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HomeMy WebLinkAbout10-10004 Vicki L. Mowers, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Paul L. Mowers, NO. d - 1000.> Defendant 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 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, Pennsylvania 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE Y 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 S. BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 F t" ti x ? o? z _04 Vicki L. Mowers, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW c ?+?%?i't Paul L. Mowers, NO. M - 1660 Defendant . IN DIVORCE COMPLAINT AND NOW COMES the above-named Plaintiff, by her attorney, Susan J. Hartman, Esquire, and makes the following Complaint in Divorce: 1. Plaintiff, Vicki L. Mowers, is an adult individual currently residing at 179 Big Spring Terrace, Newville, Cumberland County, Pennsylvania.. 2. Defendant, Paul L. Mowers, is an adult individual currently residing at 2 Stine Drive, Carlisle, Cumberland County, Pennsylvania. 3. Both Plaintiff and Defendant have been bona fide residents in 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 May 6, 1979 at Carlisle, Cumberland County, Pennsylvania.. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers, in accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7. Plaintiff has been advised that counseling, is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Defendant herein is not a member of the armed forces of the United States of America. WHEREFORE, Plaintiff prays this Honorable Court enter a decree dissolving the marriage between the parties. Respectfully Submitted, Susan J. H squire Attorney for Pla' tiff Duncan & Hartman, P.C. 1 Irvine Row Carlisle, PA 17013 (717)249-7780 Attorney ID 65184 VERIFICATION The undersigned, having read the attached Complaint, hereby verifies that the facts set forth therein are true and correct to the best of his knowledge, information and belief. This verification is made subject to the penalties of 18 Pa.C.S.section 4904 pertaining to unsworn falsification to authorities. Vicki L. Mowers Dated: Vicki L. Mowers, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Paul L. Mowers, NO. 1D- loo0 (2 ivil -Tvp C7 Defendant _? IN DIVORCE w r AFFIDAVIT ?m Vicki L. Mowers, Plaintiff, being duly sworn according to law, deposes and says- .? .rte 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I (RGJ/DO NOT) request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 4. I realize that if the divorce is brought under section 3301(c) of the Divorce Code, then counseling must be completed within ninety days after the filing of the complaint. If the divorce is brought under section 3301(d) of the Divorce Code, then counseling must be completed within one hundred and twenty days after the filing of the complaint. 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?7C` ?/?Otvy3? Vicki L. Mowers Vicki L. Mowers, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW Paul L. Mowers, NO. lp _ 1Doo C'i v i TerM Defendant IN DIVORCE -Z n r_j NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: rim You have been named as the Defendant 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 3301(c) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree 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 the list. All necessary arrangements and the cost off counseling sessions are to be born by you and your spouse. If you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary Vicki L. Mowers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~• :CIVIL ACTION -LAW Paul L. Mowers, : NO. ~[~ j p - v / o v c"!. Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Susan J. Hartman, Esquire, being duly sworn according to law, do swear that I served a Complaint in Divorce on the Defendant, Paul L. Mowers, by hand delivering a true copy to the Defendant, Paul L. Mowers at the following address on ~~ ~o~ ~ ~-~ Susan J. Hart squire Sworn to and subscribed before me this /6~'~ day of c~: ~, -~- ___ otary Public -- - : _~__ COO)9M0!`iWEALTH OF PENNSYLVANIA ~'' NOTARIAL SEAL t. ` -~; JOAN D. ADAMS, Notary Public __ :~: Carlisle Boro., Cumberland County ~ ~ , My Commission Expires March 7, 2011 _'' `" _` ~,.. • t Vicki L. Mowers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~• :CIVIL ACTION -LAW Paul L. Mowers, NO, ~ ~ ~ o - a ~ c, ~ ~~ Defendant , IN DIVORCE Acceptance of Service I, Paul L. Mowers, being duly sworn according to law, do swear that I was served a certified copy of a Complaint in Divorce by hand delivery from Susan J. Hartman, Esq. at 1 Irvine Row, Carlisle, on February /~~ ,2010. -~~,~- Paul L. Mowers Sworn to and subscribed before me this ~ day of otary Public CUMWPUMWEALTH OF PEhSi~lSYLVAtdiA NOTARIAL SEAL JOAN D. ADAMS, Notary Public Carlisle Bore., CumberSand Ccunty M Commission Expires March 7, 2011 ,`, .Y~.__..._____..__.~.__._.