HomeMy WebLinkAbout04-4886
IN THE COURT OF COMMON PLEAS OF
THE 39'h JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow, ) Civil Action - Law
Plaintiff, )
) OLf- Lf ~ f' ~
vs, ) No.
)
Timothy P. McMorrow, )
Defendant, ) In Divorce a v.m.
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 wamed 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 ground for divorce is indignities or irretrievable breakdown ofthe maniage, you may request
maniage counseling. A list of maniage counselors is available in the Office of the Prothonotary of the
Franklin County Court House, First Floor, Chambersburg, 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.
C.(.l.l-\\,b-ef' ~J.. C!J.
P (.l~~ ~)'l'\<ltRi~ Bar Association
Lawyer Referral Service ~ L '5 D. j r <:{
1-800-692-7375 (PA Only) or . fJ C (J.. Ktn:l JP
(717) 238 CT U ~ Lf q - ~ t (p~
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Franklin County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available
to disabled individuals having business before the court, please contact our office. All arrangements must be
made at least 72 hours prior to any healing or business before the court. You must attend the scheduled
conference or hearing.
IN THE COURT OF COMMON PLEAS OF
THE 39th JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow,
Civil Action - Law
Plaintiff,
)
)
)
)
)
)
)
No. 0<1- Line,. CU;JT~
vs.
Timothy P. McMorrow,
Defendant,
In Divorce a v.m.
COMPLAINT UNDER SECTION 3301 (c) OR 3301(d) OF THE DIVORCE CODE
I. Plaintiff is Krista A. McMorrow, who currently resides at 12714 Bedford Road, N .E.,
Cumberland, Allegany County, Maryland, 21502, since August, 2004.
2. Defendant is Timothy P. McMorrow, who currently resides at 21] Colonial Drive,
Shippensburg, Cumberland County, Pennsylvania 17257, since October, 2000.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least
six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on November 20, 1999 in Cumberland,
Allegany County, Maryland.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Neither the Plaintiff nor Defendant is a minor or incompetent.
8. The Plaintiffhas 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.
9. Plaintiff requests the Court to enter a decree of divorce.
BARLEY SNYDER
Date:
Cf /2 J I Le>t> <{.
By: #Zd/~ ~
Michael J. Connor, Esquire,
Attorney for Plaintiff
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.
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IN THE COURT OF COMMON PLEAS OF
ruE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow, )
Plaintiff, )
)
vs. )
)
Timothy P. McMorrow, )
Defendant, )
Civil Action - Law
No. 04 - 4886 Civil
In Divorce a v.m.
AFFIDA VIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF FRANKLIN )
Michael J. Connor, Esquire, being duly sworn according to law, deposes and says that he is
the attorney for the Plaintiff, Krista A, McMorrow, in the above. captioned matter; that he did serve
a true copy of the Notice to Defend and Claim Rights and Complaint Under Section 3301(c) or
3301(d) of the Divorce Code by mailing the same to Timothy p, McMorrow, Defendant, by
certified mail, restricted delivery, article number 7160 3901 98440233 9405 on September 30,2004,
to his mailing address of21] Colonial Drive, Shippensburg, Pennsylvania 17257; that said certified
mail article was delivered to Defendant, Timothy P. McMorrow, on October 1,2004, all as appears
from the receipt for certified mail and the return receipt attached hereto.
BARLEY SNYDER
By:
A'~5{.
Michael J. ConilOr, Esquire,
Attorney for Plaintiff
Sworn and subscribed to before me
this J!tJ{ day of tJei'4,1f!:A? ,2004.
~-/~~-L
Notary Pu lC '
1320263
NoCarfa/ Seal
Angela It RabIIan, Nc&y PoAlIIc
~Bcm,FI1IIIkMnCounly
My CommissiOO Expires Oct. 24, 2005
Member. ~ 4ssociation 01 NoIarieo
7loWJ 3'IJ], '181I14 0i!33 'llf05
TO: Timothy P. McMorrow
211 Colonial Drive
~",Pfu51257
to.60
$2.30
tl.75
SENDER: MJC$3,50
REFERENCE: $8.15
0201
04
09/30/~i
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
,60
30
. 75
0.;0
. 5
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mall
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7lWJ 3'11], '1511~ la3 ~
3. Service Type CERTIFIED MAIL
4. Pleslricted Delivery? (Extra Fee)
1. Article Addressed to:
Timothy P. McMorrow
211 Colonial Drive
Shippensburg, P A 17257
PS Form 3811, July 2001
MJC
Oon'le8tlc Return Receipt
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IN THE COURT OF COMMON PLEAS OF
THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow, )
Plaintiff, )
)
vs. )
)
Timothy P. McMorrow, )
Defendant, )
Civil Action - Law
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No. 04-4886 Civil
In Divorc(l a v.m.
