HomeMy WebLinkAbout04-5507
II
MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. ()<{ -56'67
CIVIL TERM
DAVID NEIL STONER,
Defendant
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 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, PA 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, PA 17013-3302
Telephone: (717) 249-3166
11
I fL\div\STOrERmegan-complaint
MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 04- S'S"G1 C~u~(
DAVID NEIL STONER,
Defendant
CIVIL ACTION LAW
IN DIVORCE
l~
COMPLAINT UNDER ~3301(c) OR ~3301(d)
OF THE DIVORCE CODE
1. The Plaintiff in this action is MEGAN LOUISE STONER, an adult
individual, who currently resides at 201 North Walnut Street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant in this action is DAVID NEIL STONER, an adult
individual, who currently resides at 411 South High Street, Apt. 1,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Both the Plaintiff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage
on May 12, 2001, in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
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6. The Plaintiff avers as the grounds upon which this action is
based is that the marriage between the parties hereto is irretrievably
broken.
7. The Plaintiff avers that one child has been born of this
marriage.
8. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of
divorce.
COUNT I - CUSTODY
10. Paragraphs one (I) through nine (9) are incorporated herein
by reference as though fully set forth at length.
11. The Plaintiff in this action is MEGAN LOUISE STONER, an
adult individual, who currently resides at 201 North Walnut Street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
12. The Defendant in this action is DAVID NEIL STONER, an adult
individual, who currently resides at 411 South High Street, Apartment
#1, Mechanicsburg, Cumberland County, Pennsylvania 17013.
13. Plaintiff seeks primary physical custody of IZACC MICHAEL
ANDREW STONER, who resides with his mother, the Plaintiff, at 201
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North Walnut Street, Mechanicsburg, Cumberland County, Pennsylvania
17055, and is three (3) years of age having been born on August 30,
2001. The child was not born out of wedlock.
The child is presently in the custody of his mother, the
Plaintiff above-named.
The Plaintiff seeks majority physical custody of the child.
Plaintiff agrees to shared legal custody of the minor child with the
Defendant enjoying partial physical custody.
During the past three (3) years, the child has resided with the
following persons and at the following addresses:
NAME
ADDRESS
DATES
Plaintiff & Defendant
201 N. Walnut St.
Mechanicsburg, PA
7/2004- present
same as above
330 S. Washington Street
Mechanicsburg, PA
6/02-7/04
same as above
125 North 17th Street
Camp Hill, PA
6/01 - 6/02
The mother of the child is the Plaintiff, Megan Louise Stoner,
currently residing at 201 North Walnut Street, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
The father of the child is the Defendant, David Neil Stoner, who
currently resides at 411 South High Street, Apartment #1,
Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married
to the Plaintiff.
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20. The relationship of Plaintiff to the child is that of
mother. The Plaintiff currently resides with the following persons:
NAME
Subject Minor child
RELATIONSHIP
Son
21. The relationship of Defendant to the child is that of
father. The Defendant currently resides with the following persons:
NAME
Alone
RELATIONSHIP
22. Plaintiff has not participated as a party or witness, or in
another capacity, in other litigation concerning the custody of the
child in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child pending in a Court of this Commonwealth.
Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the minor child or claims to
have custody or visitation rights with respect to the child.
23. The best interest and permanent welfare of the minor child
will be served by granting the relief requested because:
A. The child has resided with his father and mother since
birth who have provided a continuous living relationship with the
child;
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B. The mother is able to provide a stable home and extended
family environment for the child allowing the child opportunity to
spend time with the child's father consistent with a schedule the
parties have arranged between themselves;
24. Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the child has
been named as parties to this action.
WHEREFORE, Plaintiff respectfully requests that this Court grant
the Plaintiff majority physical custody of the child with shared legal
custody to the Defendant, giving the Defendant partial physical
custody.
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 P.C.S.
54904, relating to unsworn falsification
'r}/JDOC/AIl ~J1A(/11mtr
~~~ LOUISE STONER
/
STONE LaFA~HEKLETSKI
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to authorities.
