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Home My WebLink About01-2806 GAYLE A. AMOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. ~ NO. OI -.~J~ CIVIL STEVE P. AMOS, : Defendant : 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 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 mmney 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, Cun~erland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE AR 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. Lawyer Referral Service Cu~nberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ~AYLE A. AMOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. O J- 2 ~0~ Civil STEVE P. AMOS, : Defendant : IN DIVORCE COMPLAINT AND NOW comes Plaintiff, by his attorney, Kent H. Patterson, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, ~ayle A. Amos, is an adult individual residing at 719 Hummel Avenue, Borough of Lenu~yne, Cumberland County, Pennsylvania (Lemoyne, PA 17043). 2. Defendant, Steve P. Amos, is an adult individual residing at 2121 Newville Road, West Pennsboro Township, Ctuuberland County, Pennsylvania (Carlisle, PA 17013). 3. Plaintiff and Defendant have been bona fide residents in the Conunonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 28, 1999 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. Plaintiff and Defendant are both citizens of th~ United States of America. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is based are that 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 participate in counseling. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. ~ent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 VERIFICATION I, Gayle A. Amos, verify that the statements in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date ~AYLE A. AMOS, ~ IN THE COURT OF CO~ON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-2806 Civil STEVE P. AMOS, ~ Defendant ~ IN DIVORCE PRAECIPE To the Prothonotary~ Please reinstate the complaint in divorce in this case. e~n~t ~. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 Date: ~AI, ~OI ~AYLE A. AMOS, ~ IN THE COURT OF CO~ON PLEAS Plaintiff ~ CUMBERLAND COUNTY, PENNSYLVANIA v. = NO. 01-2806 Civil STEVE P. AMOS, ~ Defendant ~ IN DIVORCE CERTIFICATE OF SERVICE I, Kent H. Patterson, attorney for Plaintiff, hereby certify that I served Defendant with the Complaint in Divorce on July 2, 2001 by mailing a copy of same by U.S. Certified Mail, postage paid, addressed to Defendant as follows~ Steve P. Amoe 2121 Newville Road Carlisle, PA 17013 Attached hereto is the sender's receipt and the return receipt card which is signed by Steve Amos and indicates a date of delivery of July 9, 2001. Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 GAYLE A. AMOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-2806 Civil STEVE P. AMOS, : Defendant : IN DIVORCE I SENDER: i : ~ I also wish to receive the i· Complele Items 1 am//or 2 I~ add~llO~al sewces. ~ following services (for an " · Complete ~ mp.s 3 4a and 4 . . xtrB foe ' 3 ArJ,"le Addressed~l~_ 4a. Articl~ Numbe - [] Relum Re~eipl roi' ~h~la [] COO . 7. Date o~ Do~iv~./.~ 5. R~e~:l By: (P#nf Name) 8. A~lress~e's Addr~ (0~ if r~ues~ -~ PS Form 3811, December ~994 ,0~5~S-.~mB-~ Domestic Return Receipt GAYLE A. AMOS, z IN THE COURT OF CO~ON PLEAS Plaintiff : COMBERLAND COUNTY, PENNSYLVANIA v. ~ NO. 01-2806 CIVIL STEVE P. AMOS, , Defendant , IN DIVORCE NOTICE If you wish to defend any of the statements set forth in this Affidavit, you mast file e Counter-Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF TH~ DIVORCE CODE 1. The parties to this action separated on ~uly 9, 2000, and have continued to live separate and apart for a period of at least two years. 2. The ---=riage 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 end correct. I ttnderst~nd that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904 relating to unsworn falslfication to authorities. Dat., 71/71o GA'¥'LE Ac AMOS, z ZN THE COURT OF CO~(O~ P'r.EAB Plalntif£ : CUMBERLAND COUNTY, PE~NSYLVANZ& v. I NO. 01-2806 Civil .. STEVE P. AMOS, -- Defendant -- IN DIVORCE CERTIFICATE OF SERVICE I, Kent K. Patterson, attorney £or plaintlf£, hereby certify that I served defendant with the Affidavit under Section 3301(d) of the Divorce Code on ~ 29, 2002 by mailing a cody of same by U.S. ~all, postage paid, addressed to defendant as follows~ SC~ P. Amos 2121 Newville Road C&rlisle, PA 17013 Kent R. Patterson Attorney for Plaintlff 221 Pine Street Harrisbul~, PA 17101 (717) 238-4100 GAFf~E A. AMOS, 8 IN THE COURT OF C0~0N PLEAS Plaintiff 8 CUMBERLAND COU~T~, PENNSYLVANIA v. ~ NO. 01-2806 CML STEVE P. AMOS, ~ De£enda.ut ~ 'tN D:~,'OB. CI~- PRAECTPE TO TRANSMIT RECOP. D To the Prothonot&ry= Please transm/t the record, together with the £ollowlng information, to the court for entry of & divorce decree. 1. Ground £or dlvorce~ Irretrievoble breakdown under Section 3301(d) of the Divorce Code. 2. Date emd m-~ner o£ service of the Cc~u~laint= On July 2, 2001 by U.S. certlfled mail. A certl£1cate o£ Service has been filed with the Prothonotary. 3. &) Date of execution o£ tho affidavit required by Seotiou 3301(d) o£ the Divorce Codes July 17, 2002. A certific&te of service has been filed with the Prothonotary. 4. Related cls4--- pending8 None. No econo--'La cle4--- have been raised. Page 1 of 2 Date and~-~er o£ service o£ the notice of intention to request entz~ o£ 13301(d) divorce decree, a copy o£ which is attached. October 29, 2002 b~ U.8. £irst class mail, addressed to de£endant at the address set £orth in the co~lalnt, which is= 212X Newville Road, Carlisle, PA 17015 Kent H. Patterson 221 Pine Street Harrisburg, PA 17101 238- oo Page 2 of 2 GAYLE A. AMOS, = IN THE COURT OF COMMON PLEAS Plaintiff = CUMBERLAND COUNTY, PENNSYLVANIA v. = NO. 01-2806 CIVIL STEVE P. AMOS, ~ Defendant ~ IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DiVO~ DECR~ To~ Steve P. Amos 2121 Newville Road Carllsle, PA 17013 You have been sued in an action for divorce. You have failed to answer the complaint or file e counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after Nov~--~er 19, 2002 , the other party can request the court to enter a final decree in divorce. if you do not £11e with the prothonotary o£ the court an answer with your signature notarized or verified or a counter- af£idavit by the above date, the court can enter a flnal decree in divorce. A counter-ef£idavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a wrltten 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 risht to ask for economalt relief. The filing of the form counter-affidavit alone does not protect your econom/c claAms. 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 T~A~ OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEC~L HELP. Court Administrator Cumberland County Courthouse One Courthouse S~uare Carlisle, PA 17013-6200 (717) 240-6200 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 GAYLE A. AMOS, ~ IN TH~COURT OF COMMON PLEAS Plaintiff = CUMBERLAND COUNTY, PENNSYLVANIA v. ~ No. 01-2806 CIVIL STEVE P. AMOS, Defendant : IN DIVORCE COUNTER-AFFIDAViTUNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b)~ (&) I do not oppose the entry of a divorce decree. (b) I oppose the entry o~ a divorce decree because (Check (i), (ii) or both)~ (1) The parties to this action have not lived separate ~nd a~art for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (a) I do not wish to m~ke any clalms for economic relief, i understand that I m,y lose rights concerning allmony, division of property, lawyer's fees or expenses if I do not clalm them before a divorce is granted. (b) I wish to claimeconomlc rellef which may include alimony, division of property, lawyer's fees or expenses or other im~ortant rights. I understand that in addition to checking (b) above, I must also file &11 of m~ 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 o£ Intention to ]request Divorce Decree, the divorce decree may be entered without further notice tome, and I shall be unable thereafter to file any economic claims. Page i of 2 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~ Steve P. Amos NOTICE~ IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECON0~IC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. Page 2 of 2 IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF ~ PENNA. GAYLE A. AMOSt Plaintiff NO. 01-2806 CIVIL VERSUS STEVE P. AMOS. Defendant DECREE IN DIVORCE AND NOW. ~t~,-,~.l~_~ 2 ~ . 2002 . It IS ORDERED AND DECREED THAT GAYLE A. AMOS , Plaintiff, AND STEVE P. AMOS . 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: NONE BY THE COURT: ~ ~1 / / ATT ' C..~ --- {.~- J. ~PROTHONOTARY