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Home My WebLink About09-7649/' JOHN MICHAEL MCBRIDE, Plaintiff LISA ANN MCBRIDE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . NO. p9 - -71 y 9 : CIVIL ACTION -LAW : 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 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 of 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, One Courthouse Square, Carlisle, Pennsylvania 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 •?- JOHN MICHAEL MCBRIDE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. D 5- 2 ? V9 Ck?-J 7-,c....- LISA ANN MCBRIDE, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes Plaintiff, John Michael McBride, pro se, and files the within Complaint against the Defendant, averring as follows: Divorce Under 6 3301(c) and 4 3301(d) of the Divorce Code 1. Plaintiff is John Michael McBride, an adult individual, who currently resides at and has a mailing address of 243 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043. Plaintiff has lived at said address since March 2003 2. Defendant is Lisa Ann McBride, an adult individual who currently resides at 604 Warren Street, Lemoyne,Cumbedand County, Pennsylvania 17043. Defendant has lived at such address since September 2009. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 8, 1999, in Harrisburg, Dauphin County, Pennsylvania, and separated in November 2008, and have lived separate and apart since that time. 5. The Plaintiff and Defendant are both citizens of the United States of America and are not members of the Armed Forces. 6. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. Plaintiff understands that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce pursuant to Section 3301(c) or Section 3301(d) of the Pennsylvania Divorce Code of 1980, as amended. I, John Michael McBride, 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. JOHN MICHAEL M BRIDE Plaintiff Dated: /1/5 /OQ FUL: t vi r: 2;09 NOY -5 Pit 2* 04 3 3 0,S'S JOHN MICHAEL MCBRIDE, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA aq-~t~yq v. N O. -9~9~6~~ C ivi C7 ~' -. LISA ANN MCBRIDE, :CIVIL ACTION -LAW Defendant ='" `= '~' -~' IN DIVORCE ~' ' "~" ...J i _.~) \_~ _ .~ i l _-% AFFIDAVIT OF CONSENT ==~ ~- ~~~a r. ____ ,. -~ 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was`~`iled on November 5, 2009, and served on the Defendant on November 8, 2009. An acceptance of service form was filed on November 13, 2009. 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. 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. OH MICHAEL MCBRIDE Plaintiff DATE: 2`l~/l U JOHN MICHAEL MCBRIDE, Plaintiff v. LISA ANN MCBRIDE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA a4-~I'~yq Nn aa.r~~. c~~~i CIVIL ACTION -LAW IN DIVORCE ~_ ~F ~} ~`'~. -;' ,`:~.. r:_ .:_ _,: N -~, ~~ a :~.. f p~ c,:: ._~ ;:~==-~ -,- ~-,z _i-~ ~'~J r ~-; c.. L ~ _: ,~ ; ~-~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications to authorities. ~% % ~ OHN MICH EL CBRIDE Plaintiff Dated: zlilo/(O JOHN MICHAEL MCBRIDE, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA oq-h~49 v. N O. -89-G7,49-Civil ~, ~--- LISA ANN MCBRIDE, :CIVIL ACTION -LAW - cz~ Defendant -- ~' G r _ ~ ~~ `'~ IN DIVORCE ~ ~ ' ~, ~_ _:~. ; - ~ ~~; ;~ c~~ ~`j -~ AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on November 5, 2009, and served on the Defendant on November 8, 2009. An acceptance of service form was filed on November 13, 2009. 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. 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. n A AN MCBRIDE Defendant DATE: , ~ ~ JOHN MICHAEL MCBRIDE, Plaintiff v. LISA ANN MCBRIDE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA og-~~y9 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c,~ OF THE DIVORCE CODE c. _~,. ~;;-=- ~', , 1. I consent to the entry of a final decree of divorce without notice. -,~ s~.~ ~, G..~ c:.:: 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. _, -_~ -,- -r, c _> _~- J,_; ; --; ~{ 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications to authorities. ~~ A AN MCBRIDE Defendant Dated: ~ + ~ ~ ~