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HomeMy WebLinkAbout02-0603 Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff .~ LAURA F. YOUNGBLOOD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO.O~- fe,e>2:, CIVIL TERM CIVIL ACTION - LAW JOHN S. YOUNGBLOOD, 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 pages 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 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff LAURA F. YOUNGBLOOD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO.C:>2 - t.e.D:3 CIVIL TERM v. CIVIL ACTION - LAW JOHN S. YOUNGBLOOD, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(cl OR 3301{dl OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Laura S. Youngblood, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, John S. Youngblood: 1. The Plaintiff is Laura S. Youngblood, an adult individual, residing at 275 Crestwood Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is John S. Youngblood, an adult individual, residing at 225 North 25th Street, Camp Hill, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant were married on June 25,1988 in Dauphin County, Pennsylvania. 4. The Plaintiff and Defel1dant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce under Section 3301 (c) of the Divorce Code. JOHNSON, D~FFIE, S~ART & WEIDNER BY:~(A~ Keirsten W. Davidson :154170 VERIFICA TION I verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A 94904, relating to unsworn falsification to authorities. Date: Ib,/O?-- ! I Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff LAURA F. YOUNGBLOOD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. O~- CIVIL TERM v. CIVIL ACTION - LAW JOHN S. YOUNGBLOOD, IN DIVORCE Defendant AFFIDA V1T LAURA F. YOUNGBLOOD, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. 94904. relating to unsworn falsification to authorities. Date: / /30 If) /}--- I I ~ ~ "6<t ~ ~ ~ ~ \r- ~ C> lrt ~ '- Co ~ Dirt ~ -t I 9 0- w - C; ~~ 1- C) o ':'~.'t ~ r-.> .,... ...., -~ <-:'"1 ~~. ! 0t en ">: oL.J 2c) ::;;; ~o ~ ~..~ ~2 "",0;) z ~) ::< ~ ~- k ., Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff LAURA F. YOUNGBLOOD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 02-603 CIVIL TERM v. CIVIL ACTION - LAW JOHN S. YOUNGBLOOD, IN DIVORCE Defendant CERTIFICA TE OF SERVICE hereby certify that on the 8th day of February, 2002, I served a true and correct copy of the foregoing Complaint in Divorce upon the Defendant, John S. Youngblood, by certified mail, restricted delivery, to his mailing address at 228 North 25th Street, Apartment R - 2'd Floor, Camp Hill, Cumberland County, Pennsylvania 17011, return receipt requested, attached hereto and made a part hereof. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: ~ l L fv( nl)/f) Keirsten W. Davidson :154170 . --- U.S. Postal Service CERTIFIED MAil.. ;:;;:CEIPT (Domestic Mall Only, No Instlrance Coverage Provided) U1 ..lI clJ lJ""" U1 IT1 U1 U1 Certified Fee I Return Receipt Fee U1 ~ndorsement Required) ru C Restricted Delivery Fee t::1 (Endorsement Required) CJ Total Postage & Fees Cl ..lI Cl l:l l:l Cl .... . Complete ~ems 1, 2, and 3. Also complete ~em 411 Restricted Delivery Is desired. . Print your name and address on the reverse so that we can return the card to you. · Attach this card to the beck 01 the mall piece, or on the lront if space pennils. 1. Article-.edlo: John S. '/ou:gb1ocd A to 1 d~~ W. Q.)s4f, Srr~ ~ . Ca01P f-h II, fA 11011 . x D. delivery add.... different ff YES, enter dellwry __ 3. ~ice Type b!l Certified Mall 0 Express Mail D Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. _ed 0elivefy7 (E.>dnI Fee) Ves 2. Article Number l?P'y ~~ service label) . /1(7'/ _ '1OfYJ Q<a:.XJ CO,9.l:i 5535 ~lO5 PS Fann 3811 , July 1999 Domestic Retum Recoil>! 102595-99-M-17B9 ( ( -- ( ( \ i' -- ~ "OClJ ~9.j ~:le -:>~ ~C ~e >~ ) ) . . o N "TI rT1 CO N -J o ." :::! 'ci':Il t<Tr" -,m ,:'0 (~.s j~ :~.lC' +.''''"_-:D :;;')" ",_0 (Srn -4 J;-~ ::D :<; -0 :l: ~ I'-.;) CXl Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy J.