HomeMy WebLinkAbout10-3762
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(7M 241-4436
ATTORNEY FOR PLAINTIFF
2010 JUN -7 AM 11: 16
COPY !;-- IL I
ERIN L. McBRIDE,
V.
: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
HOWARD C. McBRIDE,
Defendant
: CIVIL ACTION - LAW
: NO. 2010 - 3 7&''- 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
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3,512
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NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L. McBRIDE,
Plaintiff
V.
HOWARD C. McBRIDE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. 2010 - CIVIL TERM
: IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTION 3301(C) OF THE DIVORCE CODE
NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing
as follows:
1. The plaintiff is ERIN L. McBRIDE, an adult individual residing at 15 Heather Drive, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The defendant is HOWARD C. McBRIDE, an adult individual residing at 118 Tower Circle,
Carlisle, Cumberland County, Pennsylvania 17013.
3. The plaintiff and defendant 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 July 23, 2003, in Carlisle, 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 said party
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
and for such further relief as this Honorable Court may deem equitable and just.
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. Section 4904, relating to unsworn
falsification to authorities.
c
]rINb 3 , 2010
E L. c DE, Plaintiff
WOLF & WOLF, Attorneys at Law
70N& 3 , 2010 BY:
1VA1 U. LF, ESQUIRE
Sup =igh rt ID #87380
10 a Street
Carlisle, Pennsylvania 170L3
(717) 241-4436
Attorney for Plaintiff
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L. McBRIDE,
Plaintiff
V.
HOWARD C. McBRIDE,
Defendant
4E
2010 JU! `7 ftf 11. i s
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2010 - -3 CIVIL TERM
: 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 I may
request that the court require that my spouse and I participate in counseling.
2. I 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. I understand that false
statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
2010
N L. CB DE, Plaintiff
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
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(717) 241-4436 d
ATTORNEY FOR PLAINTIFF JIN 1
PEL? '(L? NNA
ERIN L. McBRIDE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
HOWARD C. McBRIDE,
Defendant
: CIVIL ACTION - LAW
NO. 2010 - 3762 CIVIL TERM
: IN DIVORCE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint of Divorce in the above-referenced matter pursuant. Attached
is a copy of the Complaint of Divorce to reinstate.
Respectfully submitted,
WOLF & *0
F
September '%,2010 By:
N=re C. WOLF, ESQUIRE
Su Court ID #87380
10 West High Street
Carlisle, Pennsylvania 17013
(717) 241-4436
Attorney for Plaintiff
C)
4fo.oo PA A11Y
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E# 14 8aoo
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREE'T'
CARLISLE PA 17013
(717) 241-4436
AT'I ORNEY FOR PLAINTIFF
ERIN L. McBRIDE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
HOWARD C. McBRIDE, : NO. 2010 - _'/4,,! __CIVIL TERM
Defendant : 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. ?1 judgment
may also be entered against you for any other claim or relief requested in these papers by the plaintiff.
You mav_ lose money- or property or other rights important to you, including custody or visitation of jour
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 Count, 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
NATHAN C. WOLF, ESQUfRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L. McBRIDE,
Plaintiff
W.
HOWARD C. McBRIDE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2010 - _ _CIVIL TERM
: IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTION 3301(C) OF THE DIVORCE CODE.
NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing
as follows:
1. The plaintiff is ERIN L. McBRIDE, an adult individual residing at 15 Heather Drive, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The defendant is HOWARD C. McBRIDE, an adult individual residing at 118 Tower Circle,
Carlisle, Cumberland County, Pennsylvania 17013.
3. The plaintiff and defendant have heen residents of the Conlluonw•ealth of 11cnnsv lvania at least
sil months prior to the tiling of this action in divorce.
4. The parties were married on tiny 23, 2003, in Carlisle, PennSVlvalua.
5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grout ds upon which
this action) is based that the marriage between the parties is irretrievablh, broken.
