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Home My WebLink About04-3774CHARLES SIMMONS, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE e5)51_ 377y KAREN L. SIMMONS, Defendant No. 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 in 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 of your children. When the ground for 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 Cumberland County, One Courthouse Square, Carlisle, Pennsylvania. 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 COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Toll Free 1-800-990-9108 CHARLES SIMMONS, IN THE COURT OF COMMOM PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE KAREN L. SIMMONS, Defendant No. COMPLAINT IN DIVORCE 1. Plaintiff is Charles Simmons, who currently resides at 147N. 21 s` Street, Camp Hill, Pennsylvania 17013. 2. Defendant is Karen L. Simmons, who currently resides at 700 Salem Road, Lot 14, Etters, PA 17319. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on June 5, 2000, in York County, Pennsylvania. 5. No children were born of this marriage. 6. Neither Plaintiff nor Defendant are in the military or naval service of United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce Divorcing Plaintiff and Defendant and such other Orders as.are just and appropriate. COUNT II EQUITABLE DISTRIBUTION 11. The averments of paragraphs 1-I I are incorporated herein by reference. 12. During the marriage the parties acquired marital property, assets and debts which Plaintiff requests the Court equitably distribute and assign. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant, enter an Order equitably distributing marital property and such other orders as may be just and appropriate. Respectfully submitted, f usan K. Pickf d, Es e Attorney ID No. 3344 Trindle Road Camp Hill, PA 17011 (717) 612-1660 Date: ? X27 Oy Attorney for Plaintiff VERIFICATION I, Charles Simmons, hereby state that I have read the foregoing Complaint in Divorce and that the facts set forth therein are true and correct to the best of my knowledge, information and belief. Further I understand that this Verification is made subject to the penalties of 18 Pa.C.S. §4904, which relates to unworn falsification to authorities. harles Simmons, Plaintiff N kAl Rt C:l p 1. 3 h `-11 fl L l • CHARLES SIMMONS, Plaintiff VS. KAREN L. SIMMONS, Defendant 0 IN THE COURT OF COMMOM PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE No. 377cf Cjv r AFFIDAVIT OF SERVICE I, KAREN SIMMONS, the defendant in the above captioned matter, do hereby state that I have received a Notice of Complaint and a Complaint in Divorce on ae±,-(,.l 2004 through registered or certified mail in compliance with the Pa. Civil Rules of Procedure. Karen Simmons 1 41t Ab te' m r ` rrn r --- L Cl- x , °v -, lip CHARLES SIMMONS, : IN THE COURT OF COMMOM PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE KAREN M. SIMMONS, Defendant No. 04-3774 AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on August 2, 2004. 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 unworn falsification to authorities. Date: ld?` CHARLES SIMMONS N z- C;. CHARLES SIMMONS, : IN THE COURT OF COMMOM PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE KAREN M. SIMMONS, Defendant No. 04-3774 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. 1 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 unworn falsification to authorities. Date: /O d CHARLES SIMMONS cpg 4 ?C` -r D CHARLES SIMMONS, : IN THE COURT OF COMMOM PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE KAREN M. SIMMONS, Defendant No. 04-3774 AFFIDAVIT OF CONSENT 1. A conplaint in divorce under §3301(c) of the Divorce Code was filed on August 2, 2004. 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. 1. Date: ! ! r? KA SIMMOY r-•? ,. t?'' .,,a .... ? ? ? CHARLES SIMMONS, : IN THE COURT OF COMMOM PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW : DIVORCE KAREN M. SIMMONS, Defendant No. 04-3774 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 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 unworn falsification to authorities. w Date:' KA SIMMO ?/? - 0 751, CHARLES SIMMONS, : IN THE COURT OF COMMOM PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE KAREN M. SIMMONS, Defendant No. 04-3774 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: August 18, 2004, affidavit of acceptance of service signed and attached hereto. 3. Execution of the affidavit of consent required by §3301(c) of the Divorce Code were signed by Plaintiff on August 10, 2007, by Defendant on August 28, 2007. 4. All claims raised in the complaint have been resolved to the satisfaction of the parties. 5. As required by Section 3301(c) of the Divorce Code, Plaintiff and Defendant executed their respective Waivers of Notice of Intention to Request Entry of Divorce Decree on August 10, 2007 and August 28, 2007 respectively. The Waivers of Notice are being filed contemporaneously herewith. Dated : 9 Q /Susan K. Pickfo , Esq. Attorney for P aintiff 3344 Trindle Road Camp Hill, Pa 17011 717-612-1660 ID 443093 -Rr F?71 7{ .. ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. C HAP-CFS .Simmons II No. 377Y aooY VERSUS DECREE IN DIVORCE AND NOW, 5??be?r t/ OO IT IS ORDERED AND DECREED THAT CAfA",C7 //YJAi?/?IS PLAINTIFF, AND /1 /4'IeEil1 LJ/m /'I a ns 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; ALL az A-lm-s h yE ,dE-iA) .SIB-T?,SF/ED ATTEST: ROTH O N OTA RY BY THE COURT: ov7w