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Home My WebLink About09-7558JESSICA L. STEWART, Plaintiff V. LARRY E. STEWART, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0 9- 7SS k CIVIL TERM 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 following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 4 JESSICA L. STEWART, Plaintiff V. LARRY E. STEWART, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 49- SsY CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jessica L. Stewart, an adult individual currently residing at 260 West Ridge Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Larry E. Stewart, III, an adult individual currently residing at 801 Butler Pike, Mercer, Mercer County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 19, 2003, in Perry County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Hannah Herman-Snyder, Esquir Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: a JE ICA L. STEWART, Plaintiff Fli LED 2009 NOV -2 PP4 12: 05 CJP tW . , ?, =OUNJY PCENI"ISYLVANIA S? . 3,3 Ck. '1 / l G kL JESSICA L. STEWART, Plaintiff V. LARRY E. STEWART, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 09-7558 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Hannah Herman-, Esquire, counsel of record for Plaintiff, state that a true and attested copy of a Complaint in Divorce was sent to Defendant, Larry E. Stewart, III, at his address of 801 Butler Pike, Mercer, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on November 19, 2009. Hannah Herman-Snyder, Esqui Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this ? YO day of A,&Vem'hp r , 2009 N ' A PUBLIC ?11r? ¦ Complete items 1, 2, and 3. Also complete A. signature item 4 if Restricted Delivery is desired. X ¦ Print your name and address on the reverse so that we can return the card to you. C. ¦ Attach this card to the back of the maiiplece, or on the front If space permits. D. Is address dffbrent from item V 1. Article Addressed to: H YES, enter delivery address below: Qt`s &C. aA-, Lolf-r? Is 64"4A4-114 ff -T'4 q15 gb ,60-Her Pt kp. o,?,.-cam. A ( 13 -1 Agent NAlo 7- 3. Service type ?ConMied Mail ? Express Mail 13 Registered 13 Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Rssbfcted Delivery? (Ezba Fee) Yes 2. Article Number PS Fortis 3811, February 2oo4 Domestic Return Receipt 1-az-.ls,w ' FILED--(;' Cc 2099410"125 Fig 1- -9 JESSICA L. STEWART, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW LARRY E. STEWART, III, NO. 09-7558 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 Vic) of the Divorce Code was filed on November 2, 2009, and served on November 19, 2009, by certified mail, restricted delivery. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. r DATE: ~~I D (~ , JESS A L. STEWART, Plaintiff ^~ ~--- o ~ ~~ ~~ ~, -~, - r ` ri, - . , - N c..~ r r--, ~'.', .r, ~~ , -rs r , .. --..~ .:~ --- f crt JESSICA L. STEWART, 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW ~-- N_ ~ iii LARRY E. STEWART, III, NO. 09-7558 CIVIL TERM ; ~~ ; ~' -_-~ Defendant IN DIVORCE _~' ` i ~ ~ ~ ~, '' ' ~ L~ -~, r~, ; ~ - =~ ;" -, _ , -~ . .<_} WAIVER OF NOTICE OF INTENTION TO REQUEST , _T ~ ~ ;i.. c-;, 4 ~ THE ENTRY OF A DIVORCE DECREE ~ 1 UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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: o /~ JESS A L. STEWART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica L. Stewart V. Larry E. Stewart, III NO 2009-7558 DIVORCE DECREE AND NOW, i-yta~.u( ~~ zaio , it is ordered and decreed that Jessica L. Stewart plaintiff, and Larry E. Stewart, III ,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 the Court, Att t' J. i~/ Prothonotary