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HomeMy WebLinkAbout09-02850 Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff SHELLEY A. RAILING, Plaintiff V. JAMES E. RAILING, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. OQ - 28S (7 lu?("-T 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 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, PA. 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 PA LA L. PURDY ATTORNEY FOR PLAINTIFF Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff SHELLEY A. RAILING, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. JAMES E. RAILING, II, Defendant : NO. d 4, - ? & < C-a 7-x.4. . IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Shelley A. Railing who currently resides at 1417 Wellgate Lane, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is James E. Railing, II, who currently resides at 1417 Wellgate Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 28, 1994 at East Berlin, Pennsylvania. I • S 5. There have been no prior actions of divorce or for annulment between the parties. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER 3301(C) OF THE DIVORCE CODE 6. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 7. The marriage of the parties is irretrievably broken. 8. The grounds on which the action for divorce is based are Section 3301(c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. WHEREFORE the Plaintiff requests this Court to enter a decree of divorce under Section 3301(c) of the Divorce Code. Respectfully submitted, 4ae a L . Purdy Attorney for Plaintiff Dated: 1 0 280, VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. S ey A. R ' Dated: POW& ?Oi Zoo 1 1 f > r4 h1 C? )r V -Ti 7! 1 f k !_. tq ?? 0-0 SHELLEY A. RAILING Plaintiff V. JAMES E. RAILING, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-0028 : IN DIVORCE I hereby accept service of the Complaint in Divorce I n the above- captioned matter. Date: 4 ?`1 aJ J es E. Railin , II 1417 Wellgate Lane Mechanicsburg, PA 17055 , Q C- C= .sa -n rn r, m co 0 SHELLEY A. RAILING, Plaintiff V. JAMES E. RAILING, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-00285 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 21, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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: 511.? 4?00?- J1'yES E. RAILING, II f LED--r,)FrriCE O TFw PP,7, WOT 2009 MAY 14 Pty 2: 02 'D SHELLEY A. RAILING, Plaintiff V. JAMES E. RAILING, 11, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-00285 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(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 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. Lw JA S E. RAILING, II Dated: ? ?? FLED--OrrIC OF THE FP I.'! "I"'OTARY 2009 MAY 14 PH 2: Q2 Cl!Is' j iY b Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attomey for Plaintiff SHELLEY A. RAILING, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA V. NO. 2009-00285 CIVIL JAMES E. RAILING, II, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 21, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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. SH Dated: 1 Z -?©`? G# ALED-C FIC4 OF THE PRO-14'C 3TARY 2009 MAY 14 PM 2: 02 CU3?' r . 'JOIN Y L-,-, .. -% IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-00285 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(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 Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax ptpurdy@verizon.net Counsel for Plaintiff SHELLEY A. RAILING, Plaintiff V. JAMES E. RAILING, It, Defendant 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 b with the Prothonotary. 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. SH A. RWiNqr Dated: S I Z - 2 i?? -2- .+' , ,M.& FILED-OFFICE OF THE FF,n? K`)NPTARY 2099 MAY 14 PPS 2= 02 V IL -i Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2"d St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax pipurdy@verizon.net Attomey for Plaintiff SHELLEY A. RAILING, Plaintiff V. JAMES E. RAILING, II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-00285 CIVIL 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) of the Divorce Code. 2. Date and manner of service of Complaint: January 26, 2009 by regular U.S. Mail, and Certified, Restricted Mail, return receipt requested. Defendant signed an Affidavit of Acceptance of Service on January 29, 2009, which was filed of record on February 9, 2009. 3. Date of execution of Affidavit of Consent required by §3301(c) of the Divorce Code: By the Plaintiff: May 12, 2009 By the Defendant: May 12, 2009 4. Related claims pending: none. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe Date: , a f By: Pamela L. Purdy -2- ,14,C JOTAPY 2009 MAY 14 PM 2: 03 IN THE COURT OF COMMON PLEAS OF SHELLEY A. RAILING CUMBERLAND COUNTY, PENNSYLVANIA V. JAMES E. RAILING, II NO 2009-00285 DIVORCE DECREE AND NOW, , ;W1 , it is ordered and decreed that SHELLEY A. RAILING plaintiff, and JAMES E. RAILING, II , 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 Court, Attest: J. othonotary a9 ?'? ??, ..?'? ?I ' ? ?- _ ??.?? a?? .. ? ,? ... ??? .?