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HomeMy WebLinkAbout04-5202 ELIZABETH ELMORE, Plaintiff vs. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. O 4 - soZG?? l.. I t? i L,?i:2"?1 CIVIL ACTION - AT 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 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, Harrisburg, 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, PENNSYLVANIA 17013 (800) 990-9108 ELIZABETH ELMORE, Plaintiff vs. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. dLI s.2LLt, a C-) L . l CIVIL ACTION - AT LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND (d) AND NOW, comes the above captioned Plaintiff, Elizabeth Elmore, through her attorneys, The Law Offices of Patrick F. Lauer, Jr., L.L.C., and seeks to obtain a Decree in Divorce from the above named Defendant, Mark Elmore, upon the grounds hereinafter set forth: 1. Plaintiff is Elizabeth Elmore, an adult individual, who currently resides at 1306 Chatham Road, Camp Hill, Cumberland County, and State of Pennsylvania. 2. Defendant is Mark Elmore, an adult individual, who currently resides at 1306 Chatham Road, Camp Hill, Cumberland County, and State of Pennsylvania. 3. Plaintiff and Defendant have been bona He residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 11, 1982, in Newport Beach, California. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. The Plaintiff and Defendant are both Citizens of the United States of America. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. The 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. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. The parties have one minor child, Anna Elmore, born December 02, 1987. WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter a Decree in Divorce. Date: 1 C/? 0G 7 q i D. Carkciolo, Esquire 08 Market Street, Aztec Building amp Hill, Pennsylvania 170114706 IN 90919 Tel. (717) 763-1800 ELIZABETH ELMORE, Plaintiff vs. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW IN DIVORCE VERIFICATION I verify that the statements made in this Complaint for Divorce 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: /0 / Signature: Elizabeth Elmore ELIZABETH ELMORE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. MARK ELMORE, : CIVIL ACTION - AT LAW IN DIVORCE Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Divorce Complaint upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by mailing a copy of he same, certified mail, return receipt requested, to the person named as follows: Mark Elmore 1306 Chatham Road Camp Hill, PA 17025 Date: / (-/ rmt )fD. Caraciolo, Esquire Market Street, Aztec Building Hill, Pennsylvania 170114706 M# 90919 Tel. (717) 763-1800 ELIZABETH ELMORE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. MARK ELMORE, : CIVIL ACTION - AT LAW IN DIVORCE Defendant ACCEPTANCE OF SERVICE I accept service of the foregoing Complaint in Divorce. I certify that I am authorized to accept service on behalf of the above captioned defendant. Date Defendant or Authorized Agent Mailing Address d -? ADRIENNE DIMATTEO, Appellant V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- 5? F 02 e-? Appeal of Operators License Suspension APPEAL OF LICENSE SUSPENSION AND NOW comes the Appellant, Adrienne DiMatteo, by and through her attorney, Marlin L. Markley, Esquire, and respectfully avers the following: 1. Appellant resides at 821 Miller Street, Palmyra, Dauphin County, Pennsylvania 17078. 2. The underlying violation that is alleged for this suspension occurred in Cumberland County. 3. The Appellant received a notice dated November 9, 2004, that as a result of his alleged violation of Pennsylvania Crimes Code Section 6308, offenses related to alcohol, her driving privilege was being suspended for a period of two years, effective suspension date November 18, 2005, at 12:01 a.m. A true and correct copy of the Notice is attached as Exhibit "A". 3. The Appellant filed a Summary Criminal Conviction Appeal before your Honorable Court on November 18, 2004 regarding her conviction on October 19, 2004. 4. The Appellant submits that there has not been a final disposition of her appeal and that she would be unduly prejudiced if the suspension were to be imposed at this time. 5. There was insufficient evidence to convict the Appellant. 