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HomeMy WebLinkAbout04-2456 SCOT A. RICHARDSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERlAND COUNTY, PENNSYLVANIA v. NO. 01/.- ;24S1, CIVIL TERM LISA J. RICHARDSON, CIVIL l.cTION - LAW Defendant DIVORCE: NOTICE TO DEFEND AND CLAIH 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 is indignities or j.rretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street CarliSle, PA 17013 (717) 249-3166 1-800-990-9108 NOTICE QE AVAILABILITY QE 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 Corrnnon Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) 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. SCOT A. RICHARDSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERI.1\ND COUNTY, PENNSYLVANIA v. NO.Ot.j.. .2.'iS{", CIVIL TERM LISA J. RICHARDSON, CIVIL ACTION - LAW Defendant DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Scot A. Richardson who resides at 17 S. 30th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Lisa J. Richardson who resides at 17 S. 30th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant have been a bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 22, 2003 in Milton, Union County, Pennsylvania. between the parties in this or any other jurisdiction. 5. There have been no prior actions of divorce or annulment 6. The marriage is irretrievably broken. the United States or any of its Allies. 7. The Defendant is not a member of the Armed Services of 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. ~U'0. ~ Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 7:11-1461 VERIFICATION 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. 4904, relating to unsworn falsification to authorities. ;-- G "" -""'" I Da t e: :? ~ D -'-"""f Scot A. Richardson '7V '#:- - VI - t;;"' t-<> ,Stl o ~ ~ 9.) r;;- ~ '* --- <S' , d ~ 5ll. -;:\ ., ~ r' " ~ (') f';; ~f? C/} r' ~C~ "=,-, >2:" ~ ~r.:- "" 8 ,..., c.;.') c=> .<- ::1: ~" -< ", co o -., :r' ni;IJ ~gd ~tJ -.- --r-, ~.~~ ~q CSi--n ___..1 }"" ] -< -:J ::r: SCOT A. RICHARDSON, IN THE COURT OF COMMON PLE Plaintiff CUMBERLAND COUNTY, PENNSYLV IA v. NO. 04-2456 CIVIL TERM LISA J. RICHARDSON, CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on May 28, 2004. 2. The marriage of Plaintiff and Defendant is irretriev b1y 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 of Divorce a ter service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entr of the decree. I verify that the statements made in this Affidavit are t ue and correct. I understand that false statements herein are subj ct to the penalties of 18 Pa. C.S. Section 4904 relating to unsw rn DATED: /I-~ r-D4 falsification to authorities. SCOT A. RICHARDSON r;::; (,:=" -'" ...."'" ",- :~::~ r---) t,j.) ~?t .-< ..,. ""f' rrlf::: -'t"'r.t\ :(1,\\"- ~':/)~:'\ r\.'\:p\ '>:~'1:;'i\ ~:2~ ~\.,~ ;'::1.1 .~- "'R cf\ C., SCOT A. RICHARDSON, IN THE COURT OF COMMON PLE Plaintiff CUMBERLAND COUNTY, PENNSyr; IA v. NO. 04-2456 CIVIL TERM LISA J. RICHARDSON, CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on May 28, 2004. 2. The marriage of Plaintiff and Defendant is irretriev bly 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 of Divorce a ter service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42 (e) I have waived he requirement that I receive notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are t ue and correct. I understand that false statements herein are subj ct to the penalties of 18 Pa. C.S. Section 4904 relating to unsw rn falsification to authorities. DATED: / }I-J/-{) LI . "."-- ~"-". l:/' / J o ( ~ I? ~'C.p" c>. ...:. I"~ "-.() I"" c> -" "2 en CO SCOT A. RICHARDSON, Plaintiff IN THE COURT OF COMMON PL CUMBERLAND COUNTY, PENNSYL ANIA v. NO. 04-2456 CIVIL TERM LISA J. RICHARDSON, Defendant CIVIL ACTION - LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree without not'ce. 2. I understand that I may lose rights concerning alim ny, division of property, lawyer's fees or expenses if I do not c aim them before a divorce is granted. 