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HomeMy WebLinkAbout08-6693r Anna M. Holland Plaintiff V. Robert A. Holland Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA N0.08- o6,?,,3 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 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 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, Cumberland County Courthouse, 1 Courthouse Square, 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 ? A Anna M. Holland Plaintiff V. Robert A. Holland Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 4,6 43 CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is A r n 0- m' ? " `? 0?-l d , who currently resides at ZI u)je..?5? CA<yol 'S?- VA 1-7 cy'!?-5 Cumberland County, Pennsylvania. 2. Defendant is who currently resides at M C? a rl i CS r tt ) O !S;-C) 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on , aCJ? at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. le • } 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date -7?q - , "'? (?ti Plaintiff, Pro Se I, ?nQ o j?o?(Q n? verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. )I - 0-6? (?'? - Date: Plaintiff, Pro Se Assisted by: Michael J. Whare, Esq. Law Offices of Michael J. Whare 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 c W Anna M. Holland Plaintiff V. Robert A. Holland Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Anna M. Holland, Plaintiff, to proceed in forma au eris. I, Michael J. Whare, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. /0'j at,, Michael J. Whare, E uire Attorney for Plaintif Law Offices of Michael J. Whare 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 CA) t0 Anna M. Holland IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08-? 4 93 CIVIL TERM Robert A. Holland Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on dlkn4c1 ?a 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 divorce. 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. Section 4904 relating to unsworn falsification to autho Dat 1 Signature: Anna M. Holland, Plaintiff , r Anna M. Holland Plaintiff V. Robert A. Holland Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 4kg3 CIVIL TERM 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 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 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. Date. Signature: Anna M. Holland, Plaintiff r%a Q ? f77? -T'a ' jm Anna M. Holland Plaintiff V. Robert A. Holland Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08-0493 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on OVee• ?Dt?? 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: 31 i /0 A. Holland, Defendant C'! N r7 i FrIM ? ` i "? ?C" N : .z Anna M. Holland Plaintiff V. Robert A. Holland Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08-( kq3 CIVIL TERM 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 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 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. Date: l d Signature: Robert A. Holland, Defendant r-a ?; ANNA M. HOLLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law : No. 08-6693 CIVIL TERM ROBERT A. HOLLAND, Defendant INDIVORCE PROOF OF SERVICE * 1, 9, ad 9 AMamnl?isle - PA? 41f P Asbtcled Dewy is desho. " 4 i)OW' 1lfalne snd 1 41, 1 1 ©n the revoke Add ssse ?p#* We 00 Mb" ft card to ou ` i y . tWe *Wd to the bm* of the mei pWm PAO*-Ibf m " C. 011e of Ddvory a an thr Owd # epaoe pa ffft j- N - 1, Mob Ad*" tD: Is ddmy rddl d %mo *wn own 1? Ya If YIK w0m d*my ukhm trdow: 0 No RAJ tt ?' «sl?ts P? i`lOS? f ~Md © a and 19 I 0 Rs$ $Jkhm1 Rto nipt tar Mwdwnd oo [31 ell -1fM E3 COLD. 4. ReeA?lcted D~ ft s F" rYe 7008 1140 0001 6163 9969 { (tianMYraim PS Faun 3811, bale y10 IM111MMslMil?R?oNpt 1 _ ra _. ? °v = ? ? ? i? - ? s y -? G iJ j ' ?.. -5"5 n r 4i ? '? rr..ccc(?? ? ANNA M. HOLLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 08-6693 CIVIL TERM ROBERT A HOLLAND, Defendant IN DIVORCE 1 "Fit TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Filed November 12, 2008, was served on the Defendant by certified mail, endorsed restricted delivery-return receipt requested and signed on November 14, 2008. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by the Plaintiff on March 11, 2009; by the Defendant on March 1, 2009. The Affidavits were filed on March 12, 2009 for both parties. 4. Related claims pending: None 5. (b) Date 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 12, 2009. Date: 5-a q„ o q Respectfully submitted, 1--,, Michael J. Whare, Esquire 37 East Pomfret Street Carlisle, Pa 17013 (717) 243-3561 Supreme Court ID # 89028 Attorney for Plaintiff r"'1 ANNA M. HOLLAND V. ROBERT A. HOLLAND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6693- CIVIL TERM DIVORCE DECREE AND NOW, C "i i r , Z_d°j , it is ordered and decreed that ANNA M. HOLLAND , plaintiff, and ROBERT A. HOLLAND , 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, r IJV ,