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HomeMy WebLinkAbout01-1156WILLIAM R. WEST, TERESA L. WEST, Plaintiff Defkndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW NO. 01- tl]~, 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 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 fbr the divorce is indignities or in'etrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cmnberland County Court House, High and Hanover Streets, Carlisle. 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 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 WILLIAM R. WEST, TERESA L. WEST, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0l- //,4'Z. CIVIL TERM Detbndant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF TIlE DIVORCE CODE 1. Plaintiff is William R. West, who currently resides at 1510 Centerville Road, Newville, Cumberland County, Peunsylvania, since 1978. 2. Defendant is Teresa L. West, who currently resides at 9 West Main Street, Apt, 1, Ne~wille, Cumberland County, Pennsylvania, since February 5,2001. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiffand Defendant were married on June 20, 1992, in Newville, Camberland County, Pennsylvania. 5. There have been no prior actions of divorce or Ibr annulment between the parties hereto in this or any other jurisdiction. 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. Plaintiffrequests 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. § 4904, relating to unsworn falsification to authorities. Date: ~'2 7- c> l William R. West, Plaintiff ANDREWS & JOHNSON R6nald E. Jol~s~t~t Esquire Attorneys fo(P~intiff 78 '~L Pomf~t Street Carlisle, PA 17013 (717) 243-0123 WILLIAM R. WEST, TERESA L. WEST, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01- 1156 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301 (c) of the Divome Code was filed on February 28, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry ora 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 William R. West, Plaintiff falsification to authorities. WILLIAM R. WEST, TERESA L. WEST, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01- 1156 CIVIL TERM : 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 if I do not claim them before a divorce is granted. 3. I understand that I will not be divomed until a divome 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. Date: William R. West, Plaintiff WILLIAM R. WEST, TERESA L. WEST, Plaintiff De~ndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- 1156 CIVILTERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 l (c) of the Divorce Code was filed on February 28, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. § 4904, relating to unsworn falsification to authorities. Date: Teresa L. West, Plaintiff WILLIAM R. WEST, TERESA L. WEST, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- 1156 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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 divome 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 sub. ject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: Teresa L. West, Defendant WIlJ.IAM R. WEST, TERESA L, WEST, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01-tl~--(~ CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : CO U NTY OF CUMBERLAND ) AND NOW, this /.2 day of March 2001, I, Ronald E. Johnson, Esquire, attorney for Wiltiam lC West, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the (~omplaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the abovc-captioned matter, upon the Defendant at her residence at 9 West Main Street, Apt 1, Newville, PA 17324 by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on March 3, 2001, indicating service ~vas effected, is marked Exhibit 'A", attached hereto and made a part hereof. ANDREWS & JOHNSON Sworn and subscribed to before me this / Ronald E. Johj3~n Attorney for J~raintiff ,2001. NOTAR"AL SEAL SHELLY SEXTON, NO rAR¥ PUSLIC CARLISLE BORO, C!'~.~B~RLANO CO~JNTY MY COMMISSION EXPIRES APRIL 26, ~003 SENDER: I also wish to receive the follow- E] Complete items I and/or 2 for additional sewices, ing services (for an extra fee): Complete items 3, 4a, and 4b. ~. E]P nt your name and address on the reveme of this form so that we can return fl31s card to you. -- . . [] Addressee s Address\ ¥ pAetJr%Ci~it this '°tm tc~JlJ~l~='?=. ~f~J~ mallplece' °r °n the back I' space d°es n°t 2.~'1 Restricted Delivery - ~j write ;Retum Rec~ipT Rt'le~d'~l~llpiece below the aflicle number. 3. Article Addressed to: / ~:~'/3~ 4a. Article Number II~'~C ~' '~'~ ~ "~ '4~'~"Servlce Type '~Certifisd ~ ~.O~'~'..5~" i.~.~."~v,~ ~'"~'~.~"~' []Registered u) ~_~._ F3 Express Mail []Insured G: ,q~l~etum Receipt for Merchandise [] COD C3 ~[~)Vt I~{~ ~l ate of Delive. ~ 5. Receiv~ By; (Pdnt Nam~ ~ 8. Address~'s Address (~ly if r~uest~ and 6.~ignature(Addr~sseeor~enO -- PS Form 3811, D~ber 1994 102595-99-B-0223 Domestic Return Receipt Exhibit A WILLIAM R. WEST, v. TERESA L. WEST, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 01- 1156 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of a divorce Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and manner of service of the complaint: Restricted delivery, certified mail March 3, 2001 Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff June 6, 2001; by Defendant June 7~ 2001 4. Related claims pending: None~ 5. Date Plaintiff's Waiver of Notice in §3301(c) Prothonotary: Divorce was filed with the Date: June tat/, 2001 Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: ANDREWS & JOHNSON By:_ /~onald E. Johnp~Esq. [ 78 West momf[efStreet / rC~rl~i~sl, e,,mA U013 (717) 243-0123 Supreme Court ID No. 16453 THE OF CUMBERLAND COURT OF COMMON PLEAS COUNTY STATE: OF ~ PENNA. IN ................ P~i~tif f .......................... DECREE IN AND NOW,..~... ~ .! ........ , ~'~, it is ordered and decreed that wzLr.~ .. ~s~ plaintiff, and ~ERES~ ~.. ~s~ 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; ........................... ................................