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HomeMy WebLinkAbout04-3647 II " CHRISTOPHER M. BELIEU, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CLI- 31.1./7 CIVIL TERM JENNIFER LYNN BELIEU, Defendant CIVIL ACTION - LAW 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 Courthouse, Carlisle, 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 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 Count V Bar Association 2 Libertv Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 fl\div\BELIEUcomplaint2 CHRISTOPHER M. BELIEU, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0'/- 3(, '11 JENNIFER LYNN BELIEU, Defendant CIVIL ACTION LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is CHRISTOPHER M. BELIEU, an adult individual, who currently resides at 207 West First Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant in this action is JENNIFER LYNN BELIEU, an adult individual, who currently resides at 111 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on May 24, 2003, in Windham County, Connecticut. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. -1- II 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that no children have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of di- vorce. 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 p.e.s. 54904, relating to unsworn falsification to authorities. ~ . if!f:sT PHER M. BELIEU Date: ,f t-v/o'l / STONE LaFAVER TSKI ./ / / ) ESQUIRE E p(J~ \l ~ € - r- L, ~ ~ 0 S--:tJ ?=- 1- ;.~... ~ , -'Q ctM;JJt_ "'. R< (~"'-:; _ PI D, vd-i 1 f _ V .I no "" ""rfA vs. I -7(\/1 fZ, (, t' f1 '/ ~-~t In the Court of Common Pleas of Cumberland County, Pennsylvania '31041 No. ~:- .;0"1-- CiviJ.ff..:((P y.. ~:.- D>wu 7O~ fhn en o~ iJ: ~ r/G~~ tI,,~ Ia .r::t = r<-, tL f=-<- '---h..... rD'1/01/'( f) To Prothonotary 19 ~ ~~ - AII;:?t-or!'3!intiff-- ~~5.t \ . <-o,r<. of'or> , A r. No. Tenn. 19 - vs. PRAECIPE Filed 19_ , Atly. o c ,... "L'i:D 11"1r-'" z'j':, --:"\ &-~ -~~~ r:~ l ::f; ~. "7:.l.._- <2.0 .vC .-, ~ ~@ ~ '? if> r"q -0 \ rv ..-\ :;r:...,..1 rn--. 'fT, '"'0\..... :-0"( go 75.:Q, __';1"1....1 t.5rn .::..; ."? '-0 --< -0 ::;c r. - ~ SHERIFF'S RETURN - REGULAR CASE NO: 2004-03647 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BELIEU CHRISTOPHER M VS BELIEU JENNIFER LYNN RONALD KERR , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon BELIEU JENNIFER LYNN the DEFENDANT , at 1256:00 HOURS, on the 7th day of September, 2004 at 111 SHIRLEY LANE BOILING SPRINGS, PA 17007 by handing to JENNIFER L. BELIEU a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.70 .00 10.00 .00 31.70 ~~:d'<.~~ R. Thomas Kline ' 09/08/2004 STONE LAFAVER Sworn and Subscribed to before By: STONE ~sLs me this ft.':: day of ~_ .2w'r A.D. (. JI!:otqon~ ~ . fl\div\BELIEUcomplaint2 CHRISTOPHER M. BELIEU, Petitioner v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA bY - 3lHi NO. OJ ~2~3 CIVIL TERM JENNIFER LYNN BELIEU, Respondent CIVIL ACTION LAW IN DIVORCE PETITION FOR EMERGENCY HEARING TO ORDER MARITAL HOMES BE LISnm FOR IMMEDIATE SALE 1. The Petitioner in this action is CHRISTOPHER M. BELIEU, an adult individual, who currently resides at 207 West First Street, Boiling Springs, Cumberland County, pennsylvania 17007. 2. The Respondent in this action is JENNIFER LYNN BELIEU, an adult individual, who currently resides at 111 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The Petitioner and Respondent were lawfully joined in mar- riage on May 24, 2003, in Windham County, Connecticut. 