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HomeMy WebLinkAbout10-1829HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF ANGELA M. BECK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. JONATHAN M. BECK, Defendant CIVIL ACTIO - W :NO. 2010 - 1 F.2 'I CIVIL TERM : IN DIVORCE NOTICE 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 in 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, 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 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 n 32 South Bedford Street <? a Carlisle, Pennsylvania 17013 . „=n 717-249-3166 r ` - N C.3 r Fri `; y W dl $`447.5 ?R-W i? P d?xm a?73O ? Rce- .# a3 T ANGELA M. BECK, VP : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. BECK, Defendant CIVIL ACTION - LAW NO, 7006 - l 4r..-9 CIVIL TERM _ a,Dlp IN DIVORCE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint against the defendant, representing as follows: COUNT I - COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE The plaintiff is ANGELA M. BECK, an adult individual residing at 400 7T" Street, Apartment 2, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The defendant is JONATHAN M. BECK, an adult individual residing at 107A North East Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on November 5, 2005, in Mechanicsburg, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that she has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. COUNT II - CUSTODY 7. The averments of plaintiff's complaint, paragraphs one through six above, are incorporated herein by reference. 8. The parties are the natural parents of a minor child, EMILY RAYNE BECK (born September 25, 2004). 9. The child resided with both parties from the date of her birth until the parties' separation in May, 2009. The child now primarily resides with her mother, the plaintiff herein. 10. Neither party has participated as a party, witness, or in any other capacity in any other litigation concerning the custody of the child in this or another court. 11. The plaintiff has no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 12. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 13. The plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that the parties have joint legal, that the plaintiff retain primary physical custody of the child, and that the defendant have partial physical custody of the child in accordance with such schedule as may be agreed upon at the custody conciliation to be held hereon. WHEREFORE, the plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. Ay NGE M. BECK, Plaintiff HAROLD S. IRWI Attorney for Plah Supreme Court ID No. 29920 U 4 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 ANGELA M. BECK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2t>6 CIVIL TERM JONATHAN M. BECKO Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that l 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. I verify that the statements made in this affidavit are true and correct. 1 understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ANGELA M. BECK, Plaintiff . ANGELA M. BECK, v. IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN M. BECK, Defendant CIVIL ACTION -LAW NO. 2010 - 01829 CIVIL TERM IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about March 12, 2010. Service of the complaint was made upon the defendant on or about March 31, 2010 (see acceptance of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the 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 divorce. July ~ , 2010 NGE M. BECK WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $ECTION SSO1(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 !will not be divarced 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. Section 4904 relating to unsworn falsification to authorities. Ju , 20~ .. :-- ~ ANGE M. BECK ,.~. , ~_. - c~ -T, _.. .'_. -- r~ ~ -~ u~ c:, t ''s ~!-! s - C:L t ~_ o C`NI U 20IQ JUL 13 f 1'~ ~+~ U~ ANGELA M. BECK, Plaintiff IN THg~~J;EtT„O~;CS~I~I~AN PLEAS OF CUMBERI~Ii~E~'Y, PENNSYLVANIA v. JONATHAN M. BECK, ' Defendant CIVIL ACTION -LAW NO. 2010 - 01829 CIVIL TERM IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about March 12, 2010. Service of the complaint was made upon the defendant on or about March 31, 2010 (see acceptance of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the 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 divorce. July ~, 2010 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. Section 4904 relating to unsworn falsification to authorities. July ~, 2010 J HAN M. BECK ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE ANGELA M. BECK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. JONATHAN M. BECK, Defendant To the Prothonotary: CIVIL ACTION -LAW NO. 2010 - 07829 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about April 2, 2010, defendant was served with a copy of the divorce complaint (see Acceptance of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: July 1, 2010 By the defendant: July 8, 2010 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 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: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: July 13, 2010 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 13, 2010 6. There has been no prior action for divorce or annulment between the parties other than this action which commenced on March 12, 2010. July 13, 2010 HAROLD S. Attorney for n 's7 i'~'~ tT3~` ~.. i~~, i ,,,. , _ _ '~ > `- LT ..:., i._ ~^ ^~'~ •~ N n d C.-- C f ~.A~ ~~ ~' :./ -t1 -~i j'~1 T ,~, ~,, . ... ~v,: "} P: _, ~''. ' •. R JUL 14 2010 HAROLD 8. IRWIN, III, ESQ. ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17015 (717) 245-6090 ATTORNEY FOR PLAINTIFF ANGELA M. BECK, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2010 -1829 CIVIL TERM JONATHAN M. BECK, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of July, 2010, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. l~ ~ ~o ~d s ~rw ~ ~ ~ ~~ / ~oKa~a ~ ~ • ~3eck_ • r~~; cs w~,~lCd 7~jyio ~c n ~ ,~ .... ~~. ~ ;..; _, ~a .~ ~ ! r - ~ i;"i \ S- -: r't -'- ~" - ~'~ ~:, ~: . _ .~ --~ -~ s v- BY THE COURT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANGELA M. BECK V. JONATHAN M. BECK DIVORCE DECREE AND NOW, _ 2z Zo ~o , it is ordered and decreed that ANGELA M. BECK ,plaintiff, and JONATHAN M. BECK ,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 NO. 2010 - 1829 _ . By the Court, o, Prothonotary 7 ~ -iv ~ ~~,~ ~-