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Home My WebLink About04-5526 o~ Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ No. {)Lf - . ~ 1~ Civil Term WENDY 1. TRACE, vs. STEVEN E. TRACE, : ACTION 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 papers by the Plaintiff, You may lose money or property or other rights important to you, including custody or visitation of your children. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 8t. Carlisle, Pa. 17013 (717) 249~3166 ORIGINAL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA WENDY J. TRACE, vs, : No. Of.{ ~ S.{:U.~ Civil Term STEVEN E. TRACE, Defendant : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Wendy J. Trace, a competent adult individual, who has resided at 297 Bonnybrook Road, Carlisle, Cumberland County, Pennsylvania, 17013, since 1992. 2, Defendant is Steven E. Trace, a competent adult individual, who has resided at 297 Bonnybrook Road, Carlisle, Cumberland County, Pennsylvania since 1992, 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 22, 1981 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10, The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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 Pa.C.S. ~4904 relating to unsworn falsification to authorities. uQ.~ Wendy J. Tr~e~aintiff Date: /QI;l.~ loy Respectfully submitted, O~(YJ~ ~n Adams, Esquire I. . No, 79465 . b South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF e~ -- ::j D- ~, 0J -, ~ c ~ .,.. , . I . ~ -~ a>r,: ti~~-; ~~.~~ -/ ~ ~ ~ c::::> i ~fi! ..c: "'0 ~ ~ ~b :-c31 ~~~ S\ ~ ::.<: Q s:,;; -0 :E- N ., o (J1 WENDY J. TRACE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COill'lJ"TY, PENNSYLVANIA vs, : No. 04 - 5526 Civil Term STEVEN E. TRACE, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE. AND NOW, this November 30, 2004, I, Jane Adams, Esquire, hereby certify that on November 22, 2004, a certified true copy ofthe Notice to D(~fend and Divorce Complaint was served, via certified mail, return receipt requested, addressed to: . at'~. . 1.~N.tllfl..frfix 0J . - .,...,....... ~e,.'.~' .. dm~.~. ~l~)~ J70 ~ Steven E. Trace 297 BonnyBrook Road Carlisle, Pa. 17013 DEFENDANT 2. ...,...... 7003 ..- Adams, Esquire LD No. 79465 3 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF o C ::-jIoI' .....,..... ~ .~~.. r""'-:;C:,.:r ~w ,:<U .,t>> ~f3 z :.< "-> = co .....- o ., ::;:l fii::D -or,; ~l?9 ~o ;z:..: :ri ;:~("5 (31T1 ~i5 -< :z: C> < W o -0 :J: N ., (..J1 CD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WENDY J. TRACE, VS. No. 04 - 5526 Civil Term STEVEN E. TRACE, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on November 2,2004. 2. The marriage of 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 fmal decree of divorce after service of notice of intention to request entry of the decree. [ verify that the statements made in this affidavit are troe and correct. [also understand that false statements herein are made subject to the penalties of [8 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~ll \Olo ~~2. /-e-_ Steven E. Trace, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 6330Hc) AND 63301ld) OF THE DIVORCE CODE 1. [consent to entry of a fmal decree of divorce without notice. 2. I uraderstand that I may lose rights concerning aHmony, division of property, lawyer's fees or expenses if] do not claim them before a divorce is granted. 3. [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 tiled 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. ~904 relating to unsworn falsification to authorities. Date: ~ \ \ tD'o ~2/~ ven E. Trace, Defendant ~ ( Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WENDY J. TRACE, vs. No. 04 - 5526 Civil Term STEVEN E. TRACE, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 2, 2004. 2. The marriage of 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 fmal 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 true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: q . I L . 0 '" ~~l-- Wendy . , Plamtlff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER S330He) AND 6330Hd) OF THE DIVORCE CODE 1. I consent to entry of a fmal 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 wiIl 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. Date: q. I?- - OC:, o c: ';:'~~ .'~. ,..., = = "" ,,.., ... v o ""Tl :r! nl::tt -oM; ::JJ,? ~'::::lCI -,-- -j ,'..:) ,~ d~ --I :53 -< N v ::r: r:-; w . Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA WENDY J. TRACB, vs. No. 04 - 5526 Civil Term STEVEN E. TRACE, Defend'ant ACTION IN 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 9330l(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Via certified mail, restricted- delivery, return-receipt requested, on: November 22,2004. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: September 12, 2006 By Defendant: August 1, 2006 . 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: August 3, 2006 Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: September 12, 2006 Date: C\ \\~ \ \0 Respectful)>lub itted: U M e Adams, Esquire . No. 79465 6 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff , \ ! i I I , I , I , \ \ N = = "" U> r'l. -,:; (-:;.- , - ';''-7' ~ --< N -0 Z 19 o ""n :.;!..,., rnF -otT"' -'30 ::~(~?, ~~~ 9 Jj5 :..::. c--' +. +.+.+.+.+.+.+.+. +.+.+.+.+.+.+.+.+.+. +.+.+.+.+.+.+.+. +. +.+.+.+.+.+.+.+.+.+.+.+.+.+. IN THE COURT OF COMMON PLEAS 'OF CUMBERLAND COUNTY STATE OF PENNA. Wendy J. Trace, Plaintiff No. 04 - 5526 Civil Term No. VERSUS Steven E. Trace, Defendant DECREE IN DIVORCE AND NOW, S e..Q\.e..W\ 'o~{ Wendy J. Trace Steven E. Trace , PLAI NTI FF, \'1 1 ()()Ct>, I TIS 0 R DE RED AND DECREED THAT AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WHICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; None. PROTHONOTARY ~~~~~~~~~~~~+~~~~~~+ ~~~~ J. ~~??V ~ .~ ~ ~M 7rJ' 61 -,~ YWp/P fir ~ '17viY ~p7 n -w-d/!> .... . ~ .. .