Loading...
HomeMy WebLinkAbout10-1092TERRI L. ADAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. l0 ?- CIVIL TERM N ? Ga . 1 BRYANT K. ADAMS, CIVIL ACTION - LAW Defendant IN DIVORCE SO NOTICE TO DEFEND FTI YOU HAVE BEEN SUED IN COURT. If you wish to defend again th&.elairr set forth in the following pages, you must take prompt action. You are warned That i0ou 1*il 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY SAIDIS, NWNWR & LINDSAY 26 West High Street Carlisle, PA Marylou Matas, Esquire Attorney Id. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ?k? ?btivy Al TERRI L. ADAMS, Plaintiff V. BRYANT K. ADAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. /v - 169d- CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Terri L. Adams, an adult individual currently residing at 155 Timer Lane, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The Defendant is Bryant K. Adams, an adult individual currently residing at 316 Holland Circle, Statesville, North Carolina 258677. 3. The Plaintiff has been a bona fide resident in 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 January 12, 2001 in Iredell, North Carolina. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. SAMIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 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 entry of a divorce decree in her favor in accordance with §3301 (c) or (d) of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, LINDSAY 26 West High Street Carlisle, PA Dated: /` z/ zU/ SAIDIS, FLOWER & LINDSAY r Maryl s, Esquir Attorney I ".919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff TERRI L. ADAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL TERM BRYANT K. ADAMS, CIVIL ACTION - LAW Defendant IN DIVORCE VERIFICATION 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. §4904, relating to unsworn falsifications to authorities. T RRI L. ADAM Date: SAIDIS, LENDS AY ATIO EYS-AT uw 26 West High Street Carlisle, PA ~~ SAIDIS, FIAWER ~ LINDSAY ~~.~:~,W 26 West High Street Carlisle, PA TERRI L. ADAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLV~IIAr.,, . c- _~ c~ ~_, r7 v, NO. 2010-1092 CIVIL TEFL:" ~ ,y : °' ;-''~ BRYANT K. ADAMS, CIVIL ACTION -LAW ;~ -~'''~ ~ ~ Defendant IN DIVORCE _~~, {-, _. _._ -; _; c AFFIDAVIT OF SERVICE ~ ~> ~~ ac: -~ I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on February 16, 2010 she served a true and correct copy of a Divorce Complaint upon Bryant K. Adams, by mailing those documents to the his address at 316 Holland Circle, Statesville, North Carolina 28677, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Bryant K. Adams. Dated: ~- f ~ ~1 ~ 7ll G Respectfully submitted, SAIDIS, FLOWER 8~ LINDSAY Ma a s, squire ID No. 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff TERRI L. ADAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2010-1092 CIVIL TERM BRYANT K. ADAMS, CIVIL ACTION -LAW Defendant IN DIVORCE ~ • • ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so th we can return the cans to you. ^ Attac~this card to the back of the mailpiece, or on he front if space permits. 1. ArticlesAddressed to: 3~co ~{a if aln~, G~~~ ^ Agent ~( ^ Addre B. Rece ed (Printed Name), C. a~~Dell D. Is delivery address different from item 11 ^ Y If YES, enter delivery address below: ~'No ~`^-~S V ~ l jt;j I ! V. ~ 3 Service Type il ~~ ~ ~ ~} . r ~Certiffed Mail pegisterad ^ Express Ma ^ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Exha Fee) Yes 2. Article Number 7p09 2250 002 8246 3316 (Transfer from service iaben PS Form 3811, February 2004 Domestic Return Receipt 102595-o2-M-1540 TERRI L. ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 2010-1092 CIVIL TERM ~ ' ~ ~ o --nr BRYANT K. ADAMS, CIVIL ACTION -LAW ,.i~t ~_ -~-~..r. .- ~_ Defendant IN DIVORCE =' ' ' ~~ '~"` _~ ~- PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code waled~ebr 12, ~ ~~- 2010. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: ~;~~1d y ' ERRI L. ADAMS 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 FIAWERIS~6z L1NDSrAY 2G West High Street Cazlisle, PA 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 to the best of my knowledge, information and belief. 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: ~ I a'01 f~ ` l.lA~'L~ Q~t • ~~R~w~.~1 TERRI L. ADAMS TERRI L. ADAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2010-1092 CIVIL TERM n ~ ,w BRYANT K. ADAMS, CIVIL ACTION -LAW L Defendant IN DIVORCE r-~~--~~ ~=_ c_,., fW' ',..... ~ ~'! _ V DEFENDANT'S AFFIDAVIT OF CONSENT { •- ~: ~ ~- , -. 1. A Complaint in Divorce under § 3301(c) of the Divorce Code vYaiiled~bni~ry"~12, 2010. -~ -- 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalti-e7sof L18 Pa.C.S. 4904 relating to unswom falsification to authorities. Date: `~ I6~ ~0 ~~ NT . AD S 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 SAII~IS, FIAWER ~ LINDSAY 26 West High Street Cazlisle, PA 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. 7 j6"~0(D Date: R ANT K. ADAMS IN THE COURT OF COMMON PLEAS OF TERRI L. ADAMS ;CUMBERLAND COUNTY, PENNSYLVANIA V. BRYANT K. ADAMS NO. 2010-1092 DIVORCE DECREE AND NOW, Z~ 1 Z~ , it is ordered and decreed that TERRI L. ADAMS ,plaintiff, and BRYANT K. ADAMS ,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, 7.2~ . } p /t~c~-4;c.s~. cY1c~, tea -t-a S~e,~+•