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HomeMy WebLinkAbout01-0741 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff KARLA D. ARMOLT, Defendant CIVIL ACTION - LAW NO. 2001- 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 armulment 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 ofmanSage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. 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 of counseling sessions are to be borne by you and your spouse, lfyou 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. IF YOU DO NOT FILE A CLA/M FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff KARLA D. ARMOLT, Defendant CIVIL ACTION - LAW NO. 2001- IN DIVORCE CAPTION COMPLAINT IN DIVORCE AND NOW, this ~ 1 3&day of j~q ,.~ ,- ~ , 2001 comes Plaintiff, JEREMY Q. ARMOLT, by and through His attorneys, the Law Office of Michael J. Hanft, and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiffis Jeremy Q. Armolt, who currently resides at 87 Pond Road, Newville, Cumberland County, Pennsylvania 17241, since 1997. 2. The Defendant is Karla D. Annolt, who currently resides at 709 Mount Rock Road, Carlisle, Cumberland County, Pennsylvania 17013, since January 17, 2001, with mailing address at 87 Pond Road, Newville, PA 17241. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months irmnediatelypreceding the filing of this Complaint in Divorce. Peimsylvania. 5. 6. The parties were married on September 20, 1997 in Cumberland County, There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. The foregoing facts are averred and brought under Sections 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 7. The Plaintiff has been advised of the availability of counseling, and that the 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. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Attorney 1D No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint in Divorce and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. .< 0 >. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff KARLA D. ARMOLT, Defendant CIVIL ACTION - LAW NO. 2001-741 IN DWORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS Terry E. Walker, being duly sworn according to law, deposes and says that she mailed the Complaint in Divorce in this matter by certified mail, return receipt requested, addressee only, to the Defendant, Karla D. Armolt, 709 Mount Rock Road, Carlisle, PA 17013 on February 7, 2001. The return receipt signed by the Defendant is evidence of service and is attached hereto as Exhibit "A". Terry E. Walker 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Sworn to and subscribed before me this oQ('/)'//~ day of '~U2J~ 2001. Notary Public Notarial Seal Denise L. Nye, Notary Public South Middleton Twp., Cumberland CountyI My Corem ss on Exp res Feb. 26, 2005 I Memi0er, Pennsylvania Asscciation et Notaries 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff KARLA D. ARMOLT, Defendant C1VIL ACTION - LAW NO. 2001-741 IN DIVORCE · Complete items 1, 2, and 3. Also complete A~ P~ecelved by (P/ease Print Clearly) B. Date of Delivery item 4 if Res~i~ 'cted Delivery is desired. · Print your name and address oh the reveme so that we can return the card to you. C. Signat . ~ 0,~-~ t~.~ j~ a ~,~-~ ' I--I Agant ·~ thethis front cardif tOspacethe baCk~rmits.Of the mailpiece, -- 1. ~ Addre~ to: D. ~ d~v~ add~ d~nt ~ ~ 1 ? D Yes If YES, ent~ delive~ addr~ ~low: 170t~ ~ifi~ Mail ~ R~iste~ ~ Return R~eipt for Memha~ise ~ Insured Mail ~ C.O.D. 4. R~tHct~ Deliver? PS Form 3811, July 1999 Domestic Return R~' ~' 102595-00-M-0952 · LAW 'OFFICE OE MI(TI tAEL J. HANFT , . fl ATTORNEYS & C()/JN5[I IOJkS A-I LAW "-~ 19 BROOKWOOD AV£NUI Stoslr IO(5 CAP, lISlE, PA 17OI3-9142 717.2't-9.5373 ~^X 717.249.0457 WWWHAN/[:TIAWFIRM.C?OM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff KARLA D. ARMOLT, Defendant CIVIL ACTION - LAW NO. 2001-741 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 6, 2001. 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., Section 4904 relating to unsworn falsification to authorities. Date:(/ ~ · LAW OFFICE Of /%II(DtAEL J. HANFT . ~ AT]-ORNEYS & C¢)~ INSII LC)RS AT LAW 19 BROOKWOOD AVENUE St,'l/r I()(~ CARIISII, PA 17013-9142 717.249.5373 FAX 717.249.0457 k,VWkV. IIANF/IAkVFIRM (X)M IN THE COURT OF COMMON PLEAS Ol~' CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff V. KARLA D. ARMOLT, Defendant CIVIL ACTION - LAW NO. 2001-741 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST 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 ifI 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. ~4904 relating to unswom falsification to authorities. ~.~Armolt, Plaintiff LAW OFFICE Of: /%/IC! tAEL J. HANFT ATTC~RNEYS & (~'O~ JNSFL[()RS AT LAyV BROOKYVOOD AVENUE SU]]I 106 CARlISlE, PA 17013 9142 717.249.5373 FAX 7]7.249(}, 57 %%'WW. IIAIMFTIA'~¥1II~M.{C)M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff }CARLA D. ARMOLT, Defendant CIVIL ACTION - LAW NO. 2001-741 1N DIVORCE AFFIDAVIT OF CONSENT 1. A Complahxt in divome under Section 3301(c) of the Divorce Code was filed on February 6, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the (Jomplaint. 3. I consent to the entry of a final decree ofdivome 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., Section 4904 relating to unswom falsification to authorities. K~ D. Armolt, Defendant I~AW OFFICE Of: /X,~ICt4AEL ]. HANFTo .~._,---- "-----~ ATTORNEYS & (~O INSEIL()IKS AT LAW 19 BIkOOKWOOD AVENUi SUITI lOG CARLISLE, PA 17013 9142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff KARLA D. ARMOLT, Defendant CIVIL ACTION - LAW NO. 2001-741 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE D,ECRE, E UNDER §330!(C~ OF THE DIVORCE CODE 1. ! consent ,~o the entry ora final decree of divorce without notice. 2. I undcrstm~d that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if/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. §4904 relating to unsworn falsification to authorities. aria D. Armolt, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMY Q. ARMOLT, Plaintiff V. KARLA D. ARMOLT, Defendant CIVIL ACTION - LAW IN DIVORCE NO. 2001-741 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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: February 13,2001, by certified mail, restricted delivery, remm receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff-July 30, 2001 (filed August 3, 2001); by the Defendant-July 30, 2001 (filed August 3, 2001). 4. Related claims pending: No claims raised. ©0 r~ ~o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~ O. ARMOLT~ Plain~ ff VERSUS De fe.n~]~nt N O. 2001-741 AND NOW, DECREE IN DIVORCE , 2001 , IT IS ORDERED AND DECREED THAT ~ O. ARMOLT PLAINTIFF, AND F~,.RLA D. AP. MOLT , DEFENDANT, ARE D~VORCED 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; ATTEST: PROTHONOTARY