(i. 1'h?c plaintiff a?rers that she has been advised of the ,I?-ailabilit? of counseling and that ,aid part?has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage bet?ieen the parties
and fo? - such further relief as this I Ionorabte Court tmw deem equitable and just.
I v erifv- that the statements made in this Complaint are true and correct. I understand that false
statements herein arc made subject to the penattics of IS Section 4904, rrlating to utwvorn
falsificatiwi to authorities.
-2010
E Lc #WIDE, Plaintiff
WOLF & WOLF, Attorneys at Law
- , 2010 BY:
NA C. OLF, ESQUIRE
Sup e Cetirt ID #87380
10 We igh Street
Carlisle, Pennsylvania 17013
(717) 241-4436
Attorney for Plaintiff
1
~,r
`'~r Frr_EO-oFFrc~
IIfi THE PPOTNONOTARY
NATHAN C. WOLF, EsQUIRE ~~ 10 OCI 15 PhP 4 ~ Q 5
ATTORNEY ID N0.87380
10 WEST HIGH STREET ~~~~~~~At~~~ C~U~T~`r
CARLISLE PA 17013 PE~~s Yr_VAPr~A
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L. McBRIDE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
HOWARD C. McBRIDE, : N0.2010-3762 CIVIL TERM
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO.1920.4 (al(11li~
NOW, Nathan C. Wolf, Esquire, being duly sworn according to law, does depose and state:
1. That he is a competent adult and attorney fox the plaintiff in the above captioned action
in divorce.
2. That a certified copy of the complaint in divorce was served upon the defendant on or
about October 12, 2010, by certified mail "restricted delivery," addressed to the defendant at 118 Tower
Circle, Carlisle, Pennsylvania 17013 return receipt No. 7004 1350 0003 7285 6902.
3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto.
I verify that the statements made in this affidavit 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 unsworn
falsification to authorities.
October 15, 2010
...
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,i ^ Complete items 1, 2, and 3. Also complete A. Signature
" item 4 ff Restricted Delivery is desired. ~ A9~
^ Print your name and address on the reverse X ~''~1'~' Addresse
so .that we can return the card to you. g, Rived by (Printed Name) C. of Deltve~
i ^ Attach this card to the back of the mailpiece,
or on the front ff space permits.. d w a ro9 C /~ ~ 13 ~ ~ ~, d ") , -. j
D. Is delivery address different from Item t? ~ Yes
1. Article Addressed to: H YES, enter delivery address below: ^ No
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i 4. Restricted Delivery? (Exba Fee) 'Yes
2. Article Number
~ (~ansne.iromseMce>~ 70Q.4 135D D003 7285 6902
`i PS Form 3811, February 2004. .Domestic Return Receipt toxsss-o2-M-tsa
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NATHAN C. WOLF,
ATTORNEYD NO. 87380 ESQUIRE C'
10 WEST HIGH STREET -
CARLISLE PA 17013
(717)241-4436 9t+a;;Lti'N U•ll s
ATTORNEY FOR PLAINTIFF k ?E NSSY LVA,
ERIN L. McBRIDE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
HOWARD C. McBRIDE, : NO. 2010 - 3762 CIVIL TERM
Defendant : 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
NATHAN C., WOLF, ESQUIRE
ATTORNEY! ID NO. 87380
10 WEST HI¢H STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEYFOR PLAINTIFF
ERIN L.' McBRIDE,
Plaintiff
V.
HOWARD C. McBRIDE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2010 - 3762 CIVIL TERM
: IN DIVORCE
AMENDED COMPLAINT IN DIVORCE PURSUANT TO
SECTION 3301 OF THE DIVORCE CODE
NOW, comes the plaintiff and files this complaint in divorce against the defendant,
representing as follows:
The plaintiff is Erin L. McBride, an adult individual with a mailing address of 15
Heather Drive, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Howard C. McBride, an adult individual residing at 3 Maple
Avenue, Carlisle, Cumberland County, Pennsylvania 17013.