Dated: \ \ - l -0 i
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MEGAN LOUISE STONER,
Plaintiff
v.
DAVID NEIL STONER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-5507 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF CUMBERLAND )
I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys
for the plaintiff hereby certify that I served the Complaint in
Divorce in the above captioned matter on the defendant, DAVID NEIL
STONER, at 411 South High Street, Apt. 1, Mechanicsburg, PA 17055, by
United States Certified Mail, postage prepaid, restricted delivery, on
November 5, 2004, as evidenced by the attached Certified Mail return
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receipts.
CO~''10NWEAlTH OF PENNsYLVANIA
I NOTARIAL SEAL
KAYE R.LUCKEY, Notary Public
~ew Cum~erlalld Boro. Cumberland Co
Y Commission Expires March ~!, 2005
SWORN TO AND SUB~~RIBED
beff~e me this ~ day
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MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 04-5507 CIVIL TERM
DAVID NEIL STONER,
Defendant
CIVIL ACTION
IN DIVORCE
LAW
MOTION TO INCORPORATE AGREEMENT
INTO CUSTODY ACTION
Megan Louise Stoner, plaintiff in the above action, by and
through her attorneys, STONE LaFAVER & SHEKLETSKI, moves that your
Honorable Court incorporate the attached Custody Agreement for Minor
Child dated January 18, 2005, into the above captioned action as an
Order of Court,
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STONE LaFAVER ,t S
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CUSTODY AGREEMENT FOR MINOR CHILD
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~ This custody agreement is entered into this -4lL-- day of
UI\tUJ , 2005, between Megan Louise Stoner, hereinafter
re erred t as the "Mother" and, David Neil Stoner, hereinafter
referred to as the "Father",
WIT N E SSE T H:
WHEREAS, the parties herein desire to set their intentions
with respect to custody of their minor child, Izacc Michael
Andrew, in writing,
WHEREAS, one child was born of this relationship, a minor
male child, Izacc Michael Andrew Stoner, born August 30, 2001;
WHEREAS, it is the desire of the parties hereto to formalize
their agreement with respect to the said minor child when he
resides with them;
AND NOW THEREFORE, the parties hereto intending to be
legally bound hereby do agree that:
1. Both Mother and Father shall share legal custody of the
minor child.
2, The Mother shall have primary physical custody of the
minor child subject to Father's liberal visitation rights.
3, It is the intention of the parties that the minor child
shall spend time with each parent according to a schedule,
Further, the parents believe that this is in the best interests
and that this type of schedule fulfills the child's needs with
regard appropriate and adequate time with each parent. Moreover,
if this schedule does not prove to benefit the minor child, both
parties agree to modify this schedule so as to always benefit the
child and place his needs first.
4. The schedule for custody shall be as follows:
1.
until 8 p,m.
Father shall have the child on Sundays from noon
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2, Father shall have the child every Wednesday or any
other day of the week if Wednesday is not the Father's day off,
as the parties agree. This visitation will be from 7 a,m. until
bedtime at 8 p,m. Father agrees at this time to do the
transportation on Wednesdays and Sundays, There will be no less
than one day of week of all day visitation with Father.
(D) Holidays - following shall be rotated every other
year between the parties:
(1) Thanksgiving, Christmas, New Year's Eve, New
Year's Day, Memorial Day, July 4th, Labor Day.
(2) For the extended Christmas holiday vacations
the parties shall rotate or divide up these days as they may
agree.
(E) Mother shall have custody on Mother's Day and
Father shall have custody on Father's Day,
5, Each party shall be entitled to not less than two weeks
vacation in the summer. These weeks do not need to be taken
consecutively, but if the weeks are to be taken consecutively,
the requesting party shall notify the other parent at least 60
days in advance,
6, Both parties agree to consult one another whenever a
life decision is necessary with regard to the minor child, Life
decisions affect medical, dental, orthodontia, religious, or
moral decisions. Both parties agree to consult with one another
whenever prudent,
7, Both parties agree that they shall always provide the
other party with address, phone number, and or vacation location,
when necessary. In the event that either party wishes to take
the child out-of-state for a vacation/trip, that parent agrees to
furnish to the other party a phone number, location address and
emergency contact number prior to twenty-four hours of departure,
8, Both parties agree to be as flexible as possible,
whenever possible, and to always place the best interest of their
child first,
9, The Father agrees to carry the child on his health
coverage as long as his employer assumes the cost for health
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benefits, If the Father's employer no longer pays for family
health coverage, each party agrees to maintain the child on their
health coverage.