6. The Appellant denies she committed the offense. WHEREFORE, your Appellant respectfully requests your Honorable Court to schedule an evidentiary hearing on the matter and to reverse the Department's Order to suspend his Pennsylvania operating privileges. Respectfully submitted, l arli Mark-kgy, Esquire 210 M rket Street, Aztec Building Camp H 11, Pennsylvania 17011-4706 Date: ID# 84745 Tel. (717) 763-1800 I / COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: NOVEMBER 09, 2004 ADRIENNE DIMATTEO WID # 043076122385258 001 821 MILLER ST PROCESSING DATE 11/02/2004 DRIVER LICENSE # 26996980 PALMYRA PA 17078 DATE OF BIRTH 07/16/1984 Dear MS. DIMATTEO: As a result of your violation on 09/25/2004 of violating Section 6308 (offenses related to alcohol), your dri?ng privilege is being SUSPENDED for a period of 2YEAR(S) !as mandated by section 1532D of the vehicle code. The effective date of suspension is 11/18/2005, 12:01 a.*. This suspension is in addition to any other suspensions already on your record. COMPLYING WITH THIS SUSPENSION You must return all current Pennsylvania driver's licenses, learner's permits, temporary driver's licenses (camera cards) in your possession on or before 11/18/2004. You may surrender these items before, 11/18/2004, for ear 'mer credit; however, you may not drive after the a items e surrendered. - YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR I TIFIC PURPOSES. However, you may apply for and obtain a photo identification card at any Driver License Center for a cost of *10.00. You must present two (2) forms of proper identification (e.g., birth certificate, valid U.S. Passport, marriage certificate, etc.) in order to obtain your photo identification card. You will not receive credit toward serving any suspension until we receive your license(s). Complete the following steps to acknowledge this suspension. 1. Return all current Pennsylvania driver's licenses, learner's permits and/or camera cards to PennDOT. If you do,no-t have any of these items, send a sworn notarized letter stating you are aware of the suspension of your driving privilege. You must specify in your letter why you are unable to return Your driver's license. Remember: You may not retain your driver's 043076122385258 license for identification purposes. Please send these items to: Pennsylvania Department of Transportation Bureau of Driver Licensing P.O. Box 68693 Harrisburg, PA 17106-8693 2. Upon receipt, review and acceptance of your Pennsylvania driver's license(s), learner's permit(s), and/or a sworn notarized letter, PennDOT will send you a receipt confirming the date that credit began. If you do not receive a receipt from us within 3 weeks, please contact our office. Otherwise, you will not be given credit toward serving this suspension. PennDOT phone numbers are listed at the end of this letter. 3. If you 'do not return all current driver license products, we must refer this matter to the Pennsylvania State Police for prosecution under SECTION 1571(a)(4) of the Pennsylvania Vehicle Code. PROVIDING PROOF OF INSURANCE Within the last 30 days of your suspension/revocation, we will send you a letter asking that you provide proof of insurance at that time. This letter will list acceptable documents and what will be needed if you do not own a vehicle registered in Pennsylvania. IMPORTANT: Please make sure that PennDOT is notified if you move from your current address. You may notify PennDOT of your address change by calling any of the phone numbers Aio_ listed at the end of this letter. APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, NOVEMBER 09, 2004, of this letter. if you file an appeal in the County Court, the Court will give you a time-stamped certified copy of the appeal. In order for your appeal to be valid, you must send this time-stamped certified copy of the appeal by certified mail to: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 Remember, this is an OFFICIAL NOTICE OF SUSPENSION. You must return all current Pennsylvania driver license products to PennDOT by 11/18/2004. 043076122385258 Sincerely, GAQ.C? s,. Rebecca L. Bickley, Director Bureau of Driver Licensing INFORMATION 7:00 a.m. to 9:00 p.m. IN STATE 1-800-932-4600 TOD IN STATE 1-800-228-0676 OUT-OF-STATE 717-391-6190 TOO OUT-OF-STATE 717-391-6191 WEB SITE ADDRESS www.dmv.state.pa.us ADRIENNE DIMATTEO, Appellant V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . NO. Appeal of Operators License Suspension ATTORNEY VERIFICATION I, Marlin L. Markley, Esquire, undersigned counsel for Appellant, Adrienne DiMatteo, hereby verifies and states that: 1. I am the attorney for Appellant, Adrienne DiMatteo; 2. I am authorized to make this verification on my client's behalf; 3. The facts set forth in the foregoing Appeal are known to me and not necessarily to my client; 4. The facts set forth in the foregoing Appeal are true and correct to the best of my knowledge, information