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-603 CIVIL TERM CIVIL ACTION - LAW LAURA F. YOUNGBLOOD, v. JOHN S. YOUNGBLOOD, IN DIVORCE Defendant RETURN OF SERVICE The undersigned makes the following return of service: The Complaint in Divorce was mailed to the Defendant, John S. Youngblood, on February 8,2002 at 228 N. 25th Street, Apt. R - 2nd FI., Camp Hill, Cumberland County, Pennsylvania 17011: X A copy of the signed return receipt indicating service was completed on February 22, 2002 is attached hereto. The mail, refused and returned, is attached. A copy mailed to the Defendant at the same address by ordinary mail with the return address of the sender appearing thereon has not been returned within fifteen days after mailing. I, Melissa Peel Greevy, certify that I am a competent adult not a party to the action. I verify that the statements made in this affidavit and return of service are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: r taJtJ Ll I STEWART & WEIDNER :156579 t'" I.l1 ...lI '" lJ"' I.l1 m U"J Certified Fee I.l1 Return Receipt Felt ::::: fOfSltlT1ltnt Required) C ctsdJ)ellv.,y Fee e lllrsemem,Aeqi:lired) c ,{ bud Postall_ & Fees I:> ...lI I:> I:> C I:> r-- , 1\ I i I . COmplelellems 1, 2, and 3. Also complete !tern 4 If Restricted Delivery Is deslred. . Print your name and sddress on the reverse so thst we can return the oSfd to you. . Attach this card to the back of the msllplace, or on the front If space pennlts. 1. ArltcIeAddnlssedIo: .John :So '/our-gblcexj/;A I I d.;lS N'. as-w. Srret::.ll, p'r, j Cal11p ltill, fA 11011 ~. 3.~Ice1'ype IX Certified Moll Cl Express Mall Cl Registered a Return ReceIpt for Merchandise o Instnd Mall Cl C.O.D. 4. Restrlctod DeJlvery? (Extra Fas) Vas 2. Article Number (CQPY from service label) /1(7'1_ 5 <1rvYl diCO CO,9.S 5535::1~ UJ PS Fann 3811, July 1999 Domestic Retum Reoelpt X D. dellVBry_d~","1 If YESI enter delIVery addl'f!lSs bel 102595-99-M- 1 789 - - 0 0 0 C N .,., ;:: C- .-I -OW c: ~::D l;2~ % ".- ~~ W ~~ ~B -0 ::;:J'T' --L-:O ig :x o~ ~ z: ~ ~ U1 ~ 0 LAURA F. YOUNGBLOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-603 CIVIL TERM v. CIVIL ACTION - LAW JOHN S. YOUNGBLOOD, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on or about February 4, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. S 4904 relating to unsworn falsification to authorities. Date: 1-/1i/jl>5 :254362 (') c- ~c "I ...., ~-;;::::: C';-.> ~~,.n c___ C,,"~ \'".- N -,',"" cO' Q:) Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-603 CIVIL TERM LAURA F. YOUNGBLOOD, v. CIVIL ACTION - LAW JOHN S, YOUNGBLOOD, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on or about February 4, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. 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 above are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relat' to u worn f Is fication to authorities. Date: 1\ \ f\\ ~( \ \ lood, Plaintiff :254362-2 ","",' = C-'"? cJ' c_ c= e- N ;..",.,) CD Plaintiff IN THE OXJRT OF C<:MM(XII PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA 02-603 CIVIL TERM lAURA F. YOUNGBLOOD. NO. vs. JOHN S. YOUNGBLOOD, Defendant 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the ccxnplaint: Certified mail, restricted deli very to the Defendant on February 8, 2002 and received by Defendant on February 22, 2002 . 3. Ccxnplete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff July 19, 2005 by the defendant July 14, 2005 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 I s affidavit upon the defendant: 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record. and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code Waiver of Notice signed by Plaintiff on July 19, 2005 and filed concurrently herewi~h. Waiver of Notice signed by Defendant on July 14, Attorney for Plaintiff Atty r.D. #77950 n C, r-') Q ~ - ,. iP '-, (::;, ,- \'-" -- cr; .- cP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . -F.:f. if. ;t; . .. . ;t;:f.:+;:ti if. :t;;t; . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LAURA F. YOUN::BLCXJD, Plaintiff No. 02-603 CIVIL TERM VERSUS JOHN S. YOUNGBIDCXl, Defendant DECREE IN DIVORCE AND NOW, 1u.ty 270 2005 IT IS ORDERED AND , - , DECREED THAT lAURA F. YOUNGBIDCXl , PLAINTIFF, AND JOHN S. YOUNGBIDCXl , 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. ""HE COU''A J . c- ROTHONOTARY .. . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . # % ~ ry:"U. 5P.5et. ~;p~~ tHy pQ SObeL .