The URL can be used to link to this page

Home My WebLink About09-2180TIMOTHY R. NORRIS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. Dq- al80 civil Term JOYCE A. NORRIS, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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 Courthouse, One 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 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 J tH(Co4elly, Jr., Esq A r Plaintiff TIMOTHY R. NORRIS, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. Uq_ 21N JOYCE A. NORRIS, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary TIMOTHY R. NORRIS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07 - 1 F 6 0 --- JOYCE A. NORRIS, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Timothy R. Norris, who currently resides at 103 8 Swarthmore Road, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Joyce A. Norris, who currently resides at 1038 Swarthmore Road, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Plaintiff and Defendant have 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 September 30, 1989, in Camp Hill, Pennsylvania. 5. There had been a prior action for divorce between the parties filed to Docket No. 01- 3422 which was terminated on December 30, 2004. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. The parties to this action have been physically separated within the marital residence since November 24, 2008. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the Court to enter a Decree in Divorce. 11. Plaintiff avers that he is the innocent and injured spouse, and that the Defendant has offered such indignities to the Plaintiff so as to render his condition intolerable and life burdensome. 12. This action is not collusive. COUNT H CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 13. Plaintiff and Defendant are the owners of various real and personal property, motor vehicles and bank accounts acquired during their marriage which are subject to equitable distribution by this Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; b. equitably distributing all property owned by the parties hereto; and c. for such further relief as the Court may determine equitable and just. Dated: q-6-() By: Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Attorneys for Plaintiff Timothy R. Norris Hershey, PA 17033-0650 (717) 533-3280 VERIFICATION I, Timothy R. Norris, verify that the statements made in this Pleading are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date: Timothy R. Norris r = 'f CE C THc PE (ry ,0r IOTARY 2009 APR -7 FM 1: 32 r? PBtr'q'? L?i i^S)r11 `,r}???A,=d'A i 4S(04.50 Po ATW Q.T'"= aas3?7 TIMOTHY R. NORRIS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-2180 JOYCE A. NORRIS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN : ss. AND NOW, this 10th day of April, 2009, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Divorce Complaint was served on the Defendant, Joyce A. Norris, on April 9, 2009, by certified mail number 7008 1300 0001 8217 5324, as evidenced by the return receipt card attached hereto and made a part hereof Sworn to and subscribed before me this Q4 day of April, 2009. otaryPublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria B. LaRue, Notary Public Deny Twp., Dauphin County MY Commission Epires Nov. 8, 2009 Member, Pennsylvania Association of Notaries ni m m r- OFFICIAL USE ,-.l I-oo Cerftd Fee a . ri o C3 F?etum Receipt Fee ark O {EndofaemerttRequired) a. a?a ?ed +s ?`1 ndotsemeRequire? rrM Tote) Postage & Fees $' b. t d co Sew 76 1.c...._.?:_..1. Y vt ?.? S .... Street; Apt 73'0:; ••--- .. .....-. E3 orPOBoxAb. J ..... c .. ¦ ftt your awn* and ac mthat vie can ftrhtm I ¦ Attach this owd to the or on the front 8 space b do*W. X e an the reverse rd to yom th a. e rnaw", 1. ArW9 Addressed to. 73b cc S NR,?i Cbc? !o??? '?'? 1'1 i>'1 v i. 1-0911 NNOW, ; 7008 130 D. Ea ddvery addmas dNrwttfiorn heat 11 U YM H YES, snte?dWhmy addraa boom - ? No a STOP TO* Mid E3 t3cprws MeM 0 Repieteted O Rehm ReoNpt for Matdartdea O Mreteed Mldl E3 C.O.D. 4. PAdddld DoNssr'y? Oft A 0 0001 8217 5324 4Y THE t'''^"`3 ` s -OTAPY 2064 APES 14 Pi 1 • C2 C?? t{iiL:. _,}OUN1 ? FE!'"?? riliA0.}Jp VI ? ,yr?i TIMOTHY R NORRIS, Plaintiff/Respondent VS. . JOYCE A. NORRIS, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE NO. 09-2180 CIVIL TERM IN DIVORCE PACSES CASE: 046110995 ORDER OF COURT AND NOW to wit, this 10th day of August, 2009, it is hereby Ordered that the Petition for Alimony Pendente Lite for the above captioned case is continued generally. This matter may be scheduled upon the written request of either party. This Order shall become final twenty (20) days after the mailing of the notice of the entry of the order to the parties unless either party files a written demand with the Domestic Relations Section for a hearing de novo before the Court. BY THE COTJRT: M. L. Ebert, :fr., J. DRO: R.J. Shadday xc: Petitioner Respondent Samuel L. Andes, Esq. John J. Connelly, Jr., Esq. Form 0E-001 Service Type: M Worker: 21005 ~t ~1 ~f ry^,~