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Home My WebLink About04-5423 HAROLD S. IRWIN, III, UQUIRJ! AnGRNI!Y ID NO. 2lllI2O 84 SOUTH PITT STReET CARLISU PA 17013 (717) 2AS4OIO ATTORNI!Y FOR PLAINTIFF .JEREMY W. STANSFIELD, Plaintiff : IN THE COURT OF COMMON PLEAS OF THE : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW ; NO.2004.S3/2J (J;uLl T~ : IN DIVORCE } .JODI S. STANSFIELD, Defendant NOTICE 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 in 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 Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-243-3166 .... .JEREMY W. STANSFIELD, Plaintiff : IN THE COURT OF COMMON PLEAS OF THE : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2004 . --5-4 :2..-3 Clc.>LL~~ : IN DIVORCE I .JODI S. STANSFIELD, Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is JEREMY W. STANSFIELD, an adult individual residing at 5 Forge Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The defendant is JODI S. STANSFIELD, an adult individual residing at 331 Easy Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of Cumberland County, Pennsylvania since at least the year 2000. 4. The plaintiff and the defendant were married on October 20, 2002, in Boiling Springs, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. - - 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. October 25, 2004 .~ S~/tf/ JER::J W. STANSFIELD, Plaintiff HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243.6090 Supreme Court 10 No. 29920 JEREMY W. STANSFIELD, Plaintiff : IN THE COURT OF COMMON PLEAS OF THE : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2004. ~~ CoL.(;-r-'ifl...n-J : IN DIVORCE I JODI S. STANSFIELD, Defendant PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. October 25, 2004 7 sL.Ivz'j/ JERE;;J SiA;;KF~LD. Plaintiff () ...., ~ c: = 0 (:) = i '";:"" or- .." 'k 7)D; 0 l~ fJ rl1rn n ~i~'; -< N -or ....... . ~},,~,: CO ~~ :D ~ -..0 (} ~C'~-; " 2'C'.1 ::J;; ",..,.'C' 10 Pc: - Q ~ -0 ~ z .. ~ U'I ~ - 0 -< -1- JEREMY W. STANSFIELD, Plaintiff : IN THE COURT OF COMMON PLEAS OF THE : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION.. LAW JODI S. STANSFIELD, Defendant : NO. 2004 - 5423 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 a NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about November 1, 2004, by certified mail, addressed to the defendant at 331 Easy Road, Carlisle, PA 17013, return receipt No. 7003 3110 0004 57754160. 3. That a copy of the signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsifica ion authorities. Harold S. Irwin, III Attorney for plalintiff November 2, 2004 64 South Pitt Street Carlisle, PA 17013 717 -243-6090 Supreme Court 10 No. 29920 CJ .J] ...; ::r U.S. Postal Servicew CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) Lt'J l"- I"- Lt'J Postage $ :r CJ Certified Fee CJ CJ Retum Reclept Fee ~' orsement Required) c::J e.ttrtoted Oellvmy Fee ~ ndorsement Required) rn Total Postage & Fees $ PoIItmluk I HerEl rn c::J CJ I"- ( I ~ ~ ~ ( , (') ~~ "-(1 rq r{\(ii ;~:'. ;; :?: l" (/) ,.I-.. ....,'..... ~ t~~ 1., ~~~, f~ ~~ 'J.-'" (::: Z -1 -< ) i ,-...) ~ "X- o ...:: , N -t) ::i: N .. o ....J Q, ~-n rr\E -of'O S3~ -:(.3:\ qa Om -'-\ "1;>- ~ JEREMY W. STANSFIELD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW JODI S. STANSFIELD Defendant NO. 2004-5423 CNIL TERM AFFIDAVIT OF CONSENT (Under Section 3301(c)) 1. A complaint in divorce under Section 330l( c) of the Divorce Code was filed on October 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. Cons. Stat. Ann. ~ 4904 relating to unsworn falsification to authorities. (") C' ~:':' -0 t-~ '-:"' I' --:/' .. f',) = = 0"' <- ~ I c.Jl ~ :1: '-R o -n :2-n n" ! l.~ \...,.... ;\~ ... -" c2c") ,~:~:; rT1 '~ /': ~ w o JEREMY W. STANSFIELD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW JODI S. STANSFIELD Defendant NO. 2004-5423 CNIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER I 3301(c) AND 3301(d) 1. I consent to the entry of a final divorce decree 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 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. Jeremy W. Stansfield, Plaintiff o r; ""-.) = = 0__ c_ c::: o 11 -f mIl r- -rr lTi "rJO :-~- 3 ~;;) S~?6 ;,::s/n ~ :0 --< I CJ1 ~ .....lJ,. ~ij w o v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil ACTION - LAW JEREMY W. STANSFIELD Plaintiff JODI S. STANSFIELD Defendant NO. 2004-5423 CML TERM AFFIDAVIT OF CONSENT (Under Section 3301 (c)) 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on October 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. Cons. Stat. Ann. ~ 4904 relating to unsworn falsification to authorities. o ~ r-:> c:3 c:;:) o~ <- 52 , 0'1 o ..,., .-\ :::C-n en F" --r'"' (i1 ....' ,_.~., :'f~ ~l~\ V' :;: -,", \3; ;f~ . ::::\ '-r-~ '-:0 :.< ,-0 .' c..,.) C v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JEREMY W. STANSFIELD Plaintiff JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER I 3301 (c) AND 3301(d) 1. I consent to the entry of a final divorce decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in 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 affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.s. ~ 4904, relating to unsworn falsification to authorities. o ~ r-:l = c::) c.J"' I en o -n ---I :::J:-n nlf-=" :J~?:) :~,f~l ";:.::\ -.".""