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HomeMy WebLinkAbout01-2603JEFFREY L. TAYLOR, Plaintiff V. TABATHA R. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION .. 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 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 irretriewable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania, 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4.TH FLOOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 JEFFREY L. TAYLOR, Plaintiff V. TABATHA R. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o/-a,o ._ CIVIL ACTION - DIVORCE _. _COMPLAINT UNDER SECTION 3301(c) OR 3301(d) .OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes the Plaintiff, Jeffrey L. Taylor, by artd through his attorney, Gary L. Kelley, and represents as follows: DIVORCE UNDER SECTION 3301(c) OR 3301(d) .OF THE DIVORCE CODE Plaintiff is Jeffrey L. Taylor who resides at 3(}4 Market Street, Apt. No. 4, Lemoyne, Cumberland County, Pennsylvania 17043. 2. Defendant is Tabatha R. Taylor 322 Cumberland County, Pennsylvania North Front Street, Wormleysburg, 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 30, 1996 in Steelton Dauphin County, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrieyably broken. 7. No minor children were bom of this relationship. 8. Plaintiff has been adv'is;d that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Neither party is a member of the United States Military Service or in any branch of the armed forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, the Plaintiff, Jeffrey L. Taylor, respectfully requests that this Honorable Court enter a decree in divorce divorcing the parties from the bonds of matrimony. Respectfully submitted, 132-134 Walnut Street Harrisburg, PA 17101 (717) 238-14134 ATTORNEY FOR PLAINTIFF VERIFICATION 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. Section 4904, relating to unsworn falsification to authorities. Date: JEFFREY L. TAYLOR, Plaintiff V. TABATHA R. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 2603 CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for PLAINTIFF in the above-captioned matter, do hereby certify that I served a true and correct copy of PLAINTIFF'S Divorce Complaint upon Defendant by an Acceptance of Service executed by Defendant on May 21, 2001. 132-134 Walnut Street Harrisburg, PA 17101 (717) 238-1484 Atto:mey for Plaintiff JEFFREY L. TAYLOR, : Plaintiff : TABATHA R. TAYLOR, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 2603 CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint in the above-captioned matter on behalf of the Defendant and hereby certify that I am authorized to do so. DATE JEFFREY L. TAYLOR, : Plaintiff : : V. : NO. 01 - 2603 : TABATHA R. TAYLOR, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce was filed under Section 3301(c) on May 10, 2001, and served upon the Defendant on May 21, 2001, by Acceptance of Service executed by Defendant. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Diw)rce after service of notice of intention to request entry of the decree. I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date ., JEFFREY L. TAYLOR, Plaintiff Vo TABATHA R. TAYLOR, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 2603 CIVIL ACTION - ]DIVORCE WAI'v'ER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in 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 d~ivorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after is filed with the Prothonotary. I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. JEFFREY L. TAYLOR, Plaintiff V. TABATHA R. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 2603 CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce was filed under Section 3301(c) on May 10, 2001, and served upon the Defendant on May 21, 2001, by Acceptance of :Service executed by Defendant. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date JEFFREY L. TAYLOR, Plaintiff TABATHA R. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 2603 CIVIL ACTION - ]DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in 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 di.vorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after is filed with the Prothonotary. I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. CS. Section 4904 relating to unsworn falsification to authorities. Date JEFFREY L. TAYLOR, Plaintiff Vo TABATHA R. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 2603 CIVIL ACTION - 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: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: By acceptance of service exeuted by Defendant on May 21, 2001. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: 4. 5. by plaintiff on November 14, 2001; and by Defendant on November 13, 2001. Related claims pending: No other claims are pending. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: December 7, 2001. Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: December 7, 2001. LAW OFFICES OF GARY L. KELLEY 132-134 Walnut Street Harrisburg, PA 17101 (717) 238-1484 Attorney for Plaintiff INTHE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY STATE OF ~,~ PENNA. JEFFREY L. TAYLOR, Plaintiff VERSUS TABATHA R. TAYLOR, Defendant NO. 2(;03 2001 DECREE IN DIVORCE AND NOW,~ ~t DECREEd tHAT Jeffrey L. Taylor Is ORDERED AND AND Tabatha R. Taylor ,PLAINTIFF, ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLI-OW[NG CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE ""~-'~~ROTH ~ J STATE OF JEFFREY L. TAYLOR, IN THE COURT OF COIVIN'ION PLEAS OF CUMBERLAND COUNTY _,~~ ~ PF_.NNA. Plaintiff VERSUS TABATHA R. TAYLOR, Defendant NO. 2603 2001 DECREE IN DIVORCE AND NOW, DECREED THAT Jeffrey L. Taylor Tabatha R. Taylor AND 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; NONE BY THE COURT: ATTEST: J ' PROthONOtArY