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Home My WebLink About02-0377DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02- ..~'77 CIVIL TERM IN DIVORCE 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 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 fights 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 Court House, High and Hanover Streets, Carlisle. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 I verify that the statements made in this Complaint are true and correct. I tmderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. By: Gr~utler, Esquire Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 73471 DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL TERM · NO. 02- · IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this date, January 22, 2002, I mailed a copy of Divorce Complaint to the following person at the following address by U.S. Mail, Certified mail, postage prepaid, return receipt requested, and regular mail delivered to addressee only: Christopher S. Russell, Sr. 280 Smith Road Shippensburg, PA 17257 Gr~ryyCufler, Esquire DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-377 : IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) AND NOW, this 31st day of January, 2002, I, Gregory L. Cutler, Esquire, attorney for Dawn M. Russell, Plaintiff, in the above-captioned action, hereby swear that I have served a true eopy of the Divorce Complaint, executed by the Plaintiffin the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, restricted delivery, return receipt requested. The original return receipt card signed bythe Defendant on January 28, 2002, indicating service was effected, is marked Exhibit "A', attached hereto and made a part hereof. LAW OFFICES OF PAUL BRADFORD ORR Gre~i~ry~utler, Esquire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 I.D. # 73471 ri ~eer, t [] ~_~.~_. o. 18 ddv.fy ~lmm dllti,~t from ~.m 17 OYe~ If YE~, mm' ddive~ J:k~ bdow: ONo ' 4. Rmtrk~d 1~ ~xtm Fee) 2..N1k~ Number L EXHIBIT "A" DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-377 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 22, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Date: Dawn M. Russell, Pla~iff DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., De~ndant : IN TI-IE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-377 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § $301(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, &vision 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 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 unsworn falsification to authorities. Date: ~awn M. R3~ell, Plaintiff DAWN M. RUSSELL, Plaintiff CI-IR1STOPHER S. RUSSELL, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-377 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 22, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Date: ,~//c~ ~/ Christopher S. Russell, Sr., Defendant DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-377 CIVIL TERM 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A D1VORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose 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 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 unsworn falsification to authorities. Date: Christopher S. Russell, Sr., Defendant DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-377 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following inforn~ion, to the Court for emry 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: January 28, 2002 by certified mail. 3. Date of execution ofthe affidavit of consent required by Section 3301 (c) of the Divorce Code: bythe Plaintiff April 24, 2002; by Defendant April 24, 2002. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: April 29, 2002; Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: April 29, 2002. Respectfully Submitted, THE LAW OFFICES OF PAUL BRADFORD ORR t'~r~ry~ Cutle~ Esqhire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court 1D # 73471 IN THE COURT OF COMMON PLEAS DAWN M. RUSSELL, Plaintiff VERSUS CHRISTOPHER S. RUSSELL, SR. Defendant OF CUMBERLAND COUNTY STATE OF ~,~ PENNA. NO. 377 - 2002 DECREE IN DIVORCE AND NOW,_~~ 3~ , IT IS ORDERED AND DECREED that DAWN M. RUSSELL , PLAINTIFF, ANd CHRISTOPHER S. RUSSELL,.~;SR. , 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; PrOTHONOTArY DAWN M. RUSSELL, Plaintiff CHRISTOPHER S. RUSSELL, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-377 : IN DIVORCE CIVIL TERM NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, haven been granted a Final Decree in Divorce on the 30th day of April, 2002, hereby elects to resume the prior surname of Cork and gives this written notice pursuant to the provisions of 54 P.S. § 704. Signature Signature of name being resumed