4. A complaint in Divorce was filed by the Petitioner on August and the Respondent was served by the Sheriff on September, 2004. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Petitioner purchased the property located at 111 Shirley Land prior to the marriage; however, when the parties sought to consolidate debt after marriage, a re-financing of this home was done, -1- [' o "--,~ ~, ..., C=:) ~~ ...- (/) ["'"1 -":i o -n --4 ~. l'llp ~J(11 ~l,~\ ::~;~rn ':,) --<: ,- - t.) C"1 ()-i SEP 1 4 20040/ (). I v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA O'i-?jf;'I1 NO. 03 ::J2:'3J CIVIL TERM CHRISTOPHER M. BELIEU, Petitioner JENNIFER LYNN BELIEU, Respondent CIVIL ACTION LAW IN DIVORCE Order AND NOW, this IlP~ day of September, 2004, after reviewing the attached petition, this Court finds that a Hearing will be held in to determine if the Petitioner's Request to List the Marital Homes for Sale should be granted. Said Hearing to be held on I/'.et) ,in courtroom # ;;l. )1U:.- day of September, 2004, at ( By the Court -4- <"f {, if r' ~ . 1 \...It>" \.'.-.,....'j.,.'"f I vII ~ ;'/\ !'\,)i\J>:Y:.~ ALNnC" """'''''HI8 L I :8 He! 9 1 d3S 'JDOZ ,\UVLL~j!:!~j~~\(:~!1:ill :dO CHRISTOPHER M. BELlEU, PETITIONER V. . IN THE COURT OF COMMON PLEAS OF : CUMBERLA.ND COUNTY, PENNSYLVANIA JENNIFER LYNN BELlEU, RESPONDENT : 04-3647 CIVIL TERM AND NOW, this ORDER OF COURT "2J....~ day of September, 2004, it is ordered that the hearing on the petition of Christopher M. Belieu for emergency relief now scheduled for 11 :00 a.m. Monday, September 27, 2004, is cancelled. The hearing shall be conducted in Courtroom No.2 at 3:00 p.m. Thursday, October 7, 2004. vEITzabeth B. Stone, Esquire For Petitioner By the :oart, / ~ri K. Serratelli, Esquire 2080 Linglestown Road Harrisburg, PA 17110 ) ...-Jennifer Lynn Belieu 11 Shirley Lane Boiling Springs, PA 17007 :sal .A.JJ\:I~:(-'I. L S :[ pc! SZ dT; IIOnZ iJC(:\J :lHL :JO :J:)i~;~I<)"(rn!:l CHRISTOPHER M. BELIEU. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND' COUNTY. PENNSYLVANIA 04-3V'\1- : NO. M UJtl CIVIL TERM v. JENNIFER LYNN BELlEU, Defendant : CIVIL ACTION - LAW : IN DIVORCE ORDER OF COURT AND NOW, this 1" day of October, 2004, upon agreement of the parties, and without a need for hearing, it is HEREBY ORDERED AND DECREED as follows: 1. The parties shall immediately list for sale the jointly owned real property located at 207 First Street, Boiling Springs, Cumberland County, pennsylvania. The listing agent shall be d orOnL\ (}\-\'\& \\5'\\nqU'1ent ffiUtua\\y Qgrtt'.c Wayne Deakin of Wolfe & Shearer Realt/.' The Tisting price thr this property shall be detertnine<b l.L\Xl (l duXm. by the listing agent, with input from the parties. Both parties shall fully cooperate in the listing ofN- \)C\ vtlc this property and shall sign all necessary documents to effectuate a sale of this property, when requested, in a timely fashion. In the event the real property is sold, after the satisfaction of the mortgage and all costs of sale, any remaining proceeds shall be held in escrow until such time as the parties reach a mutual agreement as to how the net proce:eds should be divided. 2. Defendant, Jennifer Lynn Belieu, shall continue to reside in the jointly owned real property located at III Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania. During her occupancy of this property, she shall satisfy each and every month, the mortgage and all utility bills associated with the real property. In the event Defenwmt defaults on the mortgage for ~~ e~ !v---Uz , ~_ ~~d J~ Avli.-- ~ a period of thirty (30) days or more, the parties shall immediately list for sale the Shirley Lane real "OY o.n~ o+na- \1'5\'\1'\<), o.Qc.nt- \ property with Wayne Deakin of Wolfe & Shearer Realty. The listing price for this property sllall {'(\lAtu~dl') o.q ~(..ec be determined by the listing agent, with input from the parties. To effectuate the above, the ~:;..U) ...... "'"" "'" ...... _ whicl> "'"" '" bdd ;n ",,"w by "",""""'".0",",, c"" ~iti CS, A. Boyanowski, Esquire. In the event the real property is sold, after the satisfaction of the mortgage and all costs of sale, any remaining proceeds shall be held in escrow until such time as the parties reach a mutual agreement as to how the net proceeds should be divided. 3. Plaintiff, Christopher M. Belieu, shall remove a!~ of his personal belongings, household goods, and furnishings from the real property locatl:d at 111 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania, within thirty (30) days ofthe date of this Order of Court. Thereafter, Defendant shall enjoy exclusive possession over the real property located at 111 Shirley Lane, Boiling Springs, Cumberland County, pennsylvania. 4. Defendant, Jennifer Lynn Belieu, shall fully C<loperate with the listing agent, make the property available for showing to potential buyers, and keep the property in a reasonable stage of tidiness, in the event the Shirley Lane real property is lisu:d for sale. 5. \l\o.if'\htt' cnrl'5\-o{)hCX' M. Bd\GU, S\"\Q\\ I . Ollex -+Y\e. \"(0.\ p\"O\)e.Yt'l \oeo. r{.d ~~> S\)Y\nQ,'::)\ QlHnbeX\o.nQ . BY nmCOURT: Q.OUf\t,! \ Pexln'S~h/Qr\\o., ~/ 0.f\c\ ShQ\\ cont\ flUe.. -\0 '(e.."S\d~ \ '(\ 4-h~ ?'fOpe.xt'l \.A.(\ \-\ \ i \- ,<s 'So\d. lj {)as'Sc..''5'5\On . GU) ~\\i(l<j Edgar B. Bayley, J. / \:!,\t'ii\-;,!"S,\ ,f ;r\!_~;(f IJN;>:'-' - -i;nJ 0:; :f; lid L - DO ~Gaz ;\tJvIUhCi;<.,~Uuj ;(-[1 :10 :;;;)!::L:':-]"'G::f:H I CHRISTOPHER M. BELIEU, Plaintiff v. JENNIFER LYNN BELIEU, Defendant ~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA 6'/- J4lq : NO. 03-5293 CIVIL TERM : CIVIL ACTION - LAW : IN DNORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant, Jennifer Lynn Belieu, in the above captioned matter. Respectfully submitted, DALEY ZUCKER & GINGRICH, LLC o~. Cara A. BOYanOWSki,~ Supreme Court I.D. No. 68736 1029 Scenery Drive Harrisburg, P A 17109 (717) 657-4795 Attorney for Defendant .. ~ c... ..,.. c:> C) -< \ 0" '" _.,,'~ -"" o -n -\ :r~,;-c "'f-' ""ern :UCj! (,~() 2'~;~:) .':::':1,1 ") ~-l ~~~ r:-.? N (;1 u< 'fIlE COURT O. CO",",O" fLE" o. CIJMllE1lL""" COO""". l'y;~NSYL V ANI^- ()Y.- 30~1 C;.vl \ TerM FileNo.~- '0\\\urffi IN DIVORCE Vs fI" QJe.W...\.,l.. Defendant "o"~ i. h""bY ,i"n "'~ ill' f "'inuff I 'of"",",' in ,'" "",,, ",-, \.select one by marking "1l"1 ~.n'" '" "" ~bY of' 'uW D""" in Divo<'C " "'" "" """ of' ."", D""" in Di'''~ "'" ~ __ . c \'fIDy"~' tbi h""" doo" '" ,,_, "', pri" """"",of ~ pV~ ' ""Jl''"''Vl''OO'''''~'' '" ,5, 704, j,-' Si awe ~O'IlCE 1'0 ~ME l'lUOR SJ;~~ COMMO~TH~FP;~S)'LVANlA ) couNTY o~'1d On "" 'li:':'''' of ~ 20d. b,fo" ~'. "', !'<Ow"""''' CU' ""'" pub"" ,-no'" ,.,,,,,,01 CU' ,b'" """" """'" '0 m' '" b' ill' """" w"'" no"" i. """,,,bOO '0 ill' ",,,,in ,,,,um~' on' ~"""w '01,01 """ b' I .h' ~""'oI <b' foregoing for the purpose therein contained. '" Vh"'~' W,,,-" 1 b'" h~- ~, ,," """ h-"'o .ct my """ on' offi'''' (\~ -- \ NO" ~RI~l sE~l \ Cl~U\ll~~' ~REW~~KtR, NO" ~R~ PU~uc GalllSle ~olO. cumberland counW My commisSIon bpl,es ~p'il 4, 2005 .-:..:..:.-- prothonotary or }lotary Public seal. ~ "- ~ --.. "'9 <;;;' g~ - ~ ~ ~~i ~ ~ ~ "\: n. 6:Ci~, ~.<' r'-;.~ flr , p !~r{1t~ ~ "'" ..c- g ;:''::1 "". ~ :;:f ""-; F'fi:J:' _. r"'~ .J'Jrlj ,.i.JC,' i,,,) ! .:1:>.". ~r) --, ~"'. ~ I I ~~ C~.} _IJ :~i. I;? , :::? "'7; I "-J ~.) .r.:- eo I f1 \di V\BELIEUCOmplaint2 CHRISTOPHER M. BELIEO, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-5293 CIVIL TERM JENNIFER LYNN BELIEO, Respondent CIVIL ACTION LAW IN DIVORCE PETITION FOR SPECIAL RELIEF FOR AN ORDER LISTING MARITAL HOME FOR IMMEDIATE SALE AND TO RELEASE ESCROW FUNDS TO PAY OFF MARITAL DEBT 1. The Petitioner in this action is CHRISTOPHER M. BELIEU, an adult individual, who currently resides at 114 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Respondent in this action is JENNIFER LYNN BELIEO, an adult individual, who currently resides at III Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The Petitioner and Respondent were lawfully joined In marriage on May 24, 2003, in Windham County, Connecticut. 4. The parties separated approximately one year later on May 30, 2004. 5. A complaint in Divorce was filed by the Petitioner on July 26, 2004, and served by the Sheriff. 6. The Petitioner purchased the property located at III Shirley Land prior to the marriage; however, when the parties sought to -1- consolidate debt after marriage, a re-financing of this home was done, and the Respondent's name was placed on both the deed and the mortgage. 7. The Respondent then refused to live in the Shirley Lane property and convinced the Petitioner to purchase another home to call the "marital home". That property was located at 207 West First Street in Carlisle. Both the Petitioner and the Respondent had a legal, equitable and financial interest in this property, as well. 8. Ever since the purchase of the second home, the Respondent has refused to move out of the Shirley Lane home. 9. The Petitioner realized that the brief and tumultuous marriage had been a mistake; moved out after one year; and moved into the second home. 10. On or about October 7, 2004, a hearing was held before the Honorable Judge Bayley to hear the Petitioner's Special Relief request to immediately list the marital homes for sale. The parties signed a mutual agreement at that time whereby the Respondent agreed to sign the listing agreement, and the 207 West First Street property sold shortly thereafter. 11. The proceeds from the settlement in the amount of $15,203.02 money were placed in escrow, and are still being held in escrow by the Respondent's counsel. -2- 12. It was Petitioner's belief that the parties had agreed that all settlement proceeds were to be used to payoff marital debt, once he submitted copies of all original credit card bills to counsel, which he did. 13. It is averred that the Respondent is refusing to authorize the payment of any marital debt from this escrow account even though undersigned counsel has written and submitted numerous copies of all the debts arising from the brief marriage. 14. The Petitioner continues to pay on all the marital consumer debt, and has suffered financially. As a result of this, the 0% interest rates at which the parties originally purchased items has expired, and now most of the interest rates have risen, to a point now where the Petitioner is unable to remain current in order to meet the large monthly minimum payments requirements. 15. The Respondent is also refusing to list the second home for sale. Even though this was a very brief marriage, the Respondent has insisted that she lS entitled to one of the marital homes. Unfortunately, it is believed, and therefore, averred, that the Respondent's credit history is so poor that she will not qualify for a refinancing or new mortgage on this Shirley Lane property. 16. The Respondent is refusing to pay for any of the marital debts, and the parties are quickly falling behind in all of the bills. The sale of this home would alleviate the problem immediately. -3- WHEREFORE, the Petitioner respectfully requests that this Court schedule a hearing in the matter to hear the aforesaid Petition for Special Relief, to Order that the 111 Shirley Lane marital home be listed for sale immediately; to Order that the escrow account be released to payoff any and all marital debts as soon as possible; and Order any and all such relief as this Court deems just and proper. STONE La FAVER & SHEKLETSKI I E Attorneys r Petitioner -4- I \ :l\mic;\L-veri+i VERIFICATION Christopher M. Belieu states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. S 4904 relating to unsworn falsification to authorities. Date: 4/ J?-/CJS aMtt/tJrjz-- Christopher M. Belieu 1\ fl\m.::-s\~se[v~c'" CERTIFICATE OF SERVICE I, Elizabeth B. Stone, Attorney at Law, of the law firm of Stone LaFaver & Shekletski, attorneys for Plaintiff, Christopher M. Belieu, hereby certify that on this date I served a true and correct copy of the within instrument on Defendant's counsel of record by first class mail, postage prepaid, addressed as follows: Cara A. Boyanowski, Esquire Seratelli Schiffman Brown & Calhoon, P.C. Suite 201 2080 Linglestown Road Harrisburg, PA 17110-967// ---~ / Stone, Esquire 251 17070 DATE: l{lU?io< ..~~ (} ~i.':. ~f ("'"".?'1 t~ Q., ~,~ <"',..., .~ C:' "t: \.-, '();;.c,:, :;;;;<t~ '.,~., ,-{\ .~~' '.::,~~ ~~ ':--t~ ~j ?J 'J. 7:' _' co, . f.;;....:.' --0 ~;. '-" .' 'J%i\:~" i.-;;, :.<- <..', t-" - 1\ v. RECEIVED APR 2 7 20~r'\ IN THE COURT OF COMMON PLEAS OF '/ CUMBERLAND COUNTY, PENNSYLVANIA ~ 04. "}. Lf1 NO. GJ j2~5 CIVIL TERM CHRISTOPHER M. BELIEU, Petitioner JENNIFER LYNN BELIEU, Respondent CIVIL ACTION LAW IN DIVORCE Order AND NOW, this ;)g--rh day of April 2005, after reviewing the attached petition for special relief, this Court finds that a Hearing will be held in to determine if the Petitioner's Request to List the Marital Home for Sale should be granted and to determine whether the escrow account should be released to payoff marital debt at this time. ~ dP~/;), 2005, at ct?:30 Said Hearing to be held on ~, in courtroom # ~ By the Court -5- 82 : Ill,!\;! 82 HdV ~GOZ IU,<"(",,','J1U' "d ::lHl .10 ACl'J.J..vL.vllJ.. ....; ..,J, .:J ~'-\' I '^ 0111:1 :k)l.:',:;'o\....l- :.. _ ." ..V' I.VVJ J; IvrM S. S, B. & C, Hbg, Pa. 17110 NO, 2848 P. 2 CHRISTOPHER M. BELIEU, Plaill1ifl' : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW v. : NO. 04-3647 JENNIFER LYNN BELmU, now known: lIS JENNIFER LYNN THORPE, Defendant : IN DIVORCE AFFJDA VIr OF CQNSE~T 1. A Complaint in Divorce under ~33()1(c) of the Divorce Code was filed on July 26, 2004. 2. The marriage ofPlaintifhnd Defendant is irretrievably broken and ninety (90) 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 l'CQuest entry of the decree. [verify that the statements made in this Affidavit are true and correct. I understand that fiIlse statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities, I / r-" "'- Date: ,~i{:/t{ dd/;;?CQ5 By: '?~ '80 <-0 L-:;: ," ,,~ cr. ~~ w.:?'"""f} r~;s~~ ~~.'~\ l~:?, . ~~. . t.;.') .' '.-;:-; ',,-1 '~2; '~~i -- ~ - ~ --- _.. .." "J J, r vr/VI ~. s, B. & C. Hbg, Pa. 17110 NO. 2848 P. 3 CHRISTOPHER M. BELIEU, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSVL VANIA : CIVIL ACTION . LAW v. : NO. 04-3647 JENNIFER LYNN BELIEU, now known: as JENNIFER LYNN THORPE, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 1l3301(C) OF THE DIVORCE COJ)I( 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may Jose 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 Prothonotmy. I verify that the statements made in this affidavit are true and correct. I understand thllt false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsilication to authorities. Date: / . r-~) At/ILl. c;:jf<dWS 111'''- ChI; (".. .-' 0 i.~!. C;.:t (:_:.:~~ -n c.f' <-- (;~ ,,' C', -,'-, \',~' '-? ......J - -- )\ f 1 \0:_ v\8F:LIElJ, CHRISTOPHEE-affofconsent I I CHRISTOPHER M. BELIEU, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-3647 JENNIFER LYNN BELIEU, Defendant CIVIL ACTION LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 5 330l(c) of the Divorce Code was filed on July 26, 2004, and served September 7, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. C.S. 5 4904 relating to unsworn falsi fica- tion to authorities. , -.JiA. ~ J.-l , )vu~ {IL~~~ CHRISTOPHER M. BELIEU, Plaintiff Date r:::::.~ 1.._") ~~:.:. '"" '- c:::. ,-- r-.' C'1 c) -'1' --, rnF r;' C) (~J :Tj c;, In <:'? _..J - 11 fl \di v\BE:r.sr}, CHP,IS'O'OPliER-wai ver ! CHRISTOPHER M. BELIEU, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-3647 JENNIFER LYNN BELIEU, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER S; 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 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. 5 4904 relating to unsworn falsifica- tion to authorities. J uJ~ .}I Date \ )DQ~ , ~<<1s CHRISTOPHER M. BELIEU, Plaintiff r) ~~ f-~ C,..:'.) (:::.:> <:.:..J" C~ ,. (',) crl o ,-, -< f~ :J1 , "":.1,:2 ~-:: \~j -:';j), ~ '~ ~ ('-'\ ",:c-_"h"\ . , ",.~\ ~D .' , <:: .< .....::~ -' CHRISTOPHER M. BELIEU, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL DIVISION JENNIFER LYNN BEL lEU , DEFENDANT NO. 04-3647 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: 1. Ground for divorce: irretrievable breakdown under ~3301(c) 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: SEPTEMBER 7, 2004. VIA PERSONAL SERVICE BY R. THOMAS KLINE, DEPUTY SHERIFF 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code: by Plaintiff JULY 21, 2005 by Defendant JUNE 28, 2005 (b) (1) Date of execution of the affidavit required by ~3301(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: NONE 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver was filed with the Prothonotary: of ~otice in :~I (}f.,. /6 I , , ~3301(c) Divorce Date Defendant's Waiver of Notice in ~3301(c) Divorce ~ was filed with the Prothonotary: o c::. r-' C'~) c? "" L-_. C',:: f"- 1" C' o -n c!? N - ~~ ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+:+ff"'" .. . . . . . fi Of. :+; :+i . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF CHRISTOPHER M. BELIED, PENNA. PLAINTIFF No. 04-3647 VERSUS JENNIFER LYNN BELIED, AND NOW, DECREED THAT AND DEFENDANT DECREE IN DIVORCE ~3 ,;;t'4/:~fAM ,~, IT IS ORDERED AND CHRISTOPHER M. BELIED JENNIFER LYNN BELIED ARE DIVORCED FROM THE BONDS OF MATRIMONY. , 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; . '- " ,~-.. .~ ~" " -~. :~ "p-P " '-'.. /" , . - , , -'. -". ... ..-< "P\,.' ~.. \.,~ .... ....""... "'...--'" ,oJ .. ..... _--- / ~ ./ '..........,.,... '''''', /#-. 'loo. ~...... "'ota-",....I..t . ~~l- .. Of'" :+i'f.'t: 'to' . PROTHONOTARY 'f.Cf Of. ;t;'f.:+ . . . . . . . . . . . . J. . . . . . . . . . . .' . (7""'''' ~~~ ~ d? l'1'17/W ~/ ~v p r _ 'r PIo; 5C?- ;'-3 ~p~ ~~-r1J 5O'S-~ .~,f ~' ft' > -..... ~ .