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HomeMy WebLinkAbout01-6831REGINA McREDMOND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :No. C: l - u JOHN MCREDMOND, : 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 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 the 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 Court House, 1 Courthouse Square, Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S F~ES 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 or 1-800-990-9108 ~andra L Meil~on Attorney for Plaintiff REGINA McREDMOND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : : NO. JOHN MCREDMOND, : Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Regina McRedmond, an adult individual who is sui juris and resides at 1122 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is John McRedmond, an adult individual who is sui juris and resides at 1122 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania 17011. The present whereabouts of the Defendant, John McRedmond, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 27, 1999 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. TUCKER ARENSBERG & SWARTZ P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorney for Plaintiff 45025.1 I verify that the statements made in this Complaint 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. Re~'ir~cRedmon~ ' - HUSBAND I. NAME (F',m) (M/~e) -------- John McRedmond 61R'IH 3. ~Sl~ ~ ~ R.D. ~ ~' ~ ~' ~ 1122 Oyster Mill Road, Camp Hill, Cumberland, PA ~. ~ sram New York ~ ~ Unemployed WIFE 8. ~ ~ ~ ,~'~; Reilley Regina McRe~ond ' a~ 09 10 54 IO. ~ ~ ~O. ~. ~ 1122 Oyster Mill Road, Camp Hill, Cu~erland, PA ~ Pennsylvania ~ 0 ~ i Clerk I ~Y~ O O O N/A ~arr~age ~s ~rretrievably broken. 24. 8~ ~ ~IB~ ~K REGINA McREDMOND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6831 CIVIL TERM JOHN McREDMOND, : Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF DAUPHIN ) AND NOW, this 12th day of December 2001, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Shaun M. Kovach, who, being duly sworn according to law, deposes and says that she is the secretary for Sandra L. Meilton, who is the attorney for the Plaintiff and that she mailed a Divorce Complaint on December 3, 2001, to Mr. John McRedmond, 1122 Oyster Mill Road, Camp Hill, Pennsylvania 17011, by Certified Mail No. 7099 3400 0016 3623 7525, return receipt requested, and the same was received by him on December 3, 2001 as indicated by the Return Receipt Card, which is attached hereto. Shaun M. Kovach SWORN TO ~ SUBSCRIBED before me, this 12th day of December 2001. i I also wish to receive the foltow- SENDER: ~3 Complete items I and/or 2 for additional sewices, ing services (for an extra fee): C(x~plete items 3, 4a, and 4b. permit; 2.~.Restricted Delivery 3. Artiele Addressed to: 4a. Article Number ~099 3400 0016 3623 7525 112~ OYSTER MILL ROAD E] Registered ][~¢erafied KILL, PA 17011 r-I Express Mail r-I Insured ~ Return Receipt for Memhandise r-I COD REGINA McREDMOND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : NO. 01-6831 CIVIL TERM JOHN McREDMOND, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 30, 2001. 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. I consent to the entry of a final decree in 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. Section 4904 relating to unsworn falsification to authorities. Reglr~McRedr~ond, Pla~tiff REGINA McREDMOND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : NO. 01-6831 CIVIL TERM JOHN McREDMOND, : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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. Reg(n~dcRedmbnd, Plainti~ · REGINA McREDMOND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : NO. 01-6831 CIVIL TERM JOHN McREDMOND, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 30, 2001. 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. I consent to the entry of a final decree in 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. Section 4904 relating to unawom falsification to authorities. ,~bhn McRedmond, Defendant REGINA McREDMOND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : : NO. 01-6831 CIVIL TERM JOHN McREDMOND, : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(¢) 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 verifl/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 unswom falsification to authorities. 70223.1 ~ McRedmond, Defendant REGINA McR.EDMOND, : IN THE COURT OF COMMON PLEAS : : CUMBERLAND COUNTY, PENNSYLVANIA VS. : : CIVIL DIVISION JOHN Mc~EDMOND, : : NO. 01-6831 ClVILTERM 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 divome: Irretrievable breakdown under §3301 (c) (Strike out inapplicable section). 2. Date and manner of service of the complaint: certified mail, served on December 3, 200'1 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: byplainfiff 7/26/04 ; by defendant 7/2'1/04 (b) (1) Date of execution of the affidavit raquired by §3301(d) of the Divome Code: (2) Date of filing and service of the plaintiff's 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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 7/28/04 (mailed 7/27/04' to Prothonotary) Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 7/28/04 (mailed 7/27/04 to Pro~;honotar¥) IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF ~~i~ PENNA. REGINA McREDMOND, NO. 01-6831 CIVIL TERM VERSUS JOHN McREDMOND, DECREE IN DIVORCE ii.' ,FI AND NOW, I~'~ ~ ,2004 ,it IS ORDERED AND DECREED THAT REGINA M~'~I~])MOND , PLAINTIFF, AND 30~{N McREDMOND , DEFENDANT, ARE DIVORCED FROM THE BONDS Of MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED Of RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None