Loading...
HomeMy WebLinkAbout09-1014b Pamela L. Purdy Attorney ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verizon.net Attorney for Plaintiff HOLLI A. LAMAN, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. pq- 1014 Uyit Tem STEVEN W. LAMAN, Defendant : 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 jP MELA 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 HOLLI A. LAMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. STEVEN W. LAMAN, Defendant NO. O i- 16! V C S I/- f e%?t IN DIVORCE COMPLAINT IN DIVORCE COUNTI Divorce Under 3301(c) of the Divorce Code 1. Plaintiff is Holli A. Laman who currently resides at 321 First Street, Enola, Cumberland County, Pennsylvania. 2. Defendant is Steven W. Laman whose current mailing address is 321 First Street, Enola, 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 June 21, 1997 at Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. WHEREFORE the Plaintiff requests this Court to enter a decree of divorce under Section 3301(c) of the Divorce Code. Respectfully submitted, A"- Pamela L. Purdy . Attorney for Plaintiff Dated: +IZDO 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. 6CU G{?y1gC? Dated: '?' I I -? 10 5 W HOLLI A. LAMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-1014 CIVIL TERM STEVEN W. LAMAN, Defendant : IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce in the above- captioned matter. Date: 2 L 3.611 Enola, PA 1702 5 ?--? t:?- ? .- -? ---t -? -,-c .,.,? . , --i a _a.. k ?? ??' ?' ?ti :? Pamela L. Purdy, Esquire Attorney I.D. No. 85783 308 N. 2na St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Plaintiff HOLLI A. LAMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Oq-- g) V. STEVEN W. LAMAN, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 19, 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: 51 as 10 Cl _t- &.I 4 mk v? HOW A. LAMAN FILE- THE ' 20#13911"i t _I- a F i r m F. i ? . 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 Counsel for Plaintiff HOLLI A. LAMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO-98-9908 CIVIL STEVEN W. LAMAN, Defendant 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. 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. ., , r , 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. HOLLI A. LAMAN Dated: 51 a(, I oq -2- _ '? ?r' r i ?%'1rx "1St qrn? q,. .? .M1?.y [' ., ? ;'{" r ???.??; .. ?.??ti.`. HOLLI A. LAMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Dq- l6 (4 STEVEN W. LAMAN, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 19, 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 ar true and cor t. I understand that false statements herein are made subje o the pen s of 18 Pa.C.S. § 4904 relating to unsworn falsification to auth es. S- . L2•oq EVEN W AN Dated: T ALl..EJ ??p HOLLI A. LAMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA OG-1b lq V. NO. 00-99®S CIVIL STEVEN W. LAMAN, Defendant 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. 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 penaltie§ of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities ?. ZZ •01 ST' N W. Dated: AU""" ! 11 -1 ?? 4 - ' .4 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 Attorney for Plaintiff HOLLI A. LAMAN, Plaintiff V. STEVEN W. LAMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1014 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: Defendant signed an Affidavit of Acceptance of Service on February 23, 2009, which was filed of record on February 27, 2009. I ' N 3. Date of execution of Affidavit of Consent required by §3301(c) of the Divorce Code: By the Plaintiff: May 22, 2009 By the Defendant: May 22, 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: 7d0 C7 By. / Pamela L. Purdy -2- cT!FI" x` t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOLLIE A. LAMAN V. STEVEN W. LAMAN NO. 09-1014 DIVORCE DECREE AND NOW, '14134 13 , _, it is ordered and decreed that HOLLIE A. LAMAN plaintiff, and STEVEN W.LAMAN 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: None By the Court, ? .Ar.o?