HomeMy WebLinkAbout01-0861SUSAN L. WELSH
PLAINTIFF
Vs.
RAWNELL L. WELSH, JR.
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY PENNSYLVANIA
: CIVIL TERM
: 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 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 at:
Office of the Prothonotary
Cumberland County Court House
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS 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
2 Carlisle, PA 17013-3387
Liberty Avenue
717-249-3166
SUSAN L. WELSH
PLAINTIFF
Vs.
RAWNELL L. WELSH, JR.
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COU~NTY P.~ENNSYLVANIA
: No. 0/-~(,,/ ~ /~,~
: CIVIL TERM
: IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I
AND NOW, comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows:
1. Plaintiff is SUSAN L. WELSH, who currently resides at 1 E. Green Street, Apt. #2,
Shiremanstown, PA 17011.
2. Defendant is RAWNELL L. WELSH, JR., who currently resides at 123 E. Simpson
Street, Mechanicsburg, PA 17055.
3. Plaintiff and 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 May 2, 1992.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and also the Plaintiff may have
the right to request that the Court require the parties to participate in counseling, and after being
so advised, Plaintiff does not desire counseling.
ATTORNEY AND COUNSELOR AT LAW
352 SOUTH SPORTING I~H.I. ROAD
MECH[ANICSBURG, PA 17055
TELEPHONE (717) 737.2033
WHEREFORE: Plaintiff requests the Court to Enter a Decree in Divorce.
Respectfully submitted,
JAMES M. BACH
A, !t~orney At Law
Attorney I.D.# 18727
352 S. Sporting Hill Rd.
Mechanicsburg, PA 17050
(717) 737-2033
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that false
statements herein made are subject to penalties of 18 PA. C.S. §4904, relating to unswom
falsification to authorities.
SUSAN L. WELSH
(PLAINTIFF)
DOS - December 1, 2000
SUSAN L. WELSH
Plaintiff
V$,
RAWNELL L. WELSH, 3R.
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANI~A
NO. 01-861 - CIVt'LTERM
C~VIL ACTION - LAW
IN DIVORCE
CERTtFICATE OF PERSONAL SERVI'CE
SARAH 3. ROBERTS, being duly sworn according to Law, say that ! personally served:
RAWNELL L. WELSH, .IR.
AT 352 S. SPORTING H1;LL ROAD
MECHANICSBURG, PA 17050
by handing to him a copy of the following document:
NOTI~CE TO DEFEND AND CLAIM RZGHTS AND COMPLAt'NT tN DIVORCE
on the 26u' day of February, 2001, at 3:30 P.M.
DATE: February 26, 2001
SARAH 3. ROBERTS
SUSAN L. WELSH
Plaintiff
VS.
RAWNELL L. WELSH, JR.
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01 - 861
:
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(C) OF THE DIVORCE CODE
(1) A Complaint in Divorce reader §3301(c) of the Divorce Code was filed on
February 12,2001.
(2)
(3)
(4)
(5)
The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
I consent to the entry of a final decree of divorce, without formal notice of the intention to
request entry of divorce decree.
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.
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 tree 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.
May 28, 2001
DATE
PLAINTIFF- SUSAN L. WELSH
SUSAN L. WELSH
Plaintiff
VS.
RAWNELL L. WELSH, JR.
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
_.
: NO. 01~ 861
:
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(C) OF THE DIVORCE CODE
(1) A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
February 12, 2001
(2)
(3)
(4)
(5)
The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
I consent to the entry of a final decree of divorce, without formal notice of the intention to
request entry of divorce decree.
I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses, ifI do not claim them before a divome is granted.
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 tree 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
LL L. WELSH, 3R.
SUSAN L. WELSH
Plaintiff
VS.
PAW'NELL L. WELSH, JR.
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-861 - CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the
Court for entry of a Divorce Decree:
GROUNDS FOR DIVORCE:
( X )3301( c ) or (
applicable section.)
Irretrievable breakdown under Section
)3301( d ) of the Divorce Code. (Check
2. DATE AND MANNER of service of the Complaint:
February 26, 2001 by Personal Service
3. COMPLETE EITHER PARAGRAPH (a) or (b).
(a)
Date of execution of the Affidavit of Consent required by
Section 3301(c)of the Divorce Code:
By Plaintiff May 28, 2001 ; by Defendant May 28, 2001
(b) 1.
Date of execution of the Plaintiff's Affidavit required by
Section 3301(d) of the Divorce Code
Date of service of the Plaintiff's Affidavit upon the
Defendant:
4. RELATED CLAIMS PENDING: NONE
DATE:
DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE
PRAECIPE TO TRANSMIT RECORD, a copy of which is attached, if the
Decree is to be entered under Section 3301(d) (1) (I) of the Divorce
Code:
May 28, 2001 By:~~
JA~/~g M. BACH, ESQUIRE
Atfforney I.D.# 18727
A~torney for Plaintiff
352 S. Sporting Hill Rd.
MECHANICSBURG, PA 17050
(717)737-2033
IN THE COURT OF COMMON PLEAS
SUSAN L.
OFCUMBERLANDCOUNTY
STATE OF ~'..~ PENNA.
WELSH
Plaintiff
NO. 01-861 - CIVIL TERM
VERSUS
RAWNELL L. W~LSH, JR.
Defendant
CIVIL ACTION - LAW
IN DIVORCE
DECREE IN
DIVORCE
AND NOW, /~-~- /~ ~ , 2001
DECREED THAT SUSAN L. WELSH
, IT IS ORDERED AND
, PLAINTIFF,
AND RAWNELL L. WELSH, JR.
,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
BY THE COURT://
PROTHONOTARY
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