3. I understand that I will not be divorced until a div decree is entered by the court and that a copy of the decree be sent to me immediately after it is filed with the prothonot I verify that the statements made in this Affidavit are and correct. I understand that false statements herein are sub to the penalties of 18 Pa. C.S. Section 4904 relating 70 u s falsification to authorities. I-~ ?-c) <I DATED: // ?-- SCOT A. RICHARDSON rce ill ry. rue ect orn r-> c:;;:',,> f,;::;JI ",- ...~;.". -- ~2 l'~ oS' () HTI .-\ ~"H.n rni";::: ~~jt? (~~; ~f\ .,\..-1\, C)".;:~ .~:;::.. ~~\)'\ 'r-, ..:~ ~~~ ,-0 Gr., CO SCOT A. RICHARDSON, IN THE COURT OF COMMON PLE Plaintiff CUMBERLAND COUNTY, PENNSYLY. IA v. NO. 04 -2456 CIVIL TERM LISA J. RICHARDSON, CIVIL ACTION - LAW Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree without not'ce. 2. I understand that I may lose rights concerning alim division of property, lawyer's fees or expenses if I do not c them before a divorce is granted. 3. I understand that I will not be divorced until a div decree is entered by the court and that a copy of the decree be sent to me immediately after it is filed with the prothonot I verify that the statements made in this Affidavit are t ue and correct. I understand that false statements herein are subj ct to the penalties of 18 Pa. C.S. Section 4904 relating to unsw rn falsification to authorities. DATED: II _1/-/,:l.! , 0<, (" f .. . , '" ...J' , /~ Lr~/J. RICHARDSON ,-, c:.? c::,:~ ~;r..- - 't~) ,.<1(;:: ...:> ...r;; o -,~ q..'n ,".1 f:' -'-::1,1' ::'jt) .,_ 1'"1 ;J~~7\ y'- ~:~l 'fJ "" 0-' .------ SCOT A. RICHARDSON, Plaintiff IN THE COURT OF COMMON PL CUMBERLAND COUNTY, PENNSYL ANIA v. NO. () if - 2. t.fo6 CIVIL TE LISA J. RICHARDSON, Defendant CIVIL ACTION - LAW DIVORCE ACCEPTANCE OF SERVICE I, LISA J. RICHARDSON, accept service of the Divorce Comp aint in the above captioned matter. t: -li-Cij/' Dated: / {Jet LISA J. RI 17 S. 30TH STRE T CAMP HILL, PA 17011 DEFENDANT ...., <;;;;.;> c:c:) .&" ...,"''' (.~~ .- N \.[) \~) (n G0 -- SCOT A. RICHARDSON, IN THE COURT OF COMMON PLE Plaintiff CUMBERLAND COUNTY, PENNSYL IA v. NO. 04-2456 CIVIL TERM LISA J. RICHARDSON, CIVIL ACTION - LAW Defendant DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following informat on, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Sec ion 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On June 11, 2004 by Acceptance of Service. 3. Date of execution of the affidavit of consent require by Section 3301(c) of the Divorce Code: By Plaintiff, November 29, 2004; By Defendant, November 21, 2004. 4 . Related claims pending: N n 5. Date Plaintiff's Waiver of Notice in 5 3301(c) div rce was filed with the Prothonotary on November 29, 2004. Date Defendant's Waiver of Notice in s 3301(c) divor e was filed with the Prothonotary on November 29, 2004. 1>. Thomas D. Gould, Esquire Attorney For Plaintiff .-' c.":! ~ .,r::; f') d:) l \.0 01 U-' (OJ -n :i~ ~'n rnf"~'. ..,.,,\'1. -"Jq ':,?CJ ~":\ .~r :'.:..,1 i.'~:;~;:~:~)1 "\ -,."". -< ------ :+::+::+::+::+::+::+::+::+::+::+::+::+: ~:+::+::+::+::+::+::+::+::+::+::+::+::+::+::+::+::+::+: :+: :+::+::+: :+::+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "':+::+::+: :+::+: :+::+::+::+::+::+::+::+::+::+::+: :+::+::+::+::+::+::+:~:+::+::+::+::+::+::+::+:~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 'ii't''+::+' ",,'+: IN THE COURT OF COMMON PLEA OFCUMBERLANDCOUNTY STATE OF SCOT A. RICHARDSON, Plaintiff No. VERSUS LISA J. RICHARDSON, Defendant DECREE IN DIVORCE AND NOW, ~~ 3D DECREED THAT SCOT A. RICHARDSON AND LISA J. RICHARDSON ARE DIVORCED FROM THE BONDS OF MATRIMONY. PENNA. 04-2456 CIVIL c::r d: r'fl JOt> 1 , IT IS ORDERED AND , PLAINTIFF, , DEFENDAN , THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIC YET BEEN ENTERED; NONE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA . By ATTEST: :+::+::+::+::+::+: :+::+: . :+: :+::+::+::+: :+: :+::+::+::+::+::+::+: HAVE NOT J. PROTHONO ARY :+:'ii 'ii 'ii :+: 'ii:+:'+:'+: '+: ~ fjp-z ~I ry<??t; 1,,7 ~ if' .~ ~/ "?.6v-/.'{? /1(/ ..... . r- l.. . CI rei