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Home My WebLink About01-0062LYNN L. LIBBY, Plaintiff VSo ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- DIVORCE NO. 01- ~j~:~- CIVILTERM IN DIVORCE NOTICE 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, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & MNDSAY, P.C. Attorneys for Plaintiff By: Carol O. ~inds~y, Esquire ~ ID # 44~ 26 West High Street Carlisle, PA 17013 (717) 243-6222 Date: libby complaint in divorce tjb 01/02/01 LYNN L. LIBBY, Plaintiff vs. ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - DIVORCE : NO. 0~1- (~,~ CIVILTERM : : IN DIVORCE COMPLAINT ~ w. High st~,~t LYNN L. LIBBY, Plaintiff, by her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, P.C., respectfully represents: 1. The Plaintiff is Lynn L. Libby, who currently resides at 919 Thorton Drive, Mechanicsburg, Cumberland County, Pennsylvania, where she has resided since September 3, 2000. 2, The Defendant is Robert R. Libby, Jr., who currently resides at 113 Rollo Court, Mechanicsburg, Cumberland County, Pennsylvania, where he has resided since 1994. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately pdor to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 27, 1988, at Harrisburg, Dauphin County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. libby complaint in divorce tjb 11/06/00 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: 26 West High Street Carlisle, PA 17013 (717) 243-6222 26 W, High ~reet Ca~ PA libby complaint in divorce tjb 11/06/00 VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. Date: ~6 w. l~gh steer Cadlde, PA libby complaint in divorce tjb 01/17/01 LYNN L. LIBBY, Plaintiff vs. ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION o DIVORCE NO. 01 - ~, 7__ CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE AND 2001, I, CAROL J. LINDSAY, Esquire, of the law firmr~f~AIDIS, SHU~,Ff~FLOWER & LINDSAY, Attorneys, hereby certify that I served the Defendant, ROBERT L. LIBBY, JR. on January 12, 2001 with the Complaint in Divorce by Certified Mail, Restricted Deliver, Addressee Only, Return Receipt Requested, addressed to: Robert L. Libby, Jr. 113 Rollo Court Mechanicsburg, PA 17055 and 3roof thereof, the signed Return Receipt Card, is attached hereto. ~AIDIS, [UFF & ASLAND High Street ~arllsle, PA SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By ~.-~..._ L, arol'J ~'Cin~, Esquire 26 West High Street Carlisle, PA 17013 (717) 243-6222 libby complaint in divorce tjb 01/17/01 LYNN L. LIBBY, Plaintiff VS. ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 01-L.~/' ~ CIVIL TERM IN DIVORCE PROOF OF SERVICE · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse A. Received by (P~ase Print Clearly) B. Date of D~ ~o that we can return the (~ard to you. C. I~~ i-I · Attach this card to the back of the mailpiece, X~~,~.~ ~ r3 AgentAddn~eee o~ on the front if space permits. D. Is delivery address diff~ item 17 [] Yes 1. /~cle A~dressed to: if YES, enter delivery address below: [] No ! ~ ~' ~ -- ~ert'~l~d Mail ~1 Express Mail '~ f"l Flegle~ed r-I Return Receipt for Merchsndlae r-I Insured Mail [] C.O,D. ~ ' 4. Restricted Delivery? (Extra Fee) [~es 2. A~ticle Number (Copy from service label) ~AIDIS, [ I. JFF & ASLAND ~/. High Slreet ~arlisle, PA LYNN L. LIBBY, : Plaintiff : : VS. .' .. ROBERT R. LIBBY, JR., : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 01- 62 CIVILTERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divome Code was filed on January 2, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. SAIDIS ~HUFF, FLOWER & LINDSAY 26 W. High Stree~ Carlisle, PA libby complaint in divorce tjb 04/20/01 LYNN L. LIBBY, Plaintiff VS. ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 01 - 62 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~ L. 'bby,/ laintiff (~ SAIDIS SHUFF, FLOWER & LINDSAY 26 w. High Street Carlisle, PA libby complaintin divorce tjb 04/20/01 LYNN L. LIBBY, Plaintiff VS. ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 01- 62 ClVlL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on January 2, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~. L'b~ ~, r~., [~efendant Date: ~C'-/7-0Z- SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carligle, PA i~AY 2 ::~ ?007 libby complaint in divorce tjb 04/20/01 LYNN L, LIBBY, Plaintiff VS. ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 01- 62 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF iNTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: 5'-/'7 SAIDIS lUFF, FLOWER LINDSAY ~YS~AToLAW W. High Slreet Carlisle, PA SAIDIS R~FF, FLOWER & LINDSAY !6 W. High Street Carlisle, PA LYNN L. LIBBY, Plaintiff VS. ROBERT R. LIBBY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 01- 62 ClVlL TERM IN DIVORCE PRAEClPE 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 Section 3301 (c) ~'~'~/'~/~ ~ of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certificate of Service filed January 22, 2001 3. (Complete either paragraph (al or (b)). (al Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff filed on May 22, 2002; by the Defendant flied on June 5, 2002 (b) (1) Soction 3301 (d) of thc Divoroc Codc: (2) [3otc of scrvico of thc Piaintiff'c Dcfc,",dc,qt: Related claims pending: None Complete either (al or (b). (al (b) Datc of cxcoution of thc Plaintiff'o affidavit rcquircd by affidavit upon thc Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: May, 2002 Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: June, 2002C~~ ~ '-rney~for'~y, Atto Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~~~, PENNA. LYNN L. LIBBY, Plaintiff NO. 01-62 CIVIL TERM VERSUS ROBERT R. LIBBY, JR., Defendant IN DIVORCE DECREE IN DIVORCE AND NOW, DECREED THAT AND LYNN L. LIBBY ROBERT R. LIBBY, JR. , ~:~2. IT IS ORDERED AND __, PLAINTIFF, , 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 BY The COURT: