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Home My WebLink About01-1629IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. ~'~ - l/~ 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 efitered against you by the court. A judgement 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 grounds lbr the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in thc office of the Prothonotary at Cumberland County Courthouse. Carhsl , PA 17013. 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 SIIOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT ItAVE A LAWYER OR CANNOT AFFORD ONE, GO 'FO OR TELEPIIONE TIlE OFFICE SET FORTIt BELOW TO FIND OUT WHERE YOU CAN GET LI~GAL IIELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. () ! '//' '~ c/ Civil Term IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT I - IRRETRIEVABLE BREAKDOWN AND NOW, comes the above named Plaintiff, Beth A. Radcliffe, by and through her attorneys, Weiglc, Perkins and Associates, and Jerry A. Weiglc, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: I. Plaintiff. Beth A. Radcliffe, is an adult individual presently residing at 27 South Penn Street, Shippcnsburg, Cumberland County, Pennsylvania, since 1994. 2. Defendant, James J. Radcliffe, is an adult individual presently residing at. 103 North Penn Street, Apt. 6, Shippensburg, Cumberland County, Pennsylvania, since December, 2000. 3. Thc Plaintiff and Defendant are nationals and citizens of the United States of America. and both have been bona fide residents of thc Commonwealth of Pennsylvania tbr at least six (6) months immediately previous to the filing of thc Complaint in Divorce. 4. Tile Plaintiff and Defendant were married on February 25, 1995. in Cumberland County, Pennsylvania. 5. This Diw~rce Complaint was inadvertently filed in Franklin County, Pennsylvania. to No. 20{)1-561 Civil on February 22, 2001. Praecipe to Withdraw said action ,,vas filed by counsel on February 27, 2001. Other than the above there bare been no prior actions tbr divorce or for annulment between thc parties. 6. Plaintiff has been advised that counseling is available and the Plaintiff' may have the right to request that the court require the parties to participate in counseling. 7. Tile marriage is irretrievably broken. 8. The parties have lived separate and apart since December 8. 2000. 9. The Plaintiff requests the court to enter a decree of divorce. COUNT II - INDIGNITIES GROUNDS FOR DIVORCE 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Defendant has offered to the person of the Plaintiff, Plaintiff being the innocent and injured spouse, such indignities as to render Plaintiff's condition intolerable and Plaintiff' s life burdensome. WHEREFORE. the Plaintiff prays your Honorable Court to enter a Decree in Divorce t¥om the bonds of matrimony and for such other and further relief to which Plaintiff sball be entitled. WEIGLE, PERKINS & ASSOCIAIE~ ~ ~ j~py A. ~eigle. Esquire /~torney fbr.~laintiff Attorney ID # 01624 126 East King Street Shippensburg, PA 17257 717-532-7388 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. Dated: ~/-2c-9/r-// IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff V. JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. 01-1629 CivilTerm IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND § RHONDA R. WOLFORD, being duly sworn according to law, deposes and says that on March 30, 2001, she served a tree and attested copy of Complaint in Divorce upon the Defendant, James J. Radcliffe, by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Sworn to and subscribed before me this ii'Jay of April, 2001. Notary Public James J. Radcliffe 103 North Penn Street Shippensburg, PA 1 57 , I o,.. ~_tri~i, L Tome, Notary I~l~lc I o-~PPev, sourg Bom Cumbe~md County i L My Commission Expires June 7, 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. 01-1629 Civil Term IN DIVORCE 7099 3220 0007 0914 0874 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. 01-1629 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 21, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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. Dated: '~/~0 /01 Beth A. Radcliffe, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. 01-1629 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. 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 false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. Dated: Beth A. Radcliffe, Plmntfff] ~ / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff Vo JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. 01-1629 Civil Term IN DIVORCE statements herein are made subject to the penalties of 18 Pa. C.S. falsification to authorities. AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 21, 2001. 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 § 4904 relating to unswom Dated: ~gs J. Radcli~)t~Dtfendar~- ' ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. 01-1629 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. 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 divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after il; 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. Dated: /f~(J4'- ~/.~ ~)/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. RADCLIFFE, Plaintiff JAMES J. RADCLIFFE, Defendant CIVIL ACTION - LAW NO. 01-1629 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: Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. Date and manner of service of the complaint: March 30, 2001, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. Date of execution of the affidavit of consent required by § 3301 (c) of the Divorce Code: by Plaintiff August 20, 2001, by Defendant August 15,2001. 4. Related claims pending: None Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: August 22, 2001 Date Defendant's Waiver of Notice in § 3301(c) Divorce was fi[ed thw/tl~ tie Prothonotary: August22,2001 //~ ~ /' WEtGLE, PEILKINS~ ASSOCI4~T \ /Ie~rryl~. Weig[e, Esquire v ~ Attor~y for Plaintiff . Attorney ID #01624 126 East King Street Shippensburg, PA 17257 Telephone (717)532-7388 IN THE COURT Of COIVliVION PLEAS OF CUMBERLAND COUNTY STATE Of PENNA. BETH A. l~I)CLIr~l, Plaintiff VERSUS JANES J. RADCLIffe, Defendant NO. 01-1629 DECREE IN DIVORCE AND NOW, DECREED THAT , 2~:~ l, IT IS ORDERED AND Beth A. Radcliffe , PLAINTIFF, AND Ja~es J. Radcliffe , 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 Wt~iCH A FINAL ORDER HAS NOT YET BEEN ENTERED; none