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Home My WebLink About01-1164IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: VS. :: SHARON K. GLASS, :: Defendant :: CIVIL ACTION--LAW NO. 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 the 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, Plaintiff vs. SHARON K. GLASS, Defendant :: CIVIL ACTION--LAW :: :: NO. 2001- /'/~ CIVILTERM :: IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. It' you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: VS. SHARON K. GLASS, :: Defendant :: CIVIL ACTION--LAW NO. 2001- /lc V' IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE CIVIL TERM 5. 6. 7, Plaintiff is KEITH A. GLASS, who currently resides at 401 High Mountain Road, P.O. Box 37, Walnut Bottom, Cumberland County, Pennsylvania, where he has lived since on or about October 1, 1985. Defendant is SHARON K. GLASS, who currently at 401 High Mountain Road, P.O. Box 37, Walnut Bottom, Cumberland County, Pennsylvania, where she has lived since on or about October 1, 1985. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. The Plaintiff and Defendant were married on May 19, 1985, in Walnut Bottom, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties. 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. Plaintiffrequests the Court to enter a decree in divome. Date: February 28, 2001 ~~m, #17143 Attorney for Plaintiff FISHMAN & MORGENTHAL 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 (717) 249-6333 'x\MP~INSERVER~UBLIC~roger~Farnily Law\divorce\Glass Divorce\glass complaint.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. Ann. {}4904, relating to unsworn falsification to authorities. TH A. GLASS Date: February 28, 2001. 2 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: :: VS. ~ SHARON K. GLASS, :: Defendant :: CIVIL ACTION--LAW NO. 200 I- [ I (.o~ CIVIL TERM 1N DIVORCE ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: I hereby accept service of the Complaint in Divorce filed by Keith A. Glass, my husband and plaintiff in the above captioned action. Date: c~/'~/t~/ Sharon K. Glass, Defendant 401 High Mountain Road P.O. Box 37 Walnut Bottom, PA 17266 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: VS. SHARON K. GLASS, :: Defendant :: CIVIL ACTION--LAW NO. 01-1164 CIVIL TERM 1N DIVORCE AFFIDAVIT OF CONSENT 1. An Amended Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 28, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. I verify that the statements made in this affidavit are true and correct. I tmderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Defendant, Sharon K. Glass IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: VS. :: SHARON K, GLASS, :: Defendant :: CIVIL ACTION--LAW NO. 01-1164 CIVIL TERM 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (C) AND § 3301 (D) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce ~vithout 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 divome is granted. I understand that I will not be divomed 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, l understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. / Sharon K. Glass, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: VS. SHARON K. GLASS, :: Defendant :: CIVIL ACTION--LAW NO. 01-1164 CIVIL TERM 1N DIVORCE AFFIDAVIT OF CONSENT 1, An Amended Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 28, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry ora final decree of divorce. 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: (P~a~laint/~iff, Ke~K~i~ A. Glass IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: VS. SHARON K. GLASS, :: Defendant :: CIVIL ACTION--LAW NO. 01-1164 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF iNTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (C) AND § 3301 (D) OF THE DIVORCE CODE 1 consent to the entry of a final decree of divorce without notice. 1 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 tmtil 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. Date: 4q:me Aq , 2001 Keith A. Glass, Plaintiff IN THE, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GLASS, :: Plaintiff :: :: VS, :: SHARON K. GLASS, :: Defendant :: CIVIL ACTION--LAW OI .l/t. ~/ NO. 6,~-6¢4 CIVIL TERM 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: 1. Ground for divorce: irretrievable breakdown under Section 201(c) of the Divorce Code. 2. Date and manner of service of the complaint: Defendant accepted service on March 7,2001. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by Section 201 (c) of the Divorce Code: by plaintiff: May 29, 2001; by defendant: May 31,2001, (b)(1) Date the execution of the plaintiffs affidavit required by Section 201(d) of the Divorce Code: ; (2) date of service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: None. 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 201(d)(1)(i) of the Divorce Code. Not Applicable. Roger M. Morgenthal, Esquire ID#17143 FISHMAN & MORGENTHAL Attorneys for Plaintiff 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 717-249-6333 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE-- OF PENNA. KEITH A. GLASS N O. 01-1164 _ C1A;IL VERSUS SHARON K. GLASS AND NOW, DECREED THAT AND DECREE IN DIVORCE KEITH A. GLASS SHARONK. GLASS 2001 , IT IS ORDERED AND PLA INTI FF, 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; //~~'ROTH O NOTARY