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Home My WebLink About04-4172 " DAVID L. DARR, JR., Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01./- ~n Civil Tenn JILL N. DARR, : ACTION IN DIVORCE Defendant 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. Where the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cwnberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 .' DAVID L. DARR, JR" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANJA vs. No. 01..( At(?'J- Civil Term JILL N. DARR, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is David L. Darr, Jr., a competent adult individual, who has resided at 1107 Pheasant Dr. N., Carlisle, Cumberland County, Pennsylvania, 17013, since 2001. 2. Defendant is Jill N. Darr, a competent adult individual, who resides at 127 Center St., Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 12,2002 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have one child together, namely, Cambree Alexa Darr, date of birth, July 25,2001. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. . 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I veritY that the statements made in this Complaint are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. -'})..J '~a. ,. David L. D1 Jr., Plaint1 Date: ~ d,O 01 'J Adams, squire LD. No. 79465 36 outh Pitt Street C lisle, Pa. 17013 (717) 245-8508 A TTORNEY FOR PLAINTIFF 9 \:II- ~ -. -..0 7> () ~ 'i _. r, Jl -C ~ .J: :1 = ~ \::) 's v' DAVID L. DARR, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04 - 4172 Civil Term JILL N. DARR, : ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this August 30, 2004, I, Jane Adams, Esquire, hereby certifY that on August 24, 2004, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, addressed to: Jill N. Darr 127 Center St. Carlisle, Pa. 17013 DEFENDANT Respectful~ an Adams, EsqUire I.D No. 79465 3 outh Pitt Street arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF o c::. s: ,\,;'):: 111(:;" ~~;'" ~~~-- ~~<...) ~C) J>C -"7 ~ -< t-' g -=- ".. c:: G? W o ~ ~:n :B8 S1~ '"'0 6~ :;;: Zi'ti C>. -- ~ ., ~ 0:> 1. 2, and 3. Also complete o' OeIlvary is desired. and address on the reverse . '....m the card to you. to the back of the mail piece. ltep8Ce pennits. :.\ ,,' to: ,..'i,;'+.','j.,'r....',~"\,;::it..\ N {\.. -;) () Iln':~ \1' l)C1-.\<-1'- ,~."'.f .hQ'e., rv:\ nO \~ ;r' .", ,'.,'.' . D. delivery address different fro'TI item 1? If YES, enter delivery address below: \ 'L /\. 3. Service Type . Certified Mail o Registered a Insured Mail X.~::;,(.;/~;f".~.',.::w. ELI VERY ~{ t/);D L 1 ~, o Express Mail o Return Receipt for Merchandise a C.O.D. -;>0, 4. Restricted Delivery? (Extra Fee) 7003 1010 0004 7B1B 671B Domestic Return Receipt DYes ~ J 102595-02-M-1540 " UNITED STATES POSTAL SERVICE 111111 First-Class Mall PO$Iage & Fees Paid USPS Permn No. G-1D . Sender: Please print YOur name, address, and ZIP+4 in this box. jQ() t AJCUVL~ 3u ~. 'R.tf--S+ Cw-ll ~\~, fA /101;5 . DAVID L. DARR, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 04 - 4172 Civil Term JILL N. DARR, ACTION IN DIVORCE Defendant AFFIDA VlT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on August 23, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry ofa final decree of divorce after service of notice of intention to request entry of tlte decree. I : I verifY that the statements made in this affidavit are true and correct. f also understan<jJffiat false stlatements herein are made subject to the penalties of 18 Pa,C.S. 4904, relating to unsworn falsj'fication to authorities. I D~te: 1Yf!dD J;;r3i6 .~ WAIVER OF NOTICE INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(.) AND &330Hdl OF THE DIVORCE CODE 1. r consent to entry of a final decree of divorce w~thout notice. 2. I understand that] may lose rights concerning alimony, division of prop city, lawyer's fees or expenses if I ~o 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 4ecree will be sent to me immediately after it is filed with the Prothonotary. 1 verifY that the statements made in this affidavit are IT t to the penalties of J 8~.S. S4904 ue a~d correct. I understand that false statements herein are made sub' relatipg to unsworn falsification to authorities. Date:l)f/;20 !Jfjf)~ C' ,..., 0 .- ,= s-;: ...:::,;:) ., "-" :::1': -l :;'l"" :J:., --c rnp I ...,rn ~X<O N cOb -'-;-j ". .1:--n '.)- :z -"c'.(J (~rn ).0-: =2 w ;JJ 0'" ......,~ DAVID L. DARR, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 04 - 4172 Civil Term JILL N. DARR, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 330 1 (c) of the Divorce Code was filed on August 23, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 4/2- ~ /.2- aD la WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) AND ~330](d) OF THE DIVORCE CODE I. I consent to 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 wi1\ be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are tr ue and correct. I understand that fa1se statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 1/ J-I.c / j.,oo ~ ~2~.1~ r-' = = c:T' (/:l ~ N OJ ~ ~e -0\11 :,J:~9 ":--\~?, ~:C, -rl ;,.J(") 2m 9 r:-? 5J. <-.J .:< N -0 -' -- vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 4(72- No. 04 -'~Civil Term DAVID 1.. DARR, JR., Plaintiff JILL N. DARR, IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TOTHEPROTHONOTAR~ Please 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) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via certified mail, restricted- delivery, return-receipt requested, on: August 24, 2004. 3. D~te of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: April 25, 2005 By Defendant: September 26, 2006 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: May 2, 2005 Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: September 26, 2006 Respectfully Submitted: Date: (() . L/ · b e Adams, Esquire J.D. No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff , r.;; c.;? CJ"' C> C? .-"l ~~ ~-n rl1r=: -rJ I,J: -.f) ~~ """''''''', ..:"., :~~ ~.'z:/ _-c-ff ~.,' -;-'--".~ -- ;'._1;-- .:~i~{) ~ ~ 1 x:- '12 (.;"1 o ~~~~~~~~~~~~ ~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. David L. Darr, Jr., Plaintiff No. 04 4172 Civil Term No. VERSUS Jill N. Darr? Defendant DECREE IN DIVORCE AND NOW, O~,-- /I~ Z-dtJ(, IT IS ORDERED AND , , David L. Darr DECREED THAT , PLAI NTI FF, Jill N. Darr AND , 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. :{l~ PROTHONOTARY J. ~ jzP2 ~ ~ W.1/.i?/ -PIf} P ?- ~.~. /'? .?Cl. 1/. 0/ . . " .. ... ~t. .,. "~