> "'0 =< ~ :;"-~,.. ~.. "!~ r,.,., o v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JEREMY W. STANSFIELD Plaintiff JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance for the defendant in the above captioned matter. Date: .:r"kof> ~I ~~ , a~~t1. Douglas C. Lovelace, Jr. Attorney for Defendant Attorney ill No. 83889 36 Donegal Drive Carlisle, Pa 17013 (717) 241-2280 o ~ -or' Q]L r-.:l = = a" <- c::: ....'.;;;0' """"..- I CJl o -n -! :L-n rllp ~:~~~; ..-' C-~: . . .~. .--">: I ~ i:~f~ ~~ dD :-< '--.9 N \..0 JEREMY W. STANSFIELD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM 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 Section 330l(c) of the Divorce Code. 2. Date and manner of service of the complaint: October 28,2004; Certified Mail 3. Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Code: by plaintiff: April 18, 2006; by defendant: April 18, 2006. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: June 5, 2006. 6. Date Defendant's Waiver of Notice was filed with the Prothonotary: June 5, 2006. ~~~4, Douglas C. Lovelace, Jr. 36 Donegal Drive Carlisle, PA 17013 Attorney Identification Number 83889 (717)385-1866 Attorney for Defendant, Jodi S. Stansfield , ~, C) " ( ::i ~, .:- ~ ~ , , ,^' -I JEREMY W. STANSFIELD, PLAINTIFF V. JODI S. STANSFIELD, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-5423 CIVil TERM ORDER OF COURT AND NOW, this 14th d Y of June, 2006, upon consideration of Defendant's Praecipe To Transmit Recor in the above-captioned case, and it appearing that the affidavits of consent of both arties were stale when filed, a divorce decree will not be I entered at this time, without rejudice to the parties' rights to correct the deficiencies and file a new praecipe to tr nsmit record. ~Old S. Irwin, III, Esquire For Plaintiff By the Court, J. ~ .A1Quglas C. lovelace, Jr., Es uire For Defendant :sal AJJ":i- OS: \ Hd ~ I \:nr quill I U\J'lC-'ii\'Ir--',.-\ 'L("<' :'l' :11 11 J,ei AO'i.j 11.......';. ,-.f~..I"" -ir1i-........- 3JU~:O-CEn\::l JEREMY W. STANSFIELD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM AFFIDAVIT OF CONSENT (Under Section 330l(c)) 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on October 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. Cons. Stat. Ann. ~ 4904 relating to unsworn falsification to authorities. Date: biz "7 /2 DOb / I w's~cI Jerem~ Stansfield, Plaintiff Cl ('U r--' c:; <.- ,j'" ~:~.:: .."- f'~~' c:> I:..' C) -n --. :L:-r, ["~I r:= -s [2.; ....,. , -':~ ,-- -,-. ""\ 9'? W CJ :::,h"'1 '::-~l >-. -- v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JEREMY W. STANSFIELD Plaintiff JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM AFFIDAVIT OF CONSENT (Under Section 3301(c)) I. A complaint in divorce under Section 330l( c) of the Divorce Code was filed on October 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. Cons. Stat. Ann. ~ 4904 relating to unsworn falsification to authorities. -:-~ i'. o c ", = C:-;J w..... >') ~1 :::l r-,,) Q eej c.,) Cl v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JEREMY W. STANSFIELD Plaintiff JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) AND 3301(d) 1. I consent to the entry of a final divorce decree 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 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 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. J '" c:;) C':,' ~, () ., ~ (..J Cl '> -.]". r:.? ", -::, >.. ':J '< (J1 ., JEREMYW. STANSFIELD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) AND 3301(d) I. I consent to the entry of a final divorce decree 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 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 affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.S. ~ 4904, relating to unsworn falsification to authorities. /,j-n /6& r I V Date: 7 Jeremy I ,.....'l ~) () , 'Tl <C~ :."? -n n'i p,;;: L.-' .~~;R Cl '"' "J ) ; ", ) N -~; \ " "-7.:( L'1 ,f~. :n ~r.:-' -< JEREMY W. STANSFIELD Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JODI S. STANSFIELD Defendant NO. 2004-5423 CIVIL TERM 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: October 28, 2004; Certified Mail 3. Date of execution of the affidavit of consent required by Section 330 I (c) of the Divorce Code: by plaintiff: April 18, 2006; reexecuted June 27, 2006; by defendant: April 18, 2006; reexecuted June 27, 2006. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: June 5, 2006 and refiled June 30, 2006. 6. Date Defendant's Waiver of Notice was filed with the Prothonotary: June 5, 2006 and refiled June 30, 2006. ~cp ~1' Douglas C. Lovelace, Jr. 36 Donegal Drive Carlisle, PA 17013 Attorney Identification Number 83889 (717) 385-1866 Attorney for Defendant, Jodi S. Stansfield t<> (:''.:J .'::::J ..':'-" ~--,) -n ._, I"T! ; Il-~- , -nf"il IC: C:._ c,:) c ,~, N ~:;~ ~n -< (J1 (.7, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JEREMY W. STANSFIELD . Plaintiff NO. 2004 - 5423 . . VERSUS JODI S. STANSFIELD . Defendant . . . . DECREE IN DIVORCE . . . 0u II 3- JEREMY W. STANSFIELD Lao'. IT IS ORDERED AND AND NOW, . . . . . DECREED THAT , PLAINTIFF, . . . AND JODI S. STANSFIELD . 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 . . ~ ,e-.:v~ 93: PROTHONOTARY . . . . . . J. . . . . _~ ~ ~ ~lt. 1<1-['(., JIrrI ~ ~ ~ -pJ ~J(l-E:''-