----- ~-~ --f ~-- ,7 - -,: __ , , ~5 Vicki L. Mowers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW Paul L. Mowers, NO. ~ v ~ a ~- a i o c> ~~ Defendant . IN DIVORCE AFFIDAVIT Vicki L. Mowers, Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I (~1/DO NOT) request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 4. I realize that if the divorce is brought under section 3301(c) of the Divorce Code, then counseling must be completed within ninety days after the filing of the complaint. If the divorce is brought under section 3301(d) of the Divorce Code, then counseling must be completed within one hundred and twenty days after the filing of the complaint. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.4904 relating to unsworn falsification to authorities. ~~L~~'`~ Vicki L. Mowers ~ ~::~ r` _ .._ `_~ ..o -~_ ,l: - _ - : it ~ ~, ~.. ,i_ Vicki L. Mowers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW Paul L. Mowers, NO. ,,~~ lip --~ i vt~t~ Civil Term Defendant IN DIVORCE 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. sec. 49904 relating to unsworn falsification to authorities. Date: 5 ~ Vicki L. Mowers n ,_ ^' ~-. a r= ~ ' , ~: s,.- L fi . r.,, ",,,; t. Vicki L. Mowers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW Paul L. Mowers, NO. aG, ~~, ~ n i c> c~ ~% Defendant IN DIVORCE 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. sec. 49904 relating to unsworn falsification to authorities. Date: q 0 Paul L. Mowers n ~- ~~ :. .~' ;:': _,, - ,~.: .. . ~ . . Ij' , F _,,.:. ~.. {" - Y\ J. nF~ ~ ~!' Vicki L. Mowers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW Paul L. Mowers, NO. ;~vf v -c~ t c~~7 ~~ CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 c) of the Divorce Code was filed on ~- _~f . ~ b c,.~o,.< , "~ F ao i D 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. sec. 49904 relating to unsworn falsification to authorities. Date: .~ ~ ~ -p ,~,/ ~~,, ~~ Paul L. Mowers ~-, .-:a .~.. _, -~: c,, ra •~ _ r~. ~ ~ Vicki L. Mowers, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW Paul L. Mowers, NO. o~ U / ~ -- G ~ ~~ ~ Defendant IN DIVORCE C) ~.~ AFFIDAVIT OF CONSENT ._ ., : _ _. ~:=. 1. A complaint in divorce under Section 3301(C) of the Divorce Co~e•was flied on~ ;,._ - , s' 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. I consent to the entry of a final decree of divorce. 4. 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. sec. 49904 relating to unsworn falsification to authorities. Date: 5 ~ 19~ r c~ ~~ C~'~ ' ~/~l d~h~~ Vicki L. Mowers Vicki L. Mowers, IIV THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CML DMSION Paul L. Mowers, Defendant NO. 2010-01000 CIVIL TERM PRAECIPE TO TRANSMIT RECORD ~_-' `~_' - ~~ ~~~ -r To the Prothonotary: r ~ ' ~ _ _ ~~ ("f> Transmit the record, together with the following information to the court for entry of ~ilivorce decree: _c, -- - ~~ ~: ~. ~,, 1. Ground for divorce: ~_~ '" Irretrievable breakdown under 3301 (c) ~~ g$~~~}~of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: February 16, 2010 by personal service on the defendant 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c} of the Divorce code: by plaintiff 5 / 19 / 10 ; by defendant 5 / 19 / 10 b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. 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: b. Date of plaintiff s Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: 5 / 2 6 / 10 Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: 5 / 2 6 / 10 ,.--- Attorney fo lai iff/Deiaut,. _k -. ~~ _ ' -p- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VICKI L. MOWERS V. PAUL L. MOWERS NO 2010-01000 DIVORCE DECREE AND NOW, 7 ~ ~~ , it is ordered and decreed that VICKI L. MOWERS plaintiff, and PAUL L. MOWERS ,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 Attest: ~. ~~ Pr honotary !~•7•~o C„~.~. co~ mc~.~le~ Co•7• to K~oi c~ Ma.:lec~ -w .-~ g ~url CD~1 ~ d~-~ . s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VICKI L. MOWERS Plaintiff Vs File No. 201Q=0100Q IN DIVORCE PAUL L. MOWERS ~ c o ~_ Defendant -c, ~~ c_.. f~ __ ..~.~ ~/.~, W _T, ~ ~ ~" __,k ~f.~ NOTICE TO RESUME PRIOR SURNAME ~ t ` ~. ~, ~ ~. -~' 4 . ,-~ i he b i iff/ d f d ~ n~ . ove matter, n t a nt e en ant Notice is hereby given that the Pla [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or x after the entry of a Final Decree in Divorce dated June 7, 201 hereby elects to resume the prior surname of rlcNaugnton ,and gives this written notice avowing his /her intention pursuant to the provisions of 54 P.S. 704. Date: June 9, 2010 ~~~ ~~~~~~ Signature ~~ ~~ ~ ,~. ~ s So s a'`l ~ ~1 Signature of name eing resumed COMMONWEALTH OF PENNSYLVANIA } COUNTY OF ~-^-6crla,~~ On the ~ day of _ ,~_ , 20~ 4, before me, the Prothonotary or the notary public, personally appeazed the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he /she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. /~ ~ ~ ~ a P/R~ Notary Public ' r//. ~~r~ M1 Met.a~ io ti~i1 purl «r a