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Home My WebLink About09-0256KEIRSTEN SMITH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW GREGORY SMITH, NO. 09 - ,~,~t, CIVIL TERM Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGATS 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, Carlisle, Pennsylvania, 17013. 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, 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 INFORAMTION 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, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. KEIRSTEN SMITH, v. GREGORY SMITH, Plaintiff : Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09 - a SG CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(cl OF THjE DIVORCE CODE 1. Plaintiff is Keirsten Smith, an adult individual, who resides at 260 Gibson Street, Carlisle, Pennsylvania, 17013. 2. Defendant is Gregory Smith, an adult individual, who resides ~t 3862 Florence Dr., Apt. 3, Alexandria, Virginia, 22314. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 11, 1995 in Cazlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, BAYLEY & MANGAN Date: ~- ~(p - O Q Mazk F. Bayley; Esquire 17 West South St. Cazlisle, PA 17013 (717) 241-2446 Supreme Court LD. # 87663 Attorney for Plaintiff KEIRSTEN SMITH, v. IN THE COURT OF CO~VIMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA GREGORY SMITH, Defendant CIVIL ACTION -LAW NO. 09 - CIVIL TERM IN DIVORCE VERIFICATION I verify that the statements made in this Complaint aze true and carrect. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ~- ~~~ Qq Keirsten Smith, Plaintiff -~~,-. ~ ~ ~,~, c~.c °o L ~, ~ +Y== . ~ ~ ~ ~~` ~ o ~--- c~ N Q ~~ i~w o ;:ur a -a T: ~~ KEIRSTEN SMITH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW GREGORY SMITH, NO. 09 - 256 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on January 20, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably. broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in 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 irsten Smith F11..E~-~,~i-r~;E 2~1~9 JUG t n AM i [ ~ 2 ~ ~..: ~.- ~'~fi~t~~,`' ~ ~r„~~~ F .~ E..~~r KEIRSTEN SMITH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. . CIVIL ACTION -LAW GREGORY SMITH, NO. 09 - 256 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on January 20, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the fmal Decree in 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. /~~-~ ~ 9 Date Gregory S ith RL~-+;)~~lCE t3F 7H~ ~~~"~ ~3`~C}TA~Y 20D9 J~1~ { 0 AM f I ~ ~ ~ ~}~~,. _.. { f ~~4~"~~Y~.J~'; g~l~? KEIRSTEN SMITH, Plaintiff v. GREGORY SMITH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09 - 256 CIVIL TERM IN DIVORCE WAIVER 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 THATT EH 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. Jt -- ~~,o - ~ ~f Date irsten Smit t Flf~~i SCE 2009 J~ I U AM l ! ~ ~ ~ KEIRSTEN SMITH, Plaintiff v. GREGORY SMITH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09 - 256 CIVIL TERM IN DIVORCE WAIVER 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 THATT EH 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 rego mit ~L~Q-C7~ ~3U~ 209 JUG I ~ A~ t l ~ 25 CUt~i~:::~z ftr~~- :.~.f~~~' F'~~~,iPvl~`~E.Vr;i`J~ KEIRSTEN SMITH, Plaintiff v. GREGORY SMITH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09 - 256 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: filed on January 20, 2009 and Acceptance of Service signed on January 23, 2009. 3. Date of execution of the Affidavit Of Consent required by § 3301(c) of The Divorce Code: by the Plaintiff May 16, 2009; by the Defendant June 1, 2009. 4. Related claims pending: None 5. Date Plaintiff s Waiver Of Intention To Request Entry OfA Divorce Under ~3301(c) Of The Divorce Code was filed with the Prothonotary: on June 10, 2009; a copy of which is attached. Date Defendant's Waiver Oflntention To Request Entry OfA Divorce Under ~3301(c) Of The Divorce Code was filed with the Prothonotary: on June 10 2009; a copy of which is attached. -- ~ Date: 'Mark F. Bayley, Es uire BAYLEY & GAN 17 W. South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff FLED--t~1=rICE {~ ?Nr P~~s~~?~tr!±~TRFtY 2009 Jt~~~ ! 0 A~ I I ~ 2