and belief; and 5. I am aware that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Respectfully submitted, ar L. M t ey, Esquire 21 8 arket Street, Aztec Building 1l l, ?O¢ Cam Hill, Pennsylvania 17011-4706 Date: ID# 84745 Tel. (717) 763-1800 ADRIENNE DIMATTEO, Appellant V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. Appeal of Operators License Suspension CERTIFICATE OF SERVICE I hereby certify that I am serving a copy of the foregoing Appeal upon opposing counsel by depositing a copy of the same in the United States Mail, Camp Hill, Pennsylvania, through first class mail, certified, return receipt requested, postage paid and addressed as follows: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104 Date: //- /A a OO 4- Respectfully submitted, arl Markley, Esquire 2108' M eet Street, Aztec Building Camp 11, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 " t i ELIZABETH ELMORE, Plaintiff/Respondent vs. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-5202 Civil Term CIVIL ACTION - AT LAW IN DIVORCE TO THE HONORABLE JUDGES OF SAID COURT: AND NOW, comes Petitioner, Joseph D. Caraciolo, Esquire, and in support of his Petition to Withdraw Appearance, respectfully represents as follows: Petitioner is Joseph D. Caraciolo, Esquire, an attorney with offices located at 112 Market Street, 6m Floor, Harrisburg, Pennsylvania and formerly of the Law Offices of Patrick F. Lauer, Jr., LLC, located at 2108 Market Street, Camp Hill, Pennsylvania. 2. Respondent, Elizabeth Elmore resides at 1306 Chatham Road, Camp Hill, Pennsylvania. 3. Petitioner was retained by Respondent on or about October 7, 2004, to represent her in connection with the filing of a divorce complaint. 4. A Complaint in Divorce was filed with this Honorable Court on or about October 18, 2004 thereby instituting the above-captioned action. 5. Petitioner anticipates that there will be prolonged proceedings in the above matters. 6. On or about March 16, 2006 Petitioner's former secretary, Shelby Nelson, was advised by Respondent that Petitioner and the Law Offices of Patrick F. Lauer, Jr., LLC are to cease providing legal services to Respondent. 7. Petitioner has at all times attempted to represent Respondent effectively and vigorously to the best of his ability. 8. Petitioner asks to withdraw his appearance for Elizabeth Elmore because, inter alia: a. Respondent has requested that Petitioner terminate all further legal services regarding Respondent's case. b. Continued representation will result in an unreasonable financial burden on Petitioner. WHEREFORE, Petitioner respectfully requests that his appearance be withdrawn for Respondent and that he and the Law Offices of Patrick F. Lauer, Jr., LLC, be removed from the docket as the attorney of record for Elizabeth Elmore. ??A/12 Market Street, 6" Floor G' Harrisburg, Pennsylvania 17101-2015 ID# 90919 Tel. (717) 236-9391 Attorney for Plaintiff Date: 0 ? 7 ? ELIZABETH ELMORE, Plaintiff/Respondent vs. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-5202 Civil Term CIVIL ACTION - AT LAW IN DIVORCE I, Joseph D. Caraciolo, verify that the statements made in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 3 o r IAIL U Josep - Caraciol ELIZABETH ELMORE, Plaintiff/Respondent VS. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-5202 Civil Term CIVIL ACTION - AT LAW IN DIVORCE I, Joseph D. Caraciolo, Esquire, hereby certify that on the below-noted date I served the foregoing Petition to Withdraw Appearance by depositing a true and exact copy thereof in the United States Mail, first class, postage prepaid, addressed as follows: Elizabeth Elmore 1306 Chatham Road Camp Hill, PA 17011 John M. Glace, Esquire 132-134 Walnut Street Harrisburg, PA 17101-1612 Respectfully Submitted: Joseph p. Caraciolo, Esquire 112 Market Street, 6m Floor "Harrisburg, Pennsylvania 17101-2015 ID# 90919 Tel. (717) 236-9391 Attorney for Plaintiff i Dater ?? o? ?% ?' ^fi ?... ? _'1.' - ji1T f"V ?6 •,J fti' ,} `. _! ? ?1 ??? J ELIZABETH ELMORE, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-5202 Civil Term MARK ELMORE, : CIVIL ACTION - AT LAW IN DIVORCE Defendant AND NOW, this 30 il.. day of _-INN RC !{ , 2006, upon consideration of the foregoing Petition to Withdraw Appearance of Petitioner, Joseph D. Caraciolo, Esquire, and the Law Offices of Patrick F. Lauer, Jr., LLC, it is hereby ORDERED AND DECREED that Joseph D. Caraciolo, Esquire, and the Law Offices of Patrick F. Lauer, Jr., LLC, are permitted to withdraw as counsel for Respondent, Elizabeth Elmore. BY THE COURT -'?k 7t U4-1 h ?? - ,,; ?',:7 ;? ?_ nw ???'