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Home My WebLink About04-2641 CHARLES J. MALONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. PAMELA S. MALONE, Defendant {JI/-;:J/P 1/1 : NO. CNIL : IN DNORCE NOTTrF TO DFFFNn ANn rT .ATM RTGHTS 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. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 S. Bedford Street Carlisle, Pennsylvania (717) 249-3166 ~~/;(J.Jf1~ ~.._~ An~~ii~ca, Esquire ~:-r-r 113 Front Street P.O. Box 358 Boiling Springs, P A 17007 CHARLES J. MALONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL Y ANIA YS. : Dq~ ,;.(.1/, : NO. CIVIL : IN DIVORCE PAMELA S. MALONE, Defendant COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is Charles 1. Malone, who currently resides at 27 Ridge Avenue, Enola, Cumberland County, Pennsylvania, since August, 1984. 2. Defendant is Pamela S. Malone, who currently resides at 317 College Hill Road, Enola, Cumberland County, Pennsylvania, since April, 2004. 3. Plaintiff and/or Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 2, 1978 at Enola, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties except None.. 6. The marriage 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. Plaintiff requests the court to enter a decree of divorce. I 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. 9 4904, relating to unsworn falsification to authorities. ~r;t. ~!&- Charles J. ~Ione, Plaintiff Date: I~e'~ ,,<!t!Jo Y 4-'!~Ai ~/tVe ~~AL Antliony L. DeM Esquire Attorney for Plaintiff 113 Front Street P.O. Box 358 Boiling Springs, P A 17007 (717) 258-6844 ~ .....,_ 0' n ,...> ''''' 0 c: ,= -n , "- '-- .C" ~ ':~ v... '- --i \'\; ~ j'~ l c:.: I::<:J V' :1:,': n1,..__ , ~ :v. rn " V\ >:>0 ~. ~ v' 0' ,,- ~ ::;j (~? ( -~ '\ ':.~~ ~; ~. " '\ ,- \., ~ ;--..-; ~,") 1'i '\ .. , ~ ~ "'- ". - -, c, .'- -< '-<'\ "-) -< " '.j ~ ~ CHARLES J. MALONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. PAMELA S. MALONE, Defendant : NO. 04-2641 CIVIL TERM AFFmA VIT OF MATT TNG COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND Anthony L. DeLuca, attorney for Plaintiff, being duly sworn according to law, says that he mailed by certified mail, retum receipt requested, a true and correct copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code to the Deflmdant at 317 College Hill Road, Enola, Pennsylvania and that Defendant did receive same, as evidenced by the signed receipt attached hereto as Exhibit "A". By: a~ Anthony L. uca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, P A 17007 (717) 258-6844 (~ Sworn to and subsc.9bed before me this .;2.7Vl:tay of June, 2005. ~~/~/ ~) JJ-e-/~~ Public NCI":MnI.IIM ....~ADB.UeA Nalary NlIc "'MIlIUlCNMIICU\";'" NC)CCll.NI' "" eo.... . . 1__ Nw 4. 2007 . ~1teme1,2.elld3.AltoCo"_' ijem 4 ff Restrlcled Delivery 10 dooirod. . Print your nomo and odd.... on tho __ so that we con rotum tho cord to you. . Attach thlo card to tho beck of the moilpl_, or.on tho front ff spaco permllo. 1. Article ,.necl to: f:>/lfda S. I1.a /0 Ale ,,5 (7 Ca 1(...(;'(' 1/,(/ /('tI.>..1 e-1V,,(a( f,fj. !'1o~r 2. Article Number (Copy from service Jsbe1) '7t1(1'f oS- <0 tf)"-1' PS Fonn3811. July 1999 (') c: ~TJi~ '1-~ f' ". .:-;..," ~:~} '-" ,~ ..'''~ ..-' i-t;:;:: 7 ~ 3._~ ~CertitIed Mall 0 Expross Moll o Reglstorod 0 Rstum ~ fer Merchandise o ~nountd Mall 0 C.O.O. 4. Restrfcted Delivery? (Cxtta Fee) Yes 03fr '" YS.2 0c>m0Ilic -.", RocIipI 12)( f+(i5,J 1;Jt- (, 102586-00-M.()952 . ~ 1'" c.:> ....., = ~ '- c: < !of: -I :r:." rnj:1 iJ'fj", :~JO i~:t~ (jni ,-I ~ N ....., -,.., :J: "li' 'J\l~r~:'lt-! '" ')t,1 IJ-G ~ ~l AAM li~'~: ~c .'If",hll'i ~-:~U' \i.ItIO.i"'~i;,' ,~\,4,it ~1C_.J1..iClC.lHtfItI()l p .--,J~. .'~Iflpa .1(It~drl'lm;)':' "M CHARES J. MALONE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. PAMELA S. MALONE, Defendant : NO. 04-2641 Civil : IN DIVORCE A FFIDA VIT OF rONSFNT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 11,2004. 