HomeMy WebLinkAbout01-1900KENNETH R. McPHERSON,
Plaintiff
vs.
SUSAN M. McPHERSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. O,- /900
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RI~HTS
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 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 Courthouse,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ~LIMONY, 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 YO~ LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO THE OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHEI~ YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
Two Liberty A~mnue
Carlisle, PA 17013
(717) 249-3166
KENNETH R. McPHERSON,
Plaintiff
vs.
SUSAN M. McPHERSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVTLNIA
:
No.
:
: CIVIL ACTION - LAW
: IN DIVORCE
AVISO PARA DEFENDER Y RECLAMAR DERECHOR
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de
las quejas expuestas en las paginas sigientes, debe tomar accion
con prontitud. Se le avisa que si no se defiende, el caso puede
proceder sin usted y decreto de divorcio o anulamiento puede se
emitido en su contra por la Corte. %~a decision puede tambien se
emitida en su contra por cualquier otra queja o compensacion
reclamados por el demandante. Usted puede perder dinero, o
propiedades, o otros derechos importantes para usted.
Cuando la base para el divorcio es indignidades o rompimiento
irreparable del matrimonio, usted puede solicitar consejoi
matrimonial. Una lista de consejeros imatrimoniales esta disponible
en la oficina del Prothonotario, en la Cumberland County
Courthouse, Carlisle, Pennsylvania.
SI USTED NO RECLAM_A PENSION ALIMENTICIA, PROPIEDAD M3kRITAL,
HONORARIOS DE ABOGADO 00TROS GASTOS ENTES DE QUE EL DECRETO FINAL
DE DIVORCIO 0 ANULAMIENTO SE EMITIDO, USTED PUEDE PERDER EL DERECH0
A RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE ?.T.~.VAR ESTE PAPEL A UN ABOGADO DE II~4EDIATO. SI NO
TIENE O NO PUEDE PAGAR UN ABOC4~O, VAYA O ?.?~ME A LA OFICIHA
INDICADA ABAJO PARA AVERIGUAR DONDE Pt~.~DE OBTENER ASISTENCIA LEGAL.
Cumberland County BarAssociation
Two Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
KENNETH R. McPHERSON, JR.,
Plaintiff
VS.
SUSAN M. McPHERSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUN]BERLAND COUNTY, PENNSYLVANIA
No.
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTIONS 3301 (a), 3301 (c) or 3301 (d)
OF THE DIVORCE GOD~
The Plaintiff, Kenneth R. McPherson, through his attorneys,
The Law Offices of Patrick F. Lauer, Jr., makes the following
Complaint in Divorce and, in support thereof, avers as follows:
1. The Plaintiff, Kenneth R. McPherson, is an adult
individual who currently resides at 52 N. 8th Street, Lemoyne,
Cumberland County, Pennsylvania 17043.
2. The Defendant, Susan M. McPherson, is an adult
individual who currently resides at 167 Cedar Lane, Carlisle,
Cumberland County, Pennsylvania 17013.
3. The Plaintiff is a bona fide resident of the
Commonwealth of Pennsylvania and has been for at least six months
immediately prior to the filing of this Complaint.
CO~T I- DIV_ORCE
4. Paragraphs one through three are incorporated herein by
reference.
5. The Plaintiff and the Defendant were married on August
22, 1997, at Lemoyne, Cumberland County, Pennsylvania.
6. There have been no prior actions of divorce or for
annulment between the parties.
8.
available
The marriage is irretrievably broken.
The Plaintiff has been advised that counseling is
and that the Plaintiff may have the right to request that
the court require the parties to participate in counseling.
9. This action is not collusive.
10. There are no minor children to the marriage.
WHEREFORE, the Plaintiff, Kenneth R. McPherson,
requests this Honorable
matter.
respectfully
Court to enter a decree of divorce in this
COUNT II - INDIGNITIES
11.
reference.
12.
13.
Paragraphs one through ten are incorporated herein by
Plaintiff is the innocent and injured spouse.
Plaintiff would aver that Defendant, in violation of her
marriage vows
Pennsylvania, has
make Plaintiff's
burdensome.
and in violation of the laws of the Commonwealth of
offered such indignities unto Plaintiff as to
condition intolerable and Plaintiff's life
WHEREFORE, the Plaintiff requests your Honorable Court to
enter a decree in divorce, divorcing Plaintiff and Defendant.
Date:
Respectfully submitted,
~arl~n L. Markley, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
KENNETH R. McPHERSON, JR., :
Plaintiff :
:
VS. :
:
SUSAN M. McPHERSON, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CU~ERIJkND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN DIVORCE
I verify that the statements made in this Complaint are tru~
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.
Signature:~~ ~ 1'
Kenneth R. McPhersof~
KENNETH R. McPHERSON, JR., :
Plaintiff :
:
vs. :
:
SUS~tN M. McPHERSON, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
IN THE COURT OF COMMON PLEAS OF
CUmbERLAND COUNTY, PENNSYLVANIA
NOTICE TO THE DEFENDANT
IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS
AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDAVIT WITHIN TWENTY (20) DAYS
AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL
BE ADMITTED.
AFFIDAVIT UNDER SECTION 3301(d.) OF THE DIVORCE COn~
1. The parties to this action separated on or about April 22,
1999, and have continued to live separate and apart for a period of
at least two years.
2. The marriage is irretrievably broken.
3. 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.
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.
falsification to authorities.
DATE:.~/~/
C.S. ~ 4904 relating to unsworn
Kenneth'Rl'McPherson
Sworn to and subscribed to
before me this ~i day
of ~22/~- , 2001
KENNETH R. McPHERSON,
Plaintiff
VS.
SUSA-NM. McPHERSON,
Defendant
JRof
IN THE COURT OF COMMON PLEAS OF
CU~BERLAND COUNTY, PENNSYLVANIA
NO. 01-1900
CIVIL ACTION - LAW
IN DIVORCE
COUNTER-AFFIDAVIT UNDER ~ 3301 (d)
OF THE D].~OR~E QODF,
1. Check either (a) or (b):
~ (a)
[] (b)
I do not oppose the entry of a divorce decree.
I oppose the entry of a divorce decree because:
Check (i), (ii), or both:
[] (i) The parties to this action have not lived separate and
apart for a period of at least two years.
[] (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
~ (a) I do not wish to make any olaims for economic
relief. 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.
[] (b) I wish to claim economic relief which may
include alimony, division of property, lawyer's fees,
or expenses or other important rights.
I understand that in addition to checking (b) above, I must
Also file all of my economic claims with the prothonotary in
writing and serve them on the other party. If I fail to
do so before the date set forth on the Notice of Intention to
Request Divroce Decree, the divorce decree may be entered
without further delay.
I verify that the statements made in this counter-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 aut~rities.
Date: ~ -d~0 ~0~ / Signature:.
' SUSAN M. MCPHERSON
KENNETH R. McPHERSON, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUmbERLAND COUNTY, PENNSYLVANIA
:
vs. : No. 01- I~O0 £"~"1
:
SUSAN M. McPHERSON, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICe.
TO THE PROTHONOTARY:
I, Marlin L. Markley, Esquire, verify that the Complaint in
Divorce has been served upon the Defendant indicated above by
first class, Certified Mail No. Z 353 364 617, postage prepaid,
return receipt requested, pursuant to the requirements of
Pa. R.C.P. 1930.4.
