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Home My WebLink About09-2217THOMAS F. FORD, Plaintiff v. LISA A. FORD, Defendant :IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA . NO. Oq - oZo117 li-v it T~Ir'N'` CIVIL ACTION -- 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 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, 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 ANNiTLMENT 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 23 South Bedford Street Carlisle, PA 17013 (717) 249-3166 THOMAS F. FORD, : IN THE COURT OF COMMON PLEAS, Plaintiff :CUMBERLAND COUNTY, :PENNSYLVANIA v. LISA A. FORD, Defendant :CIVIL ACTION -- DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Thomas F. Ford, who resides at 4800 B Charles Road, Mechanicsburg, Pennsylvania 17050. 2. Defendant is Lisa A. Ford, who resides at 7 Rexford Road, Enola, Pennsylvania 17025. 3. Plaintiff and Defendant have been bona fide residents of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 11,1993, in Camp Hill, Pennsylvania. 5. The parties have been living separate and apart since on or about August 1, 2007, a date prior to the filing of this Complaint. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and of the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff waives the right to request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. Plaintiff avers that this ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter a Decree of Divorce. DATED: ~ - ~ „ 0 Respectfully submitted, -~~ i _.__ No F. Blair Supreme Court ID 45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VERIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dated: ~ FI1.~D-~=1~~ ~F Tk~ , t`~T~;~~TAAY 209 Af~R -8 Ply 1 CU~a~ ~~ t~?~rv;Y $338.50 PD ATT`/ C',i~*' 388 aa34rl`f THOMAS F. FORD, Plaintiff v. LISA A. FORD, Defendant :IN THE COURT OF COARMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2217 Civil Term CIVIL ACTION -- DIVORCE ACCEPTANCE OF SERVICE I, Melissa Peel Greevy, am theAttorney for the Defendant, Lisa A. Ford, in the above-captioned matter. In that capacity, I am authorized/to and have accepted service of -the Complaint in Divorce, as of this the / may of 2009. Melissa Peel Greevy, Esquire Attorney for Defen Supreme Court ID ~~ 301 Market Street PO Box 109 Lemoyne, PA 17043 #~~ ~ °~ ~~YF~"t~.:`"_ ~.ii ~~±` r'r ~ ~ . ~+r~t r THOMAS F. FORD, : IN THE COURT OF COMMON ~LE~iS,_ f Plaintiff :CUMBERLAND COUNTY, PENNS,V~IIA_, - ." r__, a7i - ~ --; ova v. : NO. 09-2217 Civil Term ~ ` ~. -`~ `~` . : i_ - = ...,, - 7. LISA A. FORD, :CIVIL ACTION -- DIVORCE = ' <. Defendant =~ ~~' ~~+ i G ~ :,~ ~, PRAECIPE TO TRANSMIT RECORD UNDER § 3301(c) OF THE DIVORCE CODE 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 the complaint: (a) Date of service: April 13, 2009. (b) Manner of service: Acceptance of Service by Counsel for Defendant 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: (a) By the Plaintiff: January 15, 2010 (b) By the Defendant: January 19, 2010 4. Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (a) By the Plaintiff: January 15, 2010 (b) By the Defendant: January 19, 2010 5. Related claims pending: NONE DATED: January 22, 2010 ora .Blair, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THOMAS F. FORD v. LISA A. FORD NO. 09-2217 CIVIL TERM DIVORCE DECREE AND NOW, r ~, ~~ , it is ordered and decreed that THOMAS F. FORD ,plaintiff, and LISA A. FORD ,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 t ourt, Attest: ~ - Prot onotary