The plaintiff and defendant 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 July 23, 2003, in Carlisle, Pennsylvania.
There have been no prior actions of divorce or for annulment between the parties.
The plaintiff avers that he has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
COUNT I
REQUEST FOR A NO-FAULT DIVORCE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
The averments of Paragraphs 1 through 6 hereof are incorporated herein by
reference.
8. The marriage between the parties is irretrievably broken.
After ninety (90) days have elapsed from the date of the filing and service of this
Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that
Defendant may also file such an Affidavit.
WHEREFORE, if both parties file Affidavits consenting to a divorce after ninety (90) days
have elapsed from the filing and service of this Complaint, Plaintiff respectfully requests this
Honorable Court enter a decree of divorce pursuant to § 3301(c) of the Divorce Code.
COUNT II
REQUEST FOR A NO-FAULT DIVORCE
UNDER SECTION 3301(d) OF THE DIVORCE CODE
10. The averments of Paragraphs 1 through 9 hereof are incorporated herein by
reference.
11. The marriage of the parties is irretrievably broken.
12. The parties have lived separate and apart for a period in excess of two years and at
the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate
and apart for at least two years as specified in § 3301(d) of the Divorce Code.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a decree of
divorce pursuant to § 3301(d) of the Divorce Code.
WOLF &
2012 BY:
NATH N C/. WOLF, ESQUIRE
Suprena ourt ID #87380
10 West High Street
Carlisle, Pennsylvania 17013
(717) 241-4436
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in this amended complaint 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.
August 7,.J, 2012
E L. c e, Plaintiff
ERIN L. MCBRIDE,
Plaintiff
V.
HOWARD C. MCBRIDE,
Defendant
IN THE COURT OF COMMON
CUMBERLAND COUNTY, PEIS
: CIVIL ACTION - LAW
NO. 2010-3762 CIVIL TERM
: IN DIVORCE
NOTICE OF INTENTION TO RETAKE AND USE PRIOR NAME
TO THE PROTHONOTARY:
Kindly file the attach Notice of Intention to Retake and Use Prior Name:
I, ERIN L. MCBRIDE, hereby give notice, avowing my intention to resume and hereafter use
my prior surname, to wit: ERIN L. WOLLYUNG, in accordance with the provisions of the Act of
December 16, 1982, P.L. 1309, No. 295, Section 704 (a) (54 Pa.C.S. Section 704 (a)) and in support
there I aver as follows:
1. I, ERIN L. MCBRIDE, am an adult resident of North Middleton Township, Cumberland
County, Pennsylvania.
2. My divorce is docketed to the above term and number.
I verify that the statements made in this document are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein made are subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
IN WITNESS WHEREOF, I have hereunto set my hand and seal thisp21 day of August, 2012.
(SEAL)
IN L RI
TO BE KNOWN AS:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
E SEAL
IN OLLYUNG
:SS:
Wota=
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P-*a?96'Vs
PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania,
this ?2 day of August 2012, ERIN L. MCBRIDE, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within agreement, and acknowledge that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have
WMM N CAI. OF PENN
N rlal Sell
Nathan C. Wolf, Notary Public
CarNste 6= Cumberland Cft*
Commisa; 9604,
MEMBER, PE10MV
and official seal.
Notary
NATHAN C. WOLF, ESQUIRE
ATTORNEY TD NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L.'McBRIDE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVA91Xe -?'
-0--C ;:??7, -,
v. : CIVIL ACTION - LAW
HOWARD C. McBRIDE, : NO. 2010 - 3762 CIVIL TERM r
Defendant : IN DIVORCE -
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a counter
affidavit within twenty days after this affidavit has been served on you or the statements will be
admitted.
AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
The parties to this action separated on or about June 7, 2010, and have continued to
live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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.
