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Home My WebLink About02-0586SHARON L. ALLEN, Plaintiff PATRICK J. ALLEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- ~,f6 CIVIL TERM : : CIVIL ACTION - 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 ground 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 Franklin County Courthouse, 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. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association 100 South Street, P.O. Box 186 Harrisburg, PA 17108 (800) 692-7375 SHARON L. ALLEN, Plaintiff PATRICK J. ALLEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- ~oe6 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Sharon L. Allen, through her attomey, Thomas S. DieM, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Sharon L. Allen, is an adult individual who currently resides at 3849 Crottlestown Road, Chambersburg, Franklin County, Pennsylvania 17201. 2. The Defendant, Patrick J. Allen, is an adult individual who currently resides at Falling Spring Nursing & Rehabilitation Center, 201 Franklin Fcam Lane, Chambersburg, Franklin County, Pennsylvania 17201. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on April 18, 1984 in Washington County, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaimiff, Sharon L. Allen, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Date: Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. :~H'~R,,ON~. ~LLEN, Pla~nt~-ff :JIZ~ LAW OFFICES OF MISLITSKY AND DIEHL ONE WEST HIGH STREET, SUITE 208 CARLISLE, PENNSYLVANIA ~ 7013 TELEPHONE (717) 240"O833 FAX (717) 240-O893 SHARON L. ALLEN, Plaintiff PATRICK J. ALLEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-586 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please reinstate the above-captioned case for the purpose of securing service upon the Defendant. Date: April 4, 2002 Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX SHARON L. ALLEN, Plaintiff PATRICK J. ALLEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-586 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Kimberly L. Hough, an adult individual, hereby certify that a Complaint in Divorce was served upon the above-captioned Defendant, Patrick J. Allen, by delivering said copy to the receptionist, Donna Yeager, of Falling Spring Nursing & Rahab Center, located at 201 Franklin Farm Lane, Chambersburg, Pennsylvania on April 4, 2002 at approximately 3:20 p.m. in the afternoon, in accordance with Pa.C.R.P. 1930.4 (a)(2)(ii) DATE: April 18, 2002 BK~b e~. ]4o ugh, ~e ~a,l'A ~s/i~ant Law Offices of Thomas S. Dt'ehl One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 SHARON L. ALLEN, Plaintiff PATRICK J. ALLEN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P~NNSYLV,~NIA. NO. 2002-586 CIVIL CIVIL ACTION - LAW ~ DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on February 4, 2002. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unsworn falsification to authorities. Date.~~ '~, ~tSt~ WAIVER OF NOTICE OF INTENTIO~TO ~ DECREE UNDER §3301(c) OF TH ~aCK/~/[/L~//rfenda~t/ ~X E~pF A DIVORCE I consent to the entw of a Final Decree in 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 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. § 4909 relating to unswom falsification to authorities. ALL~D'~eh~ant