10. Both parties agree to share the costs associated with
the child's before and after school care and summer daycare.
11, Both parties agree to share the costs associated with
the child's college education.
12. All unreimbursed medical bills, including, but not
limited to, orthodontia, chiropractic, dental, and vision will be
shared equally by the parties,
13. No waiver or modification of any of the terms of this
agreement shall be valid unless in writing and signed by both
parties and no waiver of any breach hereof or default hereunder
shall be deemed a waiver of any subsequent default of the same or
similar nature, This agreement may be modified by court order,
14. This agreement shall be construed in accordance with
the laws of the Commonwealth of Pennsylvania which are in effect
as of the date of the execution of this agreement, Moreover, the
parties hereby agree that the provisions of this agreement shall
be entered as a custody order in the Court of Common Pleas of
Cumberland County, Pennsylvania,
15, This agreement constitutes the entire understanding of
the parties regarding custody and supersedes any and all prior
agreements and negotiations between them. There are no
representations or warranties regarding custody other than those
expressly set forth herein,
16, If any term, condition, clause, section, or provision
of this agreement shall be determined or declared to be void or
invalid in law or otherwise, only that term, condition, clause,
section, or provision shall be stricken from this agreement, and
in all other respects, this agreement shall be valid and continue
in full force, effect, and operation, Likewise, the failure of
any party to meet his or her obligations under anyone or more of
the articles and sections herein shall in no way void or alter
the remaining obligations of the parties.
17. In the event either party to this agreement shall
breach any term, covenant or other obligation herein, the non-
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breaching party shall be entitled, in addition to all other
remedies available at law or in equity, to recover from the
breaching party all costs which the non-breaching party may incur
including, but not limited to, filing fees and reasonable
attorney's fees, in any action or proceeding to enforce the terms
of this agreement,
IN WITNESS WHEREOF, the parties hereto intending to be
legally bound have set their hands and seals on the date first
above written,
WITNESS
j;ur/;r~~_
David Neil S ner(SEAL)
WITNESS
Dated:
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF
Megan Louise Stoner , being duly sworn according to law,
deposes and says that she is a party named in the foregoing
Custody Agreement for Minor Child and that she has executed the
same for the purposes therein contained,
U'L..--'"
Louise Stoner
SWORN TO AND SUBSCRIBED
before me this IJ'li'- day
of ,If, (}Vt~V0 ' 2005,
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Notary Pu 1
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
KATHLEEN KEIM, Notary Public
New Cumberland Bora, Cumberland Co,
My Commission ExplrllS Dee, 5. 2006
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF
David Neil Stoner, being duly sworn according to law,
deposes and says that he is a party named in the foregoing
Custody Agreement for Minor Child and that he has executed the
same for the purposes therein contained, ~
~~
David Nei Stoner
SWORN TO AND SUB~BED
before e this I day
of If 05.
(
Notary
COMMONWEALTH Of PENNSYLVANIA
NOTARIAL SEAL
KAniLEEN KEIM, Notary Public
New Cumberland Bom. Cumberland Co.
My Commission Expires Dec. 5, 2006
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,JAN 2 7 2005:i
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MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 04-5507 CIVIL TERM
DAVID NEIL STONER,
Defendant
CIVIL ACTION
IN DIVORCE
LAW
ORDER
AND NOW, this ~ day of ~t..-(
, 2005, upon
~
consideration of the foregoing motion, the Custody Agreement for Minor
Child between the parties dated January 18, 2005, and attached hereto
is hereby incorporated into the above captioned action and made an
Order of Court,
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BY THE
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fl\div\STONERconsentaffidavit
MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 04-5507
DAVID NEIL STONER,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1, A complaint in divorce under g 330l(c) of the Divorce Code
was filed on November I, 2004, and served upon the Defendant on
November 5, 2004,
2, The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed f~om the date of filing the
complaint 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 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. C,S. g 4904 relating to unsworn falsifica-
tion to authorities.
