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Home My WebLink About10-0885LORETTA Y. ANDERSON PLAINTIFF VS COREY C. ANDERSON DEFENDANT CIVIL ACTION - DIVORCE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. lb - 885 NOTICE TO DEFEND Civil lpr e? a av r ca -?r N You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. 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 divorce i marriage, you may request marriage counseling. Office of the Prothonotary at the first floor Courthouse Square, Carlisle, Pennsylvania. indignities or irretrievable breakdown of the A list of marriage counselors is available in the in the Cumberland County Courthouse, One 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 BEDFROD STREET CARLISLE, PA 17013 (717) 249-3166 -*3SQ. COO P 1k ATty 840 237 i'7q h LORETTA Y. ANDERSON PLAINTIFF VS COREY C. ANDERSON DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Loretta Y. Anderson, by her attorney, Gail Guida Souders, Esquire, and pursuant to Section 3301 (d) of the Pennsylvania Divorce Code, seeks to obtain a Decree in Divorce from the Defendant, Corey C. Anderson, upon the grounds set forth: 1. The Plaintiff, Loretta Y. Anderson, is an adult individual residing at 211 C Market Street, New Cumberland, Pennsylvania 17070. 2. The Defendant, Corey C. Anderson, is an adult individual residing at 3109 Union Deposit Road, Harrisburg, Pennsylvania 17109. 3. Plaintiff has been bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 14, 1993 in Harrisburg, Pennsylvania. M 5. 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 and does not request the same. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a retired member of the Armed Services of the United States. 9. The parties have three minor children together. 10. The Plaintiff avers that the grounds on which the action is based are: (a) That the marriage is irretrievably broken under 23 Pa. Const. Stat. § 3301(d). (b) The parties have been separated since February 2005. 11. The plaintiff requests this Honorable Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests your Honorable Court enter a Decree as follows dissolving the marriage between the parties. Respectfully submitted IM P -? Gail Guida Souders Attorney for Plaintiff Guida Law Offices, P.C. 111 Locust Street Harrisburg, PA 17101 Supreme Court ID # 68740 I, Loretta Y. Anderson, 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. DATE: ?A- z o 10 A FORNEY FOR PLAINTIFF a LORETTA Y. ANDERSON IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLANDCOUNTY, PENNSYLVANIA VS CNIL ACTION -DIVORCE COREY C. ANDERSON DEFENDANT NO. I 0-885 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on February 16, 2010, I served a copy of the Divorce Complaint upon Corey C. Anderson and in the manner indicated below, which service satisfies the requirements of Pennsylvania Rule of Civil Procedure. 403. Service by U.S. Certified Mail to: ~-~ `=- ^a ~ =_~ Corey C. Anderson n ;~~~~' ~ ~ -~ ~~ 3109 Union Deposit Road `p ~ ' ' - Harrisburg, PA 17109 ~ ~' ~ rv rv ~; ~, ~?'~ - -~ ._. _ -- ~? ~7~ y W 1 ,~ C S= "'G Gail Guida Souders, Esquire Guida Law Offices, P.C. 111 Locust Street Harrisburg, PA 17101 717-236-6440 Dated: February 19, 2010 I4 t~laif^I~la^)•PII! (Domestic Mail Only; Nc i L~ ~-- ~-~ ---- -~--- -- - . rnw~aatavw~ r ~ ~ ~ ~ ~ Postage $ ~ O Certified Fee :Z.~ Q~ p O Retum Receipt Fee (Endorsement Required) fZ.',~ Postmark Here p Restricted Delivery Fee ~~~ Q-. (Endorsement Required) ~ r1J Total Postage & Fees ~~. ~l OZ/1Z~~11) ~ nt To '~ ('~ 3`Freiet, -- orPOi3ozlYo~ ~ t'` ~ 4 ~ ^C 1//y /?IC l ------------------ ---- Clty, State, Zl --"- - ---- ----- l__.. - ltd- 1~-K- -•--- :rr , ^ Complete Rams 1, 2, end 3. Also complete Rem 4 H Restricted Delivery is desired. ^ Prhrt your name and address on the reverse so that we can return the card to you. ^ Attach this card to the t>~ of the mallpiece, or on the trout ff space permRs. 