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HomeMy WebLinkAbout01-1397LAURETTE TRICE VINCENT GUY TRICE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO. CIVILTERM Ol ~ 1~577 : 1N 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 fights 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, 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. lF 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 LAURETTE TRICE, Plaintiff VINCENT GUY TRICE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION ~ LAW · tJq9 i NO ol . CIVIL TERM : IN DWORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE l. Plaintiff is LAURETTE TRICE, who curremly resides at 122 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 since August 1996. 2. Defendant is VINCENT GUY TRICE, who currently resides at an address unknown, but can be reached in care of James K. Jones, Esquire, 7 Irvine Row, Carlisle, Cumberland County, Pennsylvania, 17055 since June 1998. 3. Plaintiffand Defendant have both been bona fide residents in the Commonweaith for at least six months immediately previous to filing of this Complaint. 4. Plaintiffand Defendant were married on December 15, 1996, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken· 7. Plaintiffhas been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 8. Plaintiffrequests the Court to enter a Decree in Divorce. 155 South Hanover Street Carlisle, Pennsylvania 17013 1 North Main Street Charnbersburg, Pennsylvania 17201 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: "-1 q Laurette Trice, Plaintiff By: Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 LAURETTE, TRICE V1NCENT GUY TRICE Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION- LAW : NO.O!-/3~VIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301(c) of the Divorce Code was filed on March 12, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date o£ filing the Complaint, 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entw of the decree. I verify that the statements made in this Affidavit are hue 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: Laurette Trice, Plaintiff LAURETTE, TRICE VINCENT GUY TRICE Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :N 13qq O. - CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT AND ACKNOWLEDGEMENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 12, 2001, and I acknowledge receipt of a copy of the same, which was served on me on March 14, 2001, by Certified Mail. 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. 4. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divome is granted. 5. I have been advised of the availability of marriage counseling, and do not request that the Court require that my spouse and I participate in said counseling. 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: '~'~ [~-~/f . ~ Vincent Trice, Defendant Notcr NOTARIAL SEAL E. MANOW S~APOE, Notary Pul~ O~ of Phil,adell:)hia ~Phil~ Oounly LAURETTE, TRICE Vo VINCENT GUY TRICE Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 - 1397 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 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 fa/se statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unswom falsification to authorities. Date: Laurette Tric~, Plaintiff LAURETTE, TRICE VINCENT GUY TRICE Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 - 1397 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 ora 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 divomed until a divome decree is entered by the Court and that a copy of the decree will be sent to me inunediately 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. Vincent Trice, D~fendant LAURETTE, TRICE Vo VINCENT GUY TRICE Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- 1397 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 2$th day of June, 2001, 1, Karl E. Romlnger, Esquire, attorney for Laurette Trice, Plaintiff: in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested, restricted delivery. The original return receipt card signed by the Respondent on March 14, 2001, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Dated: Jane 25, 2001 Karl E. Rominger, Esquire Attorney for Plain[iff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 I.D. # 81924 EXHIBIT"A" · Coml31ete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired, · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the or on the front if space permits. A. .Re~elved bY*lPleese P~nt C~ee#y) B. DateofD~ [] Agem [] Addm~ee OYe~ ,1~ No '~ Certified Mail [] Express Mail [] Registered ~ Return Receipt for Memflam:l~e [] Insured Mall [] C.O.D. 4. Restricted Delive~j? ~J~tta Fee) ~yee 2. Article Number (Copy from service label) PS Form 3811, July 1999 Domestic Return Receipt 102595-0~-M-0952 EXHIBIT "A" LAURETTE TRICE, Plaintiff VINCENT GUY TRICE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 01 -1397 CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: March 14, 2001. 3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce Code: by the Plaintiff June 15,2001; by the Defendant June 21,2001. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 25,2001. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 25, 2001. Date: June 21, 2001 ~xarl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 LAURETTE TRICE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY .STATE OF ~~ PENNA. NO. 01-1397 VINCENT GUY TRICE Defendant AND NOW, DECREED THAT AND DECREE IN DIVORCE Laurette Trico Vincent Guy Trice ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND ,PLAINTIFF, ,DEFENDANT, 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 P O~T/O~OTARY