UGf\Ji[Vv\ \ \ . doDS
Date
. rVl112j Ilt) ~L,1/Jl J!rUcy'--
~JISE STONER, Plaintiff
--
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fl\div\STONERconsentaffidavit
MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 04-5507
DAVID NEIL STONER,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1, A complaint in divorce under 5 3301(c) of the Divorce Code
was filed on November 1, 2004, and served upon the Defendant on
November 5, 2004.
2, The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing the
complaint 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 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 Fa. C,S, 5 4904 relating to unsworn falsi fica-
tion to authorities,
-----'
t-t~yI!tttO H, doOS
Date
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DAVID NEIL STONER, Defendant
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fl\div\STONERwaiverofnotice
MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 04-5507
DAVID NEIL STONER,
Defendant
CIVIL ACTION LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER ~ 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 wil:h the Prothonotary.
I verify that the statements made in this affidavit are true and
correct. T understand that fa l.se stat.ement.s herein are made subj eel:
to the penalties of 18 Pa, C,S. ~ 4904 relating to unsworn falsifica-
tion to authorities.
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LOUISE STONER, Plaintiff
fi~{\.l(la \I, JCV\
Date ,
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fl\div\STONERwaiverofnotice
MEGAN LOUISE STONER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 04-5507
DAVID NEIL STONER,
Defendant
CIVIL ACTION LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER ~ 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 righ.ts 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. S 4904 relating to unsworn falsifica-
tion to authorities,
ILl J1( )tt;;J
DAVID NEIL ST0NER, Defendant
~\I( v\Cf 1/ 000C:;
Date I
:
MEGAN LOUISE STONER, : IN THE COURT OF COMMON PLEAS
Plaintiff :
: CUMBERLAND COUNTY, PENNSYLVANIA
:
VS. : CIVIL DIVISION
:
DAVID NEIL STONER, : NO. 04-5507 CIVIL TERM
Defendant : CIVIL ACTION - LAW IN DIVORCE
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. Ground for divorce: irretrievable breakdow1 under S3301(c)
ii{~till>> of th~ Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the cOlnplaint: November 5. 2004,
Certified Mail Return Receipt
3. COlllplete either paragraph (a) or (b)..
(a) Pate of execution of the affidavit of consent required
by S3301(c) of the Divorce Code: by plaintiff February 11. 2005
by defendant February 11, 2005
(b)( 1) Date of execution of the affidavit required by Sn01(d)
of the Divorce Code: ; (2) Date of filing and
service of the plaintiff's affidavit upon the r~spondent:
4. Related claims pending:
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to
file praecipe to transmit record, a copy of whi.ch is attached:
(b) Date plaintiff's
filed with the Prothonotary:
Date defendant's
filed with the Prothonotary:
waiver of Notice in 53301(c) Divorce was
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Waiver of Notice in
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S;J301( c)
Divorce was
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
MEGAN LOUISE STONER,
PEN NA.
STATE OF
Plaintiff
No, 04-5507
VERSUS
DAVID NEIL STONER,
Defendant
DECREE IN
DIVORCE
NOW'~ ,
---
~,ITIS
AND
ORDERED AND
MEGAN LOUISE STONER
DECREED THAT
. PLAINTIFF,
DAVID NEIL STONER
AND
. DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE
BEEN RAISED OF RECO~ID r\ THIS ACTION FOR
YET BEEN ENTERED; \.jt()~
FOLLOWING CLAIMS WHICH HAVE
WHICH A FINAL ORDER HAS NOT
--
/
ATTEST: J.
~~ PRO,HORO,AP'
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