1. Article Addressed to: ~r ~Jo Una ~~ ~~i~~ A iti ., 0 ~rt B. Recblved by (piylrtet!i Name) C. Date of Dt~litlery D. Is delhbryisddress diHererrt from R~ 7? ^ Yes If YES, en48r deNvery address below: D No ~,~ ;~ ~ ~ , J ~~ertlfled Mail D ~s Mail ^ Return Reoelpt for Menchartdlse ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Ex6a Fee) ^ lllss . Article Number f~rls~erfiomservlo,~ 7004 2890 0002 8003 0227 ~ r'orrrr 3137 i Fetxuary 2004 pp~ R~rv ~~ __ _-- 1oz59s-o2-M-tsw 2 n LORETTA Y. ANDERSON iN THE COURT OF COMMON PLE~ ~r, ~ --~ Plaintiff CUMBERLAND COUNTY, PENNS.'VA N, r ~ VS. ;'~~;~;: CIVIL TERM ~ N ~ 'gym ' . NO. 2010-885 c . -~ :;. COREY C. ANDERSON ~` ~ _- . Defendant CIVIL ACTION -DIVORCE `'c ca ~~~~ ~ o PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Grounds for divorce: irretrievable breakdown under Section Q 3301 c (X) 3301 d of the Divorce Code (Check applicable code) 2. Date and manner of service of the complaint: February 3, 2010 by U.S. Certified Mail. 3. (Complete either paragraph (A) or (B).) (A) Date of execution of the affidavit of consent required by Section 3301 (c) of the divorce code: Plaintiff- , Defendant- (B) (1) Date of execution of the plaintiff s affidavit required by Section 3301 (d) of the Divorce Code: March 24, 2010 (2) Date of filing and service of the plaintiff's affidavit upon the respondent filed: March 26, 2010 Related claims pending: N/A 4. (Complete either (A) or (B).) (A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Service was done by U.S. Mail on Apri128, 2010. (B) (1) Date plaintiff s Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: (2) Date defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: Attorney for (X) Plainti efendant LORETTA Y. ANDERSON 1N THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. . NO. 2010-885 CIVIL TERM COREY C. ANDERSON Defendant CIVIL ACTION -DIVORCE n ,~, C ° ..... t, -~'' ~= NOTICE OF INTENTION TO REQUEST ENTRY ~ ,_T~~ OF § 3301 (D) DIVORCE DECREE ~ * -' N °'~ ~ ,- .. '`.1 ~_> To: Corey C. Anderson, Defendant ~ ~ ~ ~~ rv ~3 rr, -~ You have been sued in an action for divorce. You have failed to answer th~cor~lain~a'or file acounter-affidavit to the § 3301. Therefore, on or after 20th day you receive this notice, tie other party can request the court to enter a final decree in divorce. If you do file with the prothonotary of the court an answer with your signature notarized or verified or acounter-affidavit by the 20th day after you received this notice, the court can enter a final decree in the divorce. Acounter-affidavit, which you may file with the prothonotary of the court, is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the 20~' day after you received this notice or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter- affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH FELOW TO FIND OUT WHETHER YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFROD STREET CARLISLE, PA 17013 (717) 249-3166 . ~, , LORETTA Y. ANDERSON PLAINTIFF VS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE COREY C. ANDERSON DEFENDANT NO. l D - 885 NOTICE TO DEFEND ~.ivil i~r ..~ 0 -n v~v r w ~c N .. ._ You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. 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 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 first floor in the Cumberland County Courthouse, One Courthouse Square, 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFROD STREET CARLISLE, PA 17013 (717) 249-3166 $35ot . oo ~ A A`~t^/ ~-~ $~f0 ~ as7 i~~ ...