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330 I (c) or 330 I (d) of the Divorce Code was filed
on September 28, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date offiJing and service of the Complaint.
3. I consent to the entry of a final decree of divorce afte:r service of notice of intention to
request entry ofthe 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. Section 4904 relating to unsworn
falsitication to authorities.
Date: I - IV - (IS
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Kri a A. McMorrow, Plalntiff
1349063
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IN THE COURT OF COMMON PLEAS OF
THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH F~
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Krista A. McMorrow, )
Plaintiff, )
)
vs. )
)
Timothy P. McMorrow, )
Defendant, )
Civil Action - Law
'':';-1
No. 04-4886 Civil
In Divorce a v.m.
~~-'
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's tees
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 will be sent to me immediately after it is filed with the Prothonotary.
I veritY that the statements made in this Waiver 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: 1- ;Y - (J.5
A-. MC~O?!::1:::
1349063
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IN THE COURT OF COMMON PLEAS OF
THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow, )
Plaintiff, )
)
vs. )
)
Timothy P. McMorrow, )
Defendant, )
Civil Action - L
{""
No. 04-4886 Civil
In Divorce a v.m.
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WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(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, 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 will be sent to me immediately after it is filed with the Prothonotary.
I verifY that the statements made in this Waiver 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.
1349063
Tim"h:PM,JJ!2~~
Date: 1- ILl -0 ~
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IN THE COURT OF COMMON PLEAS OF
THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow,
Plaintiff,
)
)
)
)
)
)
)
No. 04-4886 Civil
Civil Action - Law
-n
vs.
Timothy P. McMorrow,
Defendant,
In Divorce a v.m.
;:,
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AFFlDA VIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on September 28,2004.
2. The marriage of Plaintiff and Defendant is irretri<:vably broken and ninety days have
elapsed from the date of 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 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:
1-/4-D 5
jJ. (/)~
[orrow, Defendant
1349063
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IN THE COURT OF COMMON PLEAS OF
THE 39'" JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow,
Civil Action - Law
Plaintiff,
)
)
)
)
)
)
)
No. 04-4886 Civil
vs.
Timothy P. McMorrow,
Defendant,
In Divorce a v,m.
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry of a divorce
decree:
I. Ground for divorce: irretrievable breakdown under Section 3301(c) or 330] (d)(J) of the Divorce
Code.
2, Date and manner of service of the Complaint: October 1,2004 - Certified Mail Return Receipt
Requested - Restricted Delivery.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) or 3301(d) of the
Divorce Code: by Plaintiff, January 14, 2005; by Defendant, January 14, 2005.
(b)( I) Date of execution of Plaintiff's Affidavit required by Section 330 I (d) ofthe Divorce Code:
(2) Date of filing and service of the Plaintiff's Aftidavit upon the Defendant:
Filing: ; Service:
4. Related claims pending: None;
5. Complete either (a) or (b)
(a) Date and manner of service of the Notice ofIntention to file Praecipe to Transmit Record, a copy
of which is attached:
(b) Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
January 20, 2005;
Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
January 20, 2005,
BARLEY SNYDER
By:
ft1'tAlw( ~ t-
Michael J. Connor, Esquire,
Attorney for Plaintiff
1356525
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IN THE COURT OF COMMON PLEAS
.
OF CUMBERLAND COUNTY
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STATE OF
PENNA.
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Krista A. McMorrow,
Plaintiff
No. 04-4886 Civil
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VERSUS
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Timothy P. McMorrow,
Defendant
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DECREE IN
DIVORCE
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AND NOW,
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KRISTA A. MCMORROW
, PLAINTIFF,
DECREED THAT
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AND
TIMOTHY P. MCMORROW
, DEFENDANT,
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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;
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None.
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ATTEST:
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PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF
THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Krista A. McMorrow
Civil Action - Law
Plaintiff,
vs.
Timothy P. McMorrow
No. 04-4886 Civil
Defendant,
In Divorce a v.m.
NOTICE OF ELECTION TO RETAKE MAIDEN NAME
Notice is hereby given that the Plaintiff in the above-captioned matter, having
been granted a Final Decree in divorce from the bonds of matrimony on the 8th day of
February, 2005, hereby elects to retake and hereafter use her previous name of
Krista A. Barry and gives this written notice avowing her intention in accordance with
the provisions of the Act of May 25, 1939, P.L. 192 as amended.
~
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Kris a A. McMorrow ~
To be known as:
K~rr~ ~~
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF FRANKLIN
On the I day of 7-11("-(, l<'"',~ ,2005, before me, a Notary Public,
personally appeared Krista A. McMorrow known to me to be the person whose name is
subscribed to the within document and acknowledged that she executed the foregoing
for the purpose therein contained.
SS:
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
~ ~~~t
-'4rota Publit
1365012
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