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Home My WebLink About08-6264C David F. Tamanini, Esquire Attorney I.D. No. 27775 TAMANINI LAW OFFICE Telephone (717) 541-1805 4800 LINGLESTOWN ROAD, SUITE 309 dft@TamaniniLaw.com HARRISBURG, PENNSYLVANIA 17112-9507 Attorney for Plaintiff, Jennifer D. Chase JENNIFER D. CHASE Plaintiff VS. JOEY R. CHASE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. p$ - (o61(o4 CIVIL TERM : CIVIL ACTION - LAW : 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 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 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone Number: (717) 249-3166 or 800-990-9108 JENNIFER D. CHASE Plaintiff VS. JOEY R. CHASE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 ?- G -? Gy CIVIL TERM : CIVIL ACTION - LAW : DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW comes the Plaintiff, JENNIFER D. CHASE, by and through her attorney, David F. Tamanini, Esquire, and files this Complaint in Divorce and in support thereof avers the following: 1. The Plaintiff is JENNIFER D. CHASE, who currently resides at 1493 Maplewood Drive, New Cumberland, Cumberland County, Pennsylvania 17070, since on or about October 2, 2008. 2. The Defendant is JOEY R. CHASE, who currently resides at 610 Harding Street, New Cumberland, Cumberland County, Pennsylvania 17070, since on or about February, 2006. 3. Both the Plaintiff and the Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 17, 1999, at New Buffalo, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties during the current marriage. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests this Honorable Court to grant the relief requested under Section 3301(c) or 3301(d) of the Divorce Code. Respectfully Submitted, A-d i; nEl David F. Tam nini, Esquire Attorney ID No. 27775 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112 (717) 541-1805 Attorney for Plaintiff 2 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. 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: ( (LP log Jennifer D. Ch se 0 01 . .L q " ra 6 W& David F. Tamanini, Esquire Attorney L D. No. 27775 TAMANINI LAw OFFICE Telephone (717) 541-1805 4800 LINGLESTOWN ROAD, SUITE 309 dft@TamaniniLaw.com HARRISBURG, PENNSYLVANIA 17112-9507 Attorney for Plaintiff, Jennifer D. Chase JENNIFER D. CHASE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-6264 CIVIL TERM JOEY R. CHASE, : CIVIL ACTION - LAW Defendant : DIVORCE CERTIFICATE OF SERVICE I, David F. Tamanini, Esquire, attorney for the Plaintiff in the above-captioned matter, hereby certify that I served a certified copy of the NOTICE TO DEFEND AND CLAIM RIGHTS and the COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE upon the Defendant, Joey R. Chase, at the address indicated below by depositing the same in the United States mail, Certified Mail, Return Receipt Requested, Restricted Delivery, on October 24, 2008, as indicated by Certified Mail Receipt No. 7004 2510 0007 6524 9530 attached hereto. As indicated by the green return receipt card attached hereto, the above-referenced documents were received by said Defendant on October 27, 2008. Joey R. Chase 610 Harding Street New Cumberland, PA 17070 Dated: 119/3 Ole F- W4 i F. Tam nini, Esquire Attorney Id. No. 27775 TAMANINI LAW OFFICE 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112-9507 717-541-1805 Attorney for Plaintiff X +? M m m .. ul Rpolp Ln Foempe is G f CerMW Fee + O C3 -_ Rstmn He met Fen° $2120 ! 0 goo P= ra (Endorsm r Ln rU Tote) PoMW & Few C3 SW C3 TO oe_ _ Chases R poo blD?4c?ro?ih .r-- X !3 rs ? W-1 D. N dAmy eddieeedMaent N YM wtar dOv" eddnee below Cl Aperr< ?f. New Cumber land, A 1.767 3. 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Chase IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6264 CIVIL TERM CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce code was filed on October 21, 2008. 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. 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 unsworn falsification to authorities. --, Ajq? Dated: 2 D JENNI ER . HASE Plainti p 54 0 David F. Tamanini, Esquire Attorney I.D. No. 27775 TAMANINI LAW OFFICE Telephone (717) 541-1805 4800 LINGLESTOWN ROAD, SUITE 309 dft@TamaniniLaw.com HARRISBURG, PENNSYLVANIA 17112-9507 Attorney for Plaintiff Jennifer D. Chase JENNIFER D. CHASE Plaintiff VS. JOEY R. CHASE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6264 CIVIL TERM : CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 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 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. -214[n Dated: 0 JENNI ER CHASE Plaintiff _ Yrlt ? S ? ?.y -r I m ft Cl) C4 40 JENNIFER D. CHASE Plaintiff VS. JOEY R. CHASE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6264 CIVIL TERM CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce code was filed on October 21, 2008. 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. 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 unsworn falsification to authorities. Dated: J R. CHASE Defendant It 19 ?v JENNIFER D. CHASE Plaintiff VS. JOEY R. CHASE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6264 CIVIL TERM : CIVIL ACTION - LAW : 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. 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 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. Dated: - Ag d z? 4, CHASE Defendant ?? ;..,J ^ i ? . Y i.f d T` ?' Y" o rw. David F. Tamanini, Esquire Attorney I.D. No. 27775 TAMANINI LAw OFFICE Telephone (717) 541-1805 4800 LINGLESTOWN ROAD, SUITE 309 dft@TamaniniLaw.com HARRISBURG, PENNSYLVANIA 17112-9507 Attorney for Plaintiff, Jennifer D. Chase JENNIFER D. CHASE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 08-6264 CIVIL TERM JOEY R. CHASE, CIVIL ACTION - LAW Defendant 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 Section (X) 3301(c) ( ) 3301(d) of the Divorce Code. (Check applicable code) 2. Date and manner of service of the complaint: by certified mail restricted delivery, return receipt requested on October 24, 2008, received by the defendant on October 27, 2008. 3. (Complete either paragraph (A) or (B).) (A) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff. February 4, 2009; by defendant: February 13, 2009. (B) (1) Date of execution of the plaintiffs affidavit required by Section 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 plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: February 12, 2009. Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: February 25, 2009. avid F. Tam i, Esquire Attorney ID No. 27775 TAMANINI LAW OFFICE 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112 (717) 541-1805 Attorney for (X) Plaintiff ( ) Defendant ' ?? C;c. ? .`' '; r ? G.1 - J { ?,? ? ? -? " ? ? ? ? ?: ,? e j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER D. CHASE V. JOEY R. CHASE NO. 08-6264 CIVIL TERM DIVORCE DECREE AND NOW, to u" aD 0 , it is ordered and decreed that JENNIFER D. CHASE , plaintiff, and JOEY R. CHASE , 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. 1"5!90W rothonotary Attest: J. .PA w