~ LORETTA Y. ANDERSON : IN THE COURT OF COMMON PLEAS PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION -DIVORCE COREY C. ANDERSON DEFENDANT ; NO, 10 _ ~, ~~ c v~ ~ ~c~~ COMPLAINT iN DIVORCE AND NOW, comes the Plaintiff, Loretta Y. Anderson, by her attorney, Gail Guida Souders, Esquire, and pursuant to Section 3301 (d) of the Pennsylvania Divorce Code, seeks to obtain a Decree in Divorce from the Defendant, Corey C. Anderson, upon the grounds set forth: 1. The Plaintiff, Loretta Y. Anderson, is an adult individual residing at 211 C Market Street, New Cumberland, Pennsylvania 17070. 2. The Defendant, Corey C. Anderson, is an adult individual residing at 3109 Union Deposit Road, Harrisburg, Pennsylvania 17109. 3. Plaintiff has been bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 14, 1993 in Harrisburg, Pennsylvania. . ,.. 5. 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 and does not request the same. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a retired member of the Armed Services of the United States. 9. The parties have three minor children together. 10. The Plaintiff avers that the grounds on which the action is based are: (a) That the marriage is irretrievably broken under 23 Pa. Const. Stat. § 3301(d). (b) The parties have been separated since February 2005. 11. The plaintiff requests this Honorable Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests your Honorable Court enter a Decree as follows dissolving the marriage between the parties. Respectfully submitted ~~ I Gail Guida Souders Attorney for Plaintiff Guida Law Offices, P.C. 111 Locust Street Harrisburg, PA 17101 Supreme Court ID # 68740 ,. r' I, Loretta Y. Anderson, 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. DATE: ~ Z ~~ O A 1 1 UKN L Y r~UR PLAINTIFF LORETTA Y. ANDERSON IN THE COURT OF COMMON PLEAS PLAIrrTIFF CUMBERLANDCOUNTY, PENNSYLVANIA VS CIVIL ACTION - DNORCE COREY C. ANDERSON . DEFENDANT NO. 10-885 CNIL TERM CERTIFICATE OF SERVICE I hereby certify that on Apri128, 2010, I served a copy of the Notice of Intention to Request Entry of 3301 (d) Divorce Decree upon Corey C. Anderson and in the manner indicated below, which service satisfies the requirements of Pennsylvania Rule of Civil Procedure. 403. Service by U.S. Mail to: Corey C. Anderson 3109 Union Deposit Road Harrisburg, PA 17109 n c~ ^~ ° ~~ ~~~ o Gail Guida Souders, Esquire ~ E-` 'c `Y~F ~ Guida Law Offices, P.C. ~~= '`-' `=` 111 Locust Street Harrisburg, PA 17101 .. ~::' -E` , ;.._; 717-236-6440 ~ -=~ -; w -- .-c Dated: May 19, 2010 GUIDA LAW OFFICES, P.C. 1 1 1 LOCUST STREET HARRISBURG, PA 17101 uidalaw(~verizon net GAIL GUIDA SOUDERS, ESQUIRE PHONE: (717) 236-6440 FAX: (717) 236-9599 April 28, 2010 Corey Anderson 3109 Union Deposit Road Harrisburg, PA 17109 Re: Loretta Y. Anderson v. Corey C. Anderson No: 10-885 Civil Term Dear Mr. Anderson: Enclosed is a copy of the Notice of Intention to Request Entry of 3301 (d) Divorce Complaint. If you have any questions, please consult an attorney. ~incfre ° ~~_ /Ii ~, ~~ ~ ~ Gail Guida~ouders Cc: Enclosure File .+" LORETTA Y. ANDERSON IN THE COURT OF COMMON PLEAS pLAINTTFF CUMBERLANDCOUNTY, PIENNSYLVANIA VS CNIL ACTION -DIVORCE COREY C. ANDERSON DEFExDArrT : NO. 10-885 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on Apri128, 2010, I served a copy of the Notice of Intention to Request Entry of 3301 (d) Divorce Decree upon Corey C. Anderson and ini the manner indicated below, which service satisfies the requirements of Pennsylvania Rule of Civil Procedure. 