new praecipe to transmit. BY THE COURT, /nnifer A. Doran 700 Grandview Drive Durham, NC 27703 Plaintiff, pro Se irk P. Doran 53 Hillside Drive Carlisle, PA 17013 Defendant, pro Se rc V ti _s! 0 -?! fi Jennifer A. Doran V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kirk P. Doran NO. 08-6218 DIVORCE DECREE AND NOW, -2j/-L 19, o a , it is ordered and decreed that Jennifer A. Doran Kirk P. Doran bonds of matrimony. plaintiff, and defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente life 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.") A/o /Vz By the Court, 'el .0,0. 41.e