2012
L. Mcgrifle; now known as Erin L.
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L. ''McBRIDE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVA f IX."
• VJ
CIVIL ACTION - LAW ,
cn ,? rv
: NO. 2010 - 3762 CIVIL TERM
: IN DIVORCE;
V.
HOWARD C. McBRIDE,
Defendant
AFFIDAVIT OF SERVICE
I, Nathan C. Wolf, Esquire, attorney for Plaintiff, do hereby swear or affirm subject to the
penalties of perjury that on ,Qv?arr 21 ZD f caused to be mailed a copy of the foregoing Affidavit
Under Section 3301(d) upon the following person, by United States Mail, addressed as follows:
Howard C. McBride
3 Maple Avenue
Carlisle, PA 17013
Respectfully subs
WOLF & WOLF
Date: August 1 , 2012
Nathan,G. }Volf, Esquire
10 WesLWiigh Street
Carlisle, PA 17013
(717) 241-4436
Supreme Court I.D. No. 87380
Attorney for Plaintiff
t s
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L. McBRIDE,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
HOWARD C. McBRIDE, : NO. 2010 - 3762 CIVIL TERM
Defendant
: IN DIVORCE ,
.
iu
. -4
NOTICE OF I NTENTION TO REQUEST ENTRY
OF 301(d) DIVORCE DECREE r "' G
TO : HOWARD C. McBRIDE =, r*a
3 Maple Avenue == t rt
Carlisle, PA 17013
You have been sued in an action for divorce. You have failed to answer the complaint or file
a counter-affidavit to the §3301(d) affidavit. Therefore, on or after September 12, 2012, the other
parry can request the court to enter a final decree in divorce.
If you do not file with the Prothonotary of the court an answer with your signature notarized or
verified of a counter-affidavit by the above date, the court can enter a final decree in divorce. A
counter-affidavit which you may file with the Prothonotary of the court is attached to this notice.
Unless you have already filed with the court a written claim for economic relief, you must do so by the
above dale or the court may grant the divorce and you will lose forever the right to ask for economic
relief. The filing of the form counter-affidavit alone does not protect your economic claims.
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
REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
NATH&N-C. WOLF, ESQUIRE
Attorney for Plaintiff
b
NATHAN C. WOLF, ESQUIRE
ATTORNEY ID NO. 87380
10 WEST HIGH STREET
CARLISLE PA 17013
(717) 241-4436
ATTORNEY FOR PLAINTIFF
ERIN L. McBRIDE,
Plaintiff
V.
HOWARD C. McBRIDE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2010 - 3762 CIVIL TERM
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the
divorce decree:
'
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1. Ground for divorce: Irretrievable breakdown under Section 3301(d) of the Divorce Code.
2. Date and manner of service of the complaint: On or about October 12, 2010, defendant'
was served a certified copy of the divorce complaint via restricted delivery, addressed to the
defendant. (See Affidavit of Service previously filed, October 15, 2010) ** Defendant was served
with amended complaint in divorce on August 21, 2012 via regular mail (See Affidavit of Service
filed August 21, 2012)
Complete either paragraph (a) or (b):
(a) Date of execution of consent required by Section 3301(c) of the Divorce Code:
By the plaintiff n/a; By the defendant: n/a
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
August 21, 2012
(b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: August 21,
2012k
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: August 21, 2012, by regular
mail addressed to Defendant.
(b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with
the Prothonotary: n/a
Date defendant's Waiver of Notice in Section 3301(c) divorce was filed with
the Prothonotary: n/a
October 1.S , 2012
NAT C. WOLF, Esquire, for Plaintiff
Erin L. McBride
v.
Howard C. McBride
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2010-3762
DIVORCE DECREE
AND NOW, Oc.~ `l Q~( ~:SS AM , ~,01Z , it is ordered and decreed that
Erin L. McBride plaintiff, and
Howard C. McBride ,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.
..1
Prothonota
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By the Court,
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