I ~ w~s~ to receive
followln~ sen~,ces (for sn
extra fee):
1. [] ~dre~see's Address
2,~ Reetrlcted Delivery
Consult po~tmaeter for fee,
4a. Arltcle Number
z &t7
4b. S®n~c~ Ty~e
[] ReglstenKI ~ Cerl~ed
[] RetumRec~ptforMerctmnd~e ~ COD
7. Date of Delivery
5. Received By: (P~fnt Na,7~) 8. Addreseee'. Addres~ (Only ff reque~ed
1025~-97-~0179 Domestic eturn Receipt
Date:
4
Respectfully submitted,
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
KENNETH R. McPHERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No.
SUSAN M. McPHERSON, :
Defendant :
CIVIL ACTION - LAW
IN DIVORCE
TO THE PROTHONOTARY:
I, Marlin L. Marktey,
AFFIDAVIT OF SERVI~
Esquire, verify that the Notice of
Intention to File Praecipe to Transmit Record has been served
upon the Defendant indicated above by first class, Certified
Mail No. Z 353 364 635, postage prepaid, return receipt
requested, pursuant to the requirements of Pa. R.C.P. 1930.4.
SENDER:
delivered.
3. Articre Add,=o=ed to:
5. Received B?: (Pfin, t I~ame) .~ .
-~ 6. Sj~ture (Addressee orAgenJ,~,/
-- ~ F~r~ ~J81~1, December 1994
I also wish to receive the follow-
ing services (for an extra fee):
1. [] Addressee's Address
4a. Article Number
4b. Service Type _ _ ~
[2] Registered ~'
[] Express Mail
[] Return Receipt forMerchandise ~]COD
7. Data of Delivery
8. Addressee's Address (Only if requested and
fee is paid)
~02595 99.B-0223 Domestic Return Receipt
Date:
Respectfully submitted,
Marlin 4. Markley, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
KENNETH R. McPHERSON, JR., :
Plaintiff :
:
vs. : No. 01 - 1900
:
SUSAN M. McPHERSON, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE TO WITHDRAW COUNT~
TO THE PROTHONOTARY:
Kindly withdraw Count II - Indignities in the
above referenced divorce as the issues have been settled.
Respectfully submitted,
Date:
Marlin L. Markley, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
KEN1TETH R. McPHERSON, JR.,
Plaintiff
VS.
SUS~/~M. McPHERSON,
Defendant
IN THE COURT OF CC~MON PLEAS OF
CU~ERL~ COUNTY, PENNSYLVANIA
No. 01-1900
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF ~ 3301(d) DIVORCE DE~.~
Susan M. McPherson, Defendant
3485 Valley Road
Marysville, PA 17053
You have been sued in an action for divorce. You have failed
to answer the complaint or file a counter-affidavit to the
~ 3301(d) affidavit. Therefore, on or after the 5th day of
June 2001, the other party can request the court to enter a final
decree in divorce.
If you do not file with the Prothonotary of the Court an
answer with your signature notarized or verified or a
counter-affidavit by the above date, the court can enter a
final decree in divorce. A counter-affidavit which you may
file with the Prothonotary of the Court is attached to this notice.
Unless you have already filed with the court a written claim
for economic relief, you must do so by the above date, or the
court may grant the divorce and you will lose forever the riqht
to ask for economic relief. The filing of the attached form'
counter-affidavit alone does not protect your economic claims.
YOU SHOULD TAKE THIS PAPER TO YO[~ LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ()NE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
Cumberland County BarAssociation
Two Liberty A~mnue
Carlisle, PA ].7013
(717) 249-31~56
KENNETH R. McPHERSON, JR.,
Plaintiff
vs.
SUSAN M. McPHERSON,
Defendant
IN THE COURT OF CO~R~ON PLF~ OF
CUMBERI2%ND COUNTY, PEN-NSYLVANIA
No.. 01-1900
CIVIL ACTION - LAW
IN DIVORCE
COUNTER-AFFIDAVIT UNDER ~ 3301 (d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
[] (a)
[] (b)
I do not oppose the entry of a divorce decree.
I oppose the entry of a divorce decree because:
Check (i), (ii), or both:
[] (i) The parties to this action have not lived separate and
apart for a period of at least two years.
