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Home My WebLink About04-2845\kServerkShafedDocs\Word processing~dorqestic~collins, paub.div complaint & notice. MarO4,doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY ' PENNSYLVANIA PAULA E COLLINS, vi. JAMES E COLLINS, Plaintiff Defendant CIVIL ACTION- DIVORCE No. 2004-~_~ NOT~CE 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 within twenty (20) days after this Complaint and Notice are served, 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 Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013, 717.240.6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISIONOF 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 HAV£ A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH! 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 800.990.9108 }N THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, JAMES E COLLINS, Plaintiff Defendant CIVIL ACTION - DIVORCE No. 2o04- -- COMPLAINT Plaintiff is PAULA E COLLINS, who currently resides at 7810 Olde Scotland Road, Shippensburg, Franklin County, since May, 2000. Defendant is JAMES E COLLINS, who currently resides at 18A Hunterstown Hampton Road, Gettysburg, Adams County, since June, 2004. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediateJy previous to the filing of this Complaint. The Plaintiff and Defendant were married on January 18, 2002 at Shippensburg, Southampton Township, Franklin County, Pennsylvania. \~Server~SharedDocs\Word Processing\do,'n~stic\coJJins, paula.div complaint &notice. Mar04.doc There have been no prior actions of divorce or for annulment between the parties except NON E. 6. The marriage is irretrievably broken. 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. Forest N. Myers, Esquire Atty I.D.# 18064 137 Park Place West Shippensburg, PA 17'257 Phone 717. 532.9046 Fax 717..532.8879 e-mail fnmyers~earthlink.net_ \~Server\$hamdDocs\Word Proces$ing\domestic\collin~, paula,div complaint &notice. MarO4.doc 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. Cons. Stat. § 4904, relating to unsworn falsification to authorities. PAULA E COLLINS, Plaintiff IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, : Plaintiff : V. JAMES E COLLINS, : Defendant : CIVIL ACTION - No. 2004- 02845 DIVORCE AFFIDAVIT OF SERVICE BY MAIL Forest N Myers, being duly sworn by law, deposes and says that he mailed a copy of the Complaint in Divorce filed in this matter by 'Certified Mail, Return Receipt Requested, Addressee Only, to the Defendant at 18A Hunterstown Hampton Road, Gettysburg Pennsylvania 17325, on June 24th, 2004. The Return Receipt, signed by the Defendant is evidence of delivery to him and is attached hereto as Exhibit "A." Forest N. Myers, Esquire Atty I.D.# 18064 137 Park: Place West Shippensburg, PA 17257 Phone 717. 532.9046 Fax 717532.8879 e-mail fnmyers~earthli~n k.net Sworn and Subscribed before me this 16th day of ,C--C-OMMONW~ALTH OF P~SYLVANIA IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, JAMES I: COLLINS, Plaintiff Defendant CIVIL ACTION - No. 2004 - 02845 DIVORCE 18A ~unterst~n Ge~t~urg ~ 17325 ~"I[. , ......... 2.~ ~~ 7003 0500 0003 7585 7064 P~ ~ ~ ~ ~U~ ~ m m EXHIBIT "A" \\ForrestmyerskSharedDocs\Word Processing\domestic\collir~s.consent. Sept04.d~c IN ]'HE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, JAMES E COLLINS, Plaintiff : Defendant : CIVIL ACTION - No. 2004 - 02845 DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on June 21, 2004. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. § 4904 relating to unsworn falsification to authorities. Date: ~////~,~(~ ,2004 Paula E Collins, Plaintiff \\Eorrestmyers~S~aredDocs\Word Processing\domestic\collins.consent. SeptO4.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, JAMES E COLLINS, Plaintiff Defendant CIVIL ACTION - No. 2004 - 02845 DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on June 21, 2004. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: ~ ~(~ , 2004 I J Collins, Defendant \\Forrestmyers\Shared Docs\Word Processing\domestic\collins.waiver. Sept04.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, JAMES E COLLINS, Plaintiff Defendant CIVIL ACTION - DIVORCE No. 2004- 02845 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE. consent to the entry of a final decree of divorce without notice. 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 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 statement 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. Paula E COLLINS, Plaintiff \\For rest myerskSha red Docs\Word Processing\domestic\collins.waiver. Sept04.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, JAMES E COLLINS, Plaintiff Defendant CIVIL ACTION - No. 2004 - 02845 DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE. I consent to the entry of a final decree of divorce without notice. 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 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 statement made in this affidavit are true and correct. I understand that false statements herein are made subiect to the penalties of 18 Pa, C.S. §4904 relating to unsworn falsification to authorities. Date: ,_~p~-~?~.~,-- ~ , 2004 Ja~es E COLLINS, Defendant \\For restmye rs~S hared Docs\Word Processing\domestic\collins.praecipe. Sept04,doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA PAULA E COLLINS, : Plaintiff : V. : JAMES E COLLINS, : Defendant : CIVIL ACTION - No. 2004 - 02845 DIVORCE To the Prothonotary: 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 §3301 (c) of the Divorce Code. Date and manner of service of the complaint: June 28, 2004 Acceptance of Service by Defendant Date of execution of the affidavit of consent required by §3302(c) of the Divorce Code: by Plaintiff September 30, 2004; by the Defendant September 29, 2004. 4. Related claims pending: None Date plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: October ~; , 2004; Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: October ~:, , 2004. Forest N Myers, Esquire Attorney I.D. #18064 137 Park Place West Shippensburg PA 17257 Phone 717.532.9046 Fax 717.532.8879 e-mail fnmyers@earthlink.net INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. .................. ~l~inti.~f ............... Versus ...~a~l~S, .E .9(~LIN~ ~ .............. ............ Defendant ...... DECREE DIVORCE IN AND NOW ............ .~..g~..~"....../.~.' ..... ~t~;x .200~, it is ordered and decreed that ....... .P.a3~.l.a' .E...Cg.L.L.~..N.S ......................... plaintiff, and ................... .J.a.m. 9 .s..E..C. 9.L.L.~.N. $ ..................... defendant, are divorced from the bonds of matrimony. The court retains iurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; None