403. Service by U.S. Mail to: Corey C. Anderson 3109 Union Deposit Road Harrisburg, PA 17109 Gail Guida Souders, Esquire Guida Law Offices, P.C. 111 Locust Street ~ ~ ~ C _ =~; Harrisburg, PA 171 O 1 •~:> ~ ~.t:~ , --~- - 717-236-6440 nit., _- - _,:~, ~• ,~i ?~ ~ . , `~ - Dated: May 19, 2010 j~ :~. ~ ~-n ., ~ v C:. "< GUIDA LAW OFFICES, P.C. ~' 1 1 1 LOCUST STREET ~" HARRISBURG, PA 1 ? 101 uidalawnav,verizon.net GAIL GUIDA SOUDERS, ESQUIRE April 28> 2010 Corey Anderson 3109 Union Deposit Road Harrisburg, PA 17109 Re: Loretta Y. Anderson v. Corey C. Anderson No: 10-885 Civil Term Dear Mr. Anderson: PHONE: (?17) 236-6440 FAX: (? ] 7) 236-9599 Enclosed is a copy of the Notice of Intention to Request Entry of 3301 (d j Divorce Complaint. If you have any questions, please consult an attorney. ~in~fre ~~_ , l / , -' Il; '~~ -- ~ Gail Guida~ouders Cc: Enclosure File LORETTA Y. ANDERSON Plaintiff VS. COREY C. ANDERSON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYI~'A11'~ 0 'T'j ~r NO. 2010-885 CIVIL TERM r~ `-" x '-" :' _ CIVIL ACTION -DIVORCE t . ~~. ~...: ~" xm c4 c~ .. PRAECIPE TO TRANSMIT RECORD ~ c,- c To the Prothonotary: ~~-,j T ~ -~ rn -rj cf °> .~. ' '. J y~ :~ Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section Q 3301 c (X) 3301 d of the Divorce Code (Check applicable code) 2. Date and manner of service of the complaint: February 3, 2010 by U.S. Certified Mail. 3. (Complete either paragraph (A) or (B).) (A) Date of execution of the affidavit of consent required by Section 3301 (c) of the divorce code: Plaintiff- , Defendant- (B} (1) Date of execution of the plaintiff s affidavit required by Section 3301 (d) of the Divorce Code: March 24, 2010 (2) Date of filing and service of the plaintiff's affidavit upon the respondent filed: March 26, 2010 Related claims pending: N/A 4. (Complete either (A) or (B).) (A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Service was done by U.S. Mail on April 28, 2010. (B) (1) Date plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: (2) Date defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: l/~ Attorney for (X) Plainti efendant r LORETTA Y. ANDERSON Plaintiff VS. NO. 2010-885 CIVIL TERM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE n 4 ~_ ~_, -_ o -n :.~ -~ NOTICE OF INTENTION TO REQUEST ENTRY a _'~; ~'~' •~~ OF § 3301 (D) DIVORCE DECREE _ ~, . _-_~'~ =, ~ --= To: Corey C. Anderson, Defendant `__ -°~ ~-~`-' i^ ~ ~ N ;rn, :. You have been sued in an action for divorce. You have failed to answer th~co air~or file acounter-affidavit to the § 3301. Therefore, on or after 20th day you receive this notice, tie other party can request the court to enter a final decree in divorce. COREY C. ANDERSON Defendant If you do file with the prothonotary of the court an answer with your signature notarized or verified or acounter-affidavit by the 20th day after you received this notice, the court can enter a final decree in the divorce. Acounter-affidavit, which you may file with the prothonotary of the court, is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the 20`'' day after you received this notice or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter- affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH FELOW TO FIND OUT WHETHER YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFROD STREET CARLISLE, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORETTA Y. ANDERSON V. COREY C. ANDERSON NO 10-885 CIVIL TERM DIVORCE DECREE a,,fi"o~: n op. M AND NOW, ~ aS ~~ D , it is ordered and decreed that LORETTA Y. ANDERSON plaintiff, and COREY C. ANDERSON ,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 ourt, ) Attest: ~• Pr thonotary