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HomeMy WebLinkAbout09-6709APRIL B. BECKETT, Plaintiff ) VS. ) CHRISTOPHER J. BECKETT, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09- G7b19 7?? 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 foregoing 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 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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, PA 17013 Telephone: (717) 249-3166 APRIL B. BECKETT, Plaintiff ) VS. ) CHRISTOPHER J. BECKETT, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint 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 being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, 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 days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. APRIL B. BECKETT, Plaintiff vs. CHRISTOPHER J. BECKETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09- G 7o 9 I N DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, APRIL B. BECKETT, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is APRIL B. BECKETT, an adult individual who currently resides at 201 East Walnut Street in Shiremanstown, Cumberland County, Pennsylvania. 2. The Defendant is CHRISTOPHER J. BECKETT, an adult individual who currently resides at 201 East Walnut Street in Shiremanstown, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 5 July 2002 in Hellam, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. amuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12?h Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). 11 A Date: 1-7 D 9 AlyfffJB. Q n r., f rt co OR W W ,°9 C APRIL B. BECKETT, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CHRISTOPHER J. BECKETT, Defendant NO. 09-6709 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME NOTICE IS HEREBY GIVEN that APRIL B. BECKETT, Plaintiff in the above matter, [select one by marking "x": _ prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of APRIL BETH VORM, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: t L k IV COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AP L BETH BECKETT,., Si a of name being resumed APRIL BETH VORM ( SS.. On the 9th- day of -& UM 10,&) , 2010, before me, the undersigned officer, personally appeared APRIL BETH BECKETT, known to me (or satisfactorily proven) to be the person whose name is signed to the within Notice to Resume Prior Surname and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL AMY M. HARKINS, Notary Public emoyne Boro., Cumberland Coun Notary ublic 4 7ammiw1pi, ft Ms s FILED-OFFICE OF THE PROTHONOTARY 2010 DEC -9 PM 2: 15 CUMBERLAND COUNT PENNSYLVANIA a. l/. do A141 Afwtj ?f ? 7sdao3 APRIL B. BECKETT, PLAINTIFF FILED-OFFICE A THE PRi T [10N 3T;,R!,, VS. 2011 MAY -2 APB 10: 04 CUMBERLAND COUNTY CHRISTOPHERJ. BECKE'ENNSYLVANIA DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-6709 CIVIL TERM IN DIVORCE Motion for Appointment of Master April B. Beckett, Plaintiff moves the court to appoint a Master with respect to the following claims: (xxx) Divorce ( ) Annulment (xxx) Alimony (xxx) Alimony Pendente Lite and in support of the motion states: (xxx) Distribution of Property ( ) Support (xxx) Counsel Fees (xxx) Costs and Expenses 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Defendant has appeared in the action by his attorney, Melanie L. Erb, Esquire. 3. The statutory ground(s) for divorce is/are: -4 3';-X, 0 N C& 4. Check the applicable paragraph(s). 4'10;?The action is not contested. ( ) An agreement has been reached with respect to the following claims: ( ) The action is contested with respect to the following claims: 4' 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. 7. Additional information, if any, relevant to the motion: Date AND NOW, with respect to the following claims: divorce. Samuel L. Andes Attorney for Plaintiff 2011, , Esquire, is appointed Master BY THE COURT, Distribution: Samuel L. Andes, Esquire 525 North 12d' Street, P.O. Box 168, Lemoyne, Pa 17043 Melanie L. Erb, Esquire 2132 Market Street, Camp Hill, PA 17011 Christopher J. Beckett 3901 Society Hill Drive, Apt. 107, Camp Hill, PA 17011 J. r? H +?ll May -Z A1?110, 03 c1 PEN SYLVAN A? y APRIL B. BECKETT, PLAINTIFF VS. CHRISTOPHER J. BECKETT, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-6709 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated CJ rX - c? ?0 and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Date: 714LAPB. BECKETT APRIL B. BECKETT, PLAINTIFF ) VS. ) CHRISTOPHER J. BECKETT, ) DEFENDANT ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-6709 CIVIL TERM IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because (check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least 2 years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this Counter-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. Date: CHRISTOPHER J. BECKETT NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. APRIL B. BECKETT, PLAINTIFF FILED-OFFICIO a`r THE PRO T FOND TAR?( vs. 2011 MAY -2 AM 10: 04 'CUMBERLAND COUNTY CHRISTOPHER J. BECKE'ENNSYLVA.I°dIA/? DEFENDANT y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-6709 CIVIL TERM IN DIVORCE Motion for Appointment of Master April B. Beckett, Plaintiff moves the court to appoint a Master with respect to the following claims: (xxx) Divorce ( ) Annulment (xxx) Alimony (xxx) Alimony Pendente Lite and in support of the motion states: (xxx) Distribution of Property ( ) Support (xxx) Counsel Fees (xxx) Costs and Expenses 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Defendant has appeared in the action by his attorney, Melanie L. Erb, Esquire 3. The statutory ground(s) for divorce is/are: 4. Check the applicable paragraph(s). 4%i!r The action is not contested. ) An agreement has been reached with respect to the following clai ms: ? ( ) The action is contested with respect to the following claims:! c-iZT / c 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. = _4 7. Additional information, if any, relevant to the motion: m t;;= tee a rn r? t ? Cs h8 -jo 1 t 2 7 c? - -n a* 7? 6, - - Date Samuel L. Andes -- = co Attorney for Plaintiff AND NOW, 2011, 0,e,6,-j? Esquire, is appointed Master with respect to the following Aims: divorce. BY THE COURT, 11 Distribution: 10 J. 5 Samuel L. Andes, Esquire 525 North 12"' Street, P.O. Box 168, Lemoyne, Pa 17043 Melanie L. Erb, Esquire 2132 Market Street, Camp Hill, PA 17011 ? Christopher J. Beckett 3901 Society Hill Drive, Apt. 107, Camp Hill, PA 17011 APRIL B. BECKETT (now April B. Vorm), Plaintiff vs. CHRISTOPHER J. BECKETT, ) Defendant ) ? f ! JUN 23 AM !0: F CUMBERLANO PENNS L\?A Mf?y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-6709 CIVIL TERM IN DIVORCE PLAINTIFF'S PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and makes the following Petition for Economic Relief: COUNT I EQUITABLE DISTRIBUTION 1. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property Samuel L: Antes Attorney for Plaintiff P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: (O A RIL B. VORM?. kto