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Home My WebLink About02-0402DOREEN M. JONES, V JAY C. JONES, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - ,t/~,.~ CIVIL CIVIL DIVISION - LAW 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 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. · When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 DOREEN M. JONES, V JAY C. JONES, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02 - ~. CIVIL _. : CIVIL DIVISION - LAW : IN DIVORCE COMPLAINT Plaintiff, Doreen M. Jones, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff, Doreen M. Jones, is an adult individual residing at 752 Hamilton Street, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Jay C. Jones, is an adult individual residing at 752 Hamilton Street, Carlisle, Cumberland County, Pennsylvania. 3 The parties were married on August 7, 2001, in Mt. Holly Springs, Cumberland County, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 6 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7 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. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendam. BROUJOS & GILROY, P.C. By Attorney ~gr '[;~°a[liti~quire Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 I verify that the statements in the foregoing pleading are true and correct. I understand that false statemems herein are made subject to the penalties of 18 PaCS 4904 relating to unswom falsification to authorities. oreenM. Jones f/ ' BROUJO5 & GILROY, I'. c. ATTORNEYS AT LAW 4 NORTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 717-243-4574 766-1690 DOREEN M. JONES, Plaintiff JAY C. JONES, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02 - 402 CIVIL : : CIVIL DIVISION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, Jay C. Jones, Defendant in the above captioned action hereby acknowledge that I was served with a copy of the Complaint in Divorce in the above matter which included a Notice to Defend and Claim Rights on the ~ ~ day of Date: Jay C/J~ones / ,2002. DOREEN M. JONES, Plaintiff V JAY C. JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 02- 402 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301('c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on January 24, 2002. 2. Defendant acknowledges receipt and accepts service of th~ Complaint on or about January 28, 2002. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the dateof the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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 afier it is filed with the Prothonotary. 7. ! have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. ! do not request that the Court require counseling. 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. Doreen ~1-~ Jo~ DOREEN M. JONES, Plaintiff JAY C. JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND cOUNTY, PENNSYLVANIA : 02 - 402 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQ~UEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301{c} OF THE DIVORCE CODI~ 1. A Complaint in divorce nnder Section 3301(C) of the Div6ree Code was filed on January 24, 2002. 2. The marriage of the Plaintiff and Defendant is irretrievably !broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. I understand that I may lose rights coneerning alimony, divis!on of property, lawyer's fees or expenses if I do not elaim them before a divoree is granted; 5. I understand that I will not be divorced until a Divorce Decre~ is entered by the Court and that a copy of the Decree will be sent to me immediately ~fter it is filed with the Prothonotary. 6. I have been advised of the availability of marriage counseling and understand that I may request that the Court require connseling. I do not reqnes~ that the Court require counseling. I verify that the statements made in this affidavit are true and eorrec{. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to nnsworn falsification to authorities. Date: DOREEN M. JONES, Plaintiff V JAY C. JONES, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02- 402 CIVIL : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant Jay C. Jones. An Acceptance of Service signed by the Defendant Jay C. Jones is attached hereto and marked Exhibit A. DATE · ' o~,Es~re Attorney for PlainJfff Broujos & Giiro~ P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed before me this ~ day of~, 2002 I naget Ann Con:oran, Notary Public ~ Carlisle Bom, Cumberland County L_MY Com~i~'ssion F-.xpire~ June 10, 2006 DOREEN M. JONES, Plaintiff JAY C. JONES, Defendant : IN TIlE COURT OF COMMON PLICAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02 - 402 CIVIL : : CIVIL DIVISION- LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, JayqC. Jones, Defendant in the above captioned action hereby acknowledge that I was served with a copy of the Complaint in Divorce in the above matter which included a Notice to Defend and Claim Rights on the ~ C~ day of ,2002. Jay' C./Jones DOREEN M. JONES, Plaintiff JAY C. JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- 402 CIVIL : : CIVIL ACTION - LAW : IN 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 (X)3301(c) ()3301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: Defendant Jay C. Jones acknowledges service of the Complaint on January 28, 2002. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: June 10, 2002; Defendant: June 19, 2002. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code:. ; (2) Date of service of the Plaintiff's affidavit upon the Defendant: 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 10, 2002. (c) Date Defendant's Waiver of Notice in §3302(c) Divorce was filed with the Prothonotary: June 19, 2002. Hubert X. G~.oy, Esquire Attorney for Plaintiff Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. DOREEI~ Mo JONES Pla~tiff VERSUS JAY C. JONES Defendant NO. 02 - 402 AND NOW, DECREED THAT AND DECREE IN DIVORCE DOREEN M. JONES JAY C. JONES 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 Pending BY 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C1VIL ACTION - LAW Defendant NOTICE TO RESUME IN DIVORCE PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the r~q ~' day of~J~/df,9~ hereby elects to re~ume the pri6r surname of ,~7~_~'3/~.~(~_ (--if , and gives this writt :n notice pursuant to the prov/i~s of 54 P.S. 704. COMMONWEALT] OF PENNSYLVANIA : COUNTY OF C RLAND On the ~O)LI~'~ day of ~)~J-0~IU'~ , 20~_~_~, before me, a Notary Public, persogally appeared the above affiant known to me to be the person whose name is subscribed to the ~ithin document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Wimess Whereof, I have hereunto set my hand and official seal. CLAUDIA A. t Carlisle My Commi: IOTARIAL SEAL IEWSAKER, NOTARY PUBLIC :no. Cumberland County sion Expires April 4, 2005 Notary Public