[] (ii) The marriage is not irretrievably broken.
Check either (a) or (b):
[] (a) I do not wish to make any claims for economic
relief. 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.
[] (b) I wish to claim economic relief which may
include alimony, division of property, lawyer's fees,
or expenses or other important rights.
I understand that in addition to checking (b) above, I must
Also file all of my economic claims with the prothonotary in
writing and serve them on the other party. If I fail to
do so before the date set forth on the Notice of Intention to
Request Divroce Decree, the divorce decree may be entered
without further delay.
I verify that the statements made in this counter-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: Signature:
SUSAN M. MCPHERSON
~, xu~ sHOULD NOT FILE THIS CO~TER-AFFIDAVIT
KENNETH R. McPHERSON, JR.,
Plaintiff
vs.
SUSAN M. McPHERSON,
Defendant
No. ~l-/9dd
CIVIL ACTION
IN DIVORCE
IN THE COURT OF CC~MON PLEAS OF
CUmbERLAND COUNTy, PENNSYLVANIA
NOTICE TO THE DEFENDANT
IF YOU WISH TO DENY ANY OF THE STATEMENTS SET ~RT~ I~THIS
AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDAVIT WITHIN TWENTY (20) DAYS
i~ER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL
BE ADMITTED.
A~FIDAVIT UNDER SECTION 3301{d) OF THE DIVORCE CODE
1. The parties to this action separated on or about April 22,
1999, and have continued to live separate and apart for a period of
at least two years.
3.
division of property, lawyer's fees or expenses if I do
them before a divorce is granted.
I verify that the statements made in this affidavit
and correct. I understand that
subject to the penalties of 18
falsification to authorities.
The marr%age is irretrievably broken.
I understand that I may lose rights concerning alimony, !
not claim!
are true
false statements herein are made~
Pa. C.S. § 4904 relating to unsworn
DATE:~/
KennethRi'McPherson
Sworn to and subscribed to
before me this ~?~ day
of _~)~_ , 2001
KENNETH R. McPHERSON, JR., :
Plaintiff :
:
VS. :
:
SUSAN M. McPHERSON, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUmbERLAND COUNTY, PENNSYLVD~NIA
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO ].~J~NSMIT RECORD
Plaintiff's SS# 184-48-7520
To the Prothonotary: Defendant's SS# 207-44-6901
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(d) (1)of the Divorce Code.
2. Date and Manner of service of the Complaint:
Complaint served via First Class Mailf Acceptance of service
document siqned by defendant on April 16, 2001.
3. (m) Date of execution of the affidavit of consent
required by ~ 3301(c) of the Divorce Code: by the
Plaintiff ; by the Defendant
(b)(1) Date of execution of the affidavit required by
§3301(d) of the Divorc? C~de: May 3, 2001; (2) Date of filing
and service of the plaintiff's affidaw[t upon the respondent:
June 1, 2001.
4. Related claims pending: No claims were raised.
5. (a) Date and manner of service of the Notice of
Intention to File Praecipe to Transmit Record, a copy of which is
attached: June if 2001.
(b) Date Plaintiff's Waiver of Notice in § 3301(c)
Divorce was filed with the prothonotary:
;
Date Defendant's Waiver of Notice in
§ 3301(c) Divorce was filed with the prothonotary:
Date:
Respectfully submitted:
Marli~n L. Markley, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 84745 Tel. (717) 763-1800
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE Of
KAnn~hh R. MPPh~r~nn~ Jr.,
Plaintiff
VERSUS
Susan M. McPherson,
Defendant
PENNA.
N O. 01-1900
Civil
DECrEe IN
DIVORCE
AND NOW, ~, /~ ,~/
/ /
Kenneth R. McPherson, Jr.
DECREED THAT
AND
Susan M. McPherson,
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;
No claims were raised.
BY THE COURT:
PROTHONOTARY
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