?1 ?i;i}; ?c, ;.._ t: ._ . ??. ? _, i ?j ., i,_ ELIZABETH ELMORE, Plaintiff/Respondent vs. MARK ELMORE, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-5202 Civil Term CIVIL ACTION - AT LAW IN DIVORCE Kindly withdraw my appearance and the Law Offices of Patrick F. Lauer, Jr., LLC, on behalf of Elizabeth Elmore, the Plaintiff in the above-captioned matter. Respectfully su"bmitted, Joseph Caraciolo, Esquire 112 Market Street, 6`h Floor v Harrisburg, Pennsylvania 17101-2015 Date: 0311710 (? ID# 90919 Tel. (717) 236-9391 < .: , '?,. 9. ?' (?:J ELIZABETH ELMORE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. Q -' S 2 ?it V ; T-Qltr? MARK ELMORE, : CIVIL, ACTION - AT LAW IN DIVORCE Defendant ACCEPTANCE OF SERVICE I accept service of the foregoing Complaint in Divorce. I certify that I am authorized to accept service on behalf of the above captioned defendant. ' D D GL kDefendant or Authorized Agent I Mailing Address flown 1 waft 2 for add Lionel mw iees. e e items 3, 4a, and 4b. ¦ Print your name and address on the reverse of We form so that we can return this card to you. ¦Attach this form to the front of the meioece, or on the back H spaos does not pwn*• ¦ Writs Retum Remo Roquefter on ft mailoos below the adide nwnber. ¦The Rstum Receipt will show to whom the article was delivered wd the date delivered. 6t &, k' L-, ( m r? , ?3& l? I adso wish to receive the foNowing services (tor an extra fee): 1. V)Wressee's Address 2. postrnagw for ies. I M ArM- a Ni tn*mr 7002 1000 0005 0082 3813 3 t 4b. Service ype ? Registered ? Express Mail ? Insured ? Retian Receipt for Mwdw dise ? COD T.: B. Addressee's Address (Only ff requested and fee is paid) 044 PS Form W 1, Deonnbei 1025W974"179 ra ?? ?? ? ?? ? ?? -?,. :?-. -,-: ?? '? -? c } ,, ,,??. ???? ? ?. . -? ?.. , ELIZABETH ELMORE, Plaintiff vs. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04-5202 CIVIL ACTION -LAW DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 18, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 4. 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: ?a y l°, Signature: Elizabeth Elmore ?^'' t ? ..? w ?"-?. ? ??` ?r7 '??? r ? ? ? _ ? r , €; ?? ? ? ?? ? ?? _? ' J ELIZABETH ELMORE, Plaintiff VS. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 04-5202 CIVIL ACTION - LAW DIVORCE PLAINTIFF'S 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. 4. 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. Dated: 1 jyl Signature: Elizabeth Elmore C? ?? r.'. ?.. .--' ..-t «1'? ~j;?1 .... S e.:. "?. m?' .- ` ? ? ? ? ? ?` ? -,?' ` = ELIZABETH ELMORE, Plaintiff VS. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04-5202 CIVIL ACTION -LAW DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 18, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 4. 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. Date1z' ' Signature: Mark Elmore fT, ELIZABETH ELMORE, Plaintiff VS. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 04-5202 CIVIL ACTION -LAW DIVORCE DEFENDANT'S 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. 4. 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 unworn falsification to authorities. Dated: ` Signature:Lj,k, k Elmore r ?.. ? F,.?, •? ? ? ??i ? `r i 5 r ??;? - ? '1 ? ,.3 t?; k.? , .?tl ' r ? .? - ?.Y ? k ? i? ? ^ ELIZABETH ELMORE, Plaintiff VS. MARK ELMORE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 04-5202 : CIVIL ACTION -LAW DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Service by personal acceptance by defendant on October 20, 2005. See Acceptance of Service filed with the Prothonotary simultaneously with this Praecipe to Transmit Record. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by the Plaintiff: a7 ;by the Defendant Idf ls' . 4. Related claims pending: None. 5. Date Plaintiff s Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: filed simultaneously with this Praecipe to Transmit Record. Date Defendant's Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: filed simultaneously with this Praecipe to Transmit Record. RESPECTFULLY SUBMITTED: DATE: l I G GBY: Eliza eth Elmore 1306 Chatham Road Camp Hill, P A 17011 Telephone: (717) 975-2032 `?,? ? © -a ? ?? ' '. ? L.f % .? _ ' : i ?.? 1 ?s. ? ? T f$7 j ' y+4J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. fi z a h e r? VERSUS 'AAir DECREE I N DIVORCE AND NOW, 1k , 1W7 , IT IS ORDERED AND DECREED THAT 61(eZ0-' e4 k cYkv-0 f--e-- , PLAINTIFF, AND t" 4 ('4-- ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,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; IvUll e ral'' Z 4 BY THE COURT: ?u ?- ? ? A ATTEST: J. 14 PROTHONOTARY No. - ?-a0")- Co . ?7- ell