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 of 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: (p-2J-OJ L "4 -:z l:? I"\) w "'> = !;,''::' c.n '- c~: ...,~ ~ ~ '.jlf] f.:::: -'')-1" : JC'::' ..'.=l~: ~,j ~;i ':a "', I"\) "" 3' CHARLES J. MALONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL Y ANIA YS. PAMELA S. MALONE, Defendant : NO. 04-2641 Civil : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 9 3301(c) AND 9 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in 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. 9 4904 relating to unsworn falsification to authorities. Date: & -.23 - () j- rii?//"k ~ 7Jkfk..~ ~alone, Plaintiff r-O c::? ,,",' 01 <- C.:.. Z N o 11 ::;j ..,..<--,.-, rnf::::: -nO] ::~.\i) ~_!~:!;: C",( ) ',,:)rn .-. -~ :s; ;....:::: --J c..) 1') "'" - CHARES J. MALONE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. PAMELA S. MALONE, Defendant : NO. 04-2641 Civil : IN DNORCE AFFIDAVIT OF rONSFNT i. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June II, 2004. 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 of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true anrlcorre<;t. I unde~tand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: ~ q! J.OO~ ~d/)?~ Pamela S. Malone, Defendant ....' 5 GJ' (- c:: ~~ N -' q, ..... ~""'" f1\"f";' :jYo ."') \ '~~~), (':Ji;~ ';:~-~ '~-;1 :% -n - ";",... <...."'? N (...,J; CHARLES J. MALONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL Y ANIA YS. PAMELA S. MALONE, Defendant : NO. 04-2641 Civil : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 3301(c) AND ~ 3301ld) OF THE DIVORCE CODE I. 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 in 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. S 4904 relating to unsworn falsification to authorities. Date: 5" -;;)3-0S- ~~ J f7Z~ Pame18 S. Makme, Defendant o ,:; :=~- r-' = ('".;::> cJ' <..., c~ ;;C rv ...J '~.:, '~:1 -<. -v ~:: o "'n :?-c rne, ""'aw-1 ~r.J ...\.... r;?\I;~ --,--. .' .._41 ~:;-c~ ('~?l ,)1 ':;~\ ";'''' :::~ .~ '..:? N '-'" CHARLES J. MALONE, Plaintiff : : : VS. : PAMELA S. MALONE, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 04-2641 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record. together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S3301(c) ~ of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mail restricted delivery on June 16, 2004 3. Complete either paragraph (a) or (bl. (al Date of execution of the affidavit of consent required by S3301(cl of the Divorce Code: by plaintiff 6/23/05 by defendant 6/9/05 (b)(ll Date of execution of the affi,davit required by S3301(d) of the Divorce Code: ; (2) Oatc of filing and service of the plaintiff's affidavit upon the r~spondent: 4. Related claims pending: None 5. Complete either (a) or (bl. (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 plaintiff's Waiver of NotiCE! in S330l(cl Divorce was filed with the Prothonotary: June 27, 2005 Date defendant's Waiver of NotiCE! in S330l( c I Divorce was filed with the Prothonotary: June 27, 2005 C1~ 4bJ!:f~l.."3' Attorney f. (Plaintiff)*~~~~~~*t r-' = C..:;) c,)"\ l'-' --' ,~ "-iT ~.-l -~: o -n -1 :T--n rne. -,'1\ \' ")IC ;?lr!) d_'.'-' ':;t:~:)i .~~ (2 l'-' (,,) . . . . . . . . . . . . . . . . . . . . . . . . . "''''',1:'''; .. . .. . . . ;f,'f. :+;f.,.,,., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. STATE OF CHARLES J. MALONE, Plaintiff VERSUS PAMELA S. MALONE.! Defendant AND NOW, No. 04-2641 Civil DECREE IN DIVORCE J//.' -"A.P1 . r ~t' 2005 , iT IS ORDERED AND DECREED THAT Charles J. Malone , PLAINTIFF, AND Pamela S. Malone , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FiNAL ORDER HAS NOT YET BEEN ENTERED; . None . . . . . . PROTHONOTARY ""Of. 'f."" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . '~:P ~ ~ so.k-/! ~~?(f P 1-- ~ ~ -rrJ Jr:l-k'~