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Home My WebLink About01-1821KATHLEEN M. CLARK, Plaintiff VS. ROBERT L. CLARK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O I - I ,~.~ ! Civil Term ACTION 1N DIVORCE NOTICE TO DEFEND AND CLAI/Vl 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 youx children. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 (717) 249-3166 KATHLEEN M. CLARK, Plaintiff VS. ROBERT L. CLARK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COIZNTY, PENNSYLVANIA : : No. 0 J- / 3'-2 ! ~-,~ ~7-a~.~-- Civil Term : ACTION IN D1VORCF, COMPLAINT IN DIVORCI~ 1. Plaintiffis Kathleen M. Clark, an individual suijuris, who has resided at 652 Lewisberry Road, New Cumberland, Cumberland County, Pa., 17070, since 1983. 2. Defendant is Robert L. Clark, an individual suijuris, who has resided at 209 5th St., New Cumberland, Cumberland County, Pa., 17070, since August 2000. 3. Plaintiff and Defendant have been bona fide residems of the Commonwealth for at least 6 months immediately previous to the filing of this Complaim. 4. The Plaintiffand the Defendant were married on August 12, 1995 in York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available., and that plaimiffmay have the right to request that the court require the parties to participate in counseling. 7. Plainfiffand Defendant have no children together. 8. Plaintiffand Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiffrequests the court to enter a decree in 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. ]VI. Clark, Plaintiff Respectfully submitted, ams, Esquire - -- · 79465 uth Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF KATHLEEN M. CLARK, Plaintiff VS. ROBERT L. CLARK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 1821-2001 CivilTerm : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE O.F_ NOTICE TO DEFEND AND COMPLAINT AND NOW, this April 5, 2001, I, Jane Adams, Esquire, hereby certify that on April 4, 2001, a tree and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Robert L. Clark 209 5th St. New Cumberland, Pa. 17070 DEFENDANT Respectfully Submitted: ~, Esquire D No 79 ~65 Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF No. 1821 - 2001 Civil Term ACTION IN DIVORCF_ DAVIT OF CONSEN? ction 3301(c) of the Divorce Code was filed on ;fendant is irretrievably broken and ninety days have elapsed Complaint. ecree of divorce after se~/ice of notice of intention to request I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 49,04, relating to unsworn falsification to authorities. Date: // ~- ~ / ~~C-~lar~';la~inti~ ~~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~33011c~ OF THE DIVORCE CODE 1. consent to 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 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: //, ~-,~, /l~athleen M.: C~lar~r k: Plaintiff KATHLEEN M. CLARK, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 1821 -2001 CiviITerm ROBERT L. CLARK, Defendant : ACTION IN DIVORCF AFFIDAVIT OF CONSENT. 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 28, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: Rob'~'t L. Clark, Defehdant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(ct OF THE DIVORCE CO_hr: 1. I consent to 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 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 ara made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: / ]~..._ ~'~ ~ ~ ~,~L~ ~ (/~/~ Robert L. Clark, Defendant --'~ KATHLEEN M. CLARK, Plaintiff : IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 1821 -2001 CiviITerm ROBERT L. CLARK, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THEPROTHONOTARY: 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. 2. Date and manner of the service of the ComplainlI: Delivered bY certified mail. restricted delivery_, return receiot re(~uested, delivered on: April 4, 2001. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: November 5, 2001. By Defendant: November 5, 2001. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 8, 2001. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 8, 2001. Date:I/..-- Respectfu Ily.,,.~_b mitted: J/J~ Adar~s~ire I./D. No. 79465 ~ 17 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Afforney for Plaintiff IN THE COURT Of COMMON PLEAS STATE OF Flalntiff OF CUMBERLAND COUNTY PENNa. VERSUS Robert L. 01ark, Defendant N o. 1821 Civil Term 2001 AND NOW, DECREED THAT AND DECREE IN DIVORCE ~athleen M. Clark Robert L. Clark , IT IS ORDERED AND __, PLAINTIFF, __, 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; ][On~, Attest://} ,<_~/~/~ J. ~:~ ~"~~ ROT H O N OTA RY