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HomeMy WebLinkAbout10-1565 Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SCOTT W. HARVEY, Plaintiff V. GINA MARIE HARVEY, IN DIVORCE Defendant 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 9 35?. 6.6 'P.(Ijqy -Yg 3y// R ? ?.3 83?? Attorneys for Plaintiff z - _ C ?'rr? fib. Cn IN THE COURT OF COM N kEA§i rn CUMBERLAND COUNTY, P NE LV IA NO. Jd - / 6't05- CIVIL TERM CIVIL ACTION - LAW Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SCOTT W. HARVEY, Plaintiff V. Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. I D - /S6 S CIVIL TERM CIVIL ACTION - LAW GINA MARIE HARVEY, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, SCOTT W. HARVEY by and through his attorneys, Johnson, Duffie, Stewart. & Weidner, and files the following Divorce Complaint against the Defendant, GINA MARIE HARVEY: 1. The Plaintiff is Scott W. Harvey, an adult individual, residing at 6342 N. Powder Horn Road, Mechancisburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Gina Marie Harvey, an adult individual, residing at 134 Robin Lane, Apartment 6, Hummelstown, Dauphin County, Pennsylvania 17036. 3. The Plaintiff and Defendant were married on December 18, 2009, in Hampden Township, Mechanicsburg, Cumberland County, Pennsylvania. 4. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The parties separated on or about February 7, 2010. 7. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of marriage counseling and he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a Decree of Divorce. JOHNSQM DURFIE, STEWART & WEIDNER Peel Greevy VERIFICATION I, SCOTT W. HARVEY, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Dat\J / m V SCOTT W. HARVEY :394266 Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SCOTT W. HARVEY, Plaintiff V. GINA MARIE HARVEY, Defendant AFFIDAVIT CIVIL ACTION - LAW IN DIVORCE I, SCOTT W. HARVEY, being duly sworn according to law, deposes and says: 1. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I 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. 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. Date: Oz?zlzola SCOTT W. HARVEY :394266 n Attorneys for Plaintiff Q a n y_ c : c?a D) IN THE COURT OF COMM.3N PIEAS??" CUMBERLAND COUNTY, PE*S I VAW Cn -< NO. )6-15'6!r CIVIL TERM Johnson, Duffie, Stewart 8~ Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SCOTT W. HARVEY, Plaintiff v. GINA MARIE HARVEY, Defendant RETURN OF SERVICE CIVIL ACTION -LAW IN DIVORCE AND NOW, this 15th day of March, 2010, the undersigned does hereby certify that on March 10th, 2010, the Divorce Complaint filed March 5th, 2010 in the above captioned action was served upon on Defendant, GINA MARIE HARVEY, via certified mail return receipt requested, restricted delivery, addressed to 134 Robin Lane, Apt. 6, Hummelstown, Pennsylvania 17036, the Return Receipt evidencing service upon Defendant is attached hereto as Exhibit A. JOHNSO OF , STEWART & WEIDNER B Melissa Peel Greevy I.D. No. 77950 Johnson, Duffie, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Plaintiff Attorneys for Plaintiff r~ ?' v _ - ~, -rt ~ i ~ -~~ .-, ~ "~ T -r ~ '",~ R, 4 __ ~i~ r^1~ ~~ , f ~ '-~~ ...' ~ ~ti IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-1565 CIVIL TERM USPS -Track & Confirm .~ Page 1 of 1 unrrr~o srarEs PC)STx1L SERVKE+a Hams I H.glp I $~n_In __ _ ___ _ Track 8 Confirm FAQs Track & Con#irm Search Results LabellReceipt Number: 7007 2680 0001 8067 9283 - Class: First-Class Mail® ' Tr+ck & Confirm _ Service(s): Certified Mails" Enter LabellReceipt Number. Restricted Delivery ', Return Receipt Status: Delivered Go ~ ; l ~i Your item was delivered at 1:03 PM on March 10, 2010 in ~__ ___ __ _ - _ __ _ HUMMELSTOWN, PA 17036. ~~ ~ ~ ~~ Detailed Results: • Delivered, March 10, 2010, 1:03 pm, HUMMELSTOWN, PA 17036 • Arrival at Unit, March 10, 2010, 6:13 am, HUMMELSTOWN, PA 17036 Acceptance, March 09, 2010, 8:37 am, LEMOYNE, PA 17043 Mot~ftcaitaon ©ptions Track & Confirm by email Get current event information or updates for your item sent to you or others by email Ga ? Site Map ~;ustpmer Seryj~~, Fprms Gov't.Services (;afe¢rS Privagy Policy Terrng of Ilse ^ Complete items 1, 2, and 3. Also complete kem 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ~3~ ~~~h ~~e, . ~v ~~ by Bugness (:nSMmar r~aleway r ~-,'~ aR a~ x~ .~ ^ Addressee C. Date of Delivery D. Is delivery address different from item 17 ^ Yes If YES, enter delivery address below: ^ N m,~s`~ ~ ~ ~~ 3. Service Type Certified Mail ^ Express Mail ~] Registered ^ Retum Receipt for Merchandise i~D3~ ^ Insured Ma(I ^ C.O.D. 4. Restricted Delivery? t7=xtra Fee) y~ ` 2. Article Number (transfer from service label _. 7 0 D 7 _ ~_6 8 D _ -` ~~ ~~ . 9 2 8 3 PS Form 3811, February 2004 Domestic Return Receipt tao http://trkcnfrm 1. smi.usps.com/PTSInternetWeb/InterLabelInquiry.do 3/ 15/2010 J CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that I served a true and correct copy of the foregoing Return of Service upon all parties or counsel of record by depositing a copy of same in the,Ulnited States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the ~ ~~ of March, 2010, addressed to the following: Gina Marie Harvey 134 Robin Lane, Apt. 6 Hummelstown, PA 17036 JOHNSON UFFIE, STEWART & WEIDNER Y• elissa Peel Greevy :395129 IN THE COURT OF COMMON PLEAS OF SCOTT W. HARVEY :CUMBERLAND COUNTY, PENNSYLVANIA V. GINA MARIE HARVEY NO. 2010 -1565 CIVIL TERM DIVORCE DECREE AND NOW, ~ ~n/y it is ordered and decreed that SCOTT W. HARVEY, plaintiff, and GINA MARIE HARVEY defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendent elite 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 e Court: 405971 Attest: J. Prot otary 7 ~ r~l - l d ~- . cop ~ ~~ -'<~ ~-GU-vec~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW • v Plaintiff VS. %act Defendant . FILE NO. 10 0 -&5 ??..... ? -,fir ?... IN DIVORCE tlf z°g .7) NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the PlaintiffDDefendant in the above matter, having been granted a Final Decree in Divorce on the ?jam day of aVl 0 hereby elects to resume the prior surname of t h rA? (-?.yL , and gives this written notice pursuant to the prow' 'ons of 54 S. 704. DATE: ?1' II IL, Signature Signa of name being resumed COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND On the day of 20_// , before me, a Notary Public, personally appeared 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 and official seal. OF P NNSYLVMUA Il aflsl Sam Dank) James WrW x., Notary Public otary Public s*w sp*v jM*, h eAw Member, Pennsvlvanla Assodatloe of NoWles Pd. 9d W 1)44 JIM ??? ?? 3 3a / l?-r ?# a53i/ a