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HomeMy WebLinkAbout04-6402 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. OL.J -I.. '-IDA... Cl(j,_:'-T~ : CML ACTION - LAW : IN DIVORCE JILL L. BAIR, Plaintiff WILLIAM H. BAIR, Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned 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 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 Court House, One Courthouse Square, Carlisle, 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 Phone: (717) 249-3166 d1~ Attorney for Plaintiff JILL L. BAIR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. WILLIAM H. BAIR, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary JILL L. BAIR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. WILLIAM H. BAIR, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE. 1. Plaintiff is Jill L. Bair, social security no. 195-56-6431, who currently resides at 3977 Brookridge Drive, Mechanicsburg, Cwnberland County, Pennsylvania, 17050. 2. Defendant is William H. Bair, social security no. 193-38-9634, who currently resides at 4714 B Charles Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 28, 1982, in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The Plaintiffhas been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. The parties to this action have been separated since December 15,2002. 11. Plaintiff requests the Court to enter a Decree in Divorce. 12. This action is not collusive. WHEREFORE, the Plaintiff, Jill L. Bair, requests the Court to enter a Decree in divorce dissolving the marriage between the Plaintiff and Defendant. JAMES, SMITH, DIETTERICK & CONNELLY Date ~~:?O()'/ By: 4/z;faLL Susan M. Kadel, Esquire Attorney for Plaintiff, Jill L. Bair Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PA J.D. No. 44837 VERIFICATION I verify that the stateInents made in the foregoing document are true and correct. I understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. 94904; relating to unsworn falsification to authorities. Date: I 2. / ;(0 / () '( ~af B~ Jill L. Bair . .. AJG~ t '1 ~ ~ ~ CJ '\i N _, 1 ~ ~ ~ ~ $ r,'" ',' f"--,,' (') ,~) -;1 ". r-"1 --1 ; d . \, C) -r-': i', ;"'-J I. ' ( '.. , , -'"j I .. .. " , , I"';' ( ;'1 ' , ('~,,: . --'- JILL L. BAIR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2004-06402 WILLIAM H. BAIR, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: : ss. COUNTY OF DAUPHIN AND NOW, this 6 tf-~ day of ?tl/U'fizrc/ ,2005, personally appeared before V' J me, a Notary Public in and for the State and County aforementioned, Susan M. Kadel, Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce was served on the Defendant, William H. Bair, on January 3,2005, by certified mail number 7004 1160 0002 1106 0704, addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and made a part hereof. ~1J~--- Sus M. Kadd, Esquire ,2005. NotariIIJ Seal Am L Shu&an. NOl8Iy PabUa Camo lUU BorO. Cumberlind County My CommIssion Bxplres Apr. 18, 2006 . Complete items 1, 2, and 3. Also complete item 4 if 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 back of the mailpiece, or on the front if space permits. 1. Article Addressed to: &;;; jt::vr2 .J7.' Z?4?.-' r ~7/~-6 [~d-s vf'/ ~C~tP7r';-s~/4 /7t:?50 o Express Mall ~ Retum Receipt for Merchandise CJ C.O.D. 4. Restricted Delivery? (Extra Fee) rj1 Yes 7004 1160 0002 1106 0704 2. Article Number (71Imfer /rom 8M'b IrIbeI) PS Fonn 3811, February 2004 DomestIc Return Receipt 1ll25l1lHl2-M-l~ : o c -~ -s. ~~~g (:") .~ \--::. '.... "- )'~ (~ ~- CJ :J~' c.. Z ~ po c- eo, "- (. '2 .. (, - -... :-t.'l .~1 " ' '".." . 1 ~ ' < <;'; JILL L. BAIR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 2004-06402 WILLIAM H. BAIR, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 21,2004. 2, The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both 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, WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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! 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.A. ~4904, relating to unsworn falsification to authorities, Date: ~r" ';OdS ~;/&~ Jill . Bair, Plainti:ff o c r-' C,) ,:;:> "" Q, ~:~ _.~.. ~-n f\1e :n'o <.~~ {~.~ ,,-,' -~:~tl ~?\ :) .....\. .,";;> ,:<:) ',,< ~.-;o C. G~) ,,' -.J:) C? l'> -.J:) JILL L BAIR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v, : NO, 2004-06402 WILLIAM H. BAIR, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 21,2004, 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both 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. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I, 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 divof1~e 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.A !l4904, relating to unsworn falsification to authorities. Date: 1- ;f - 0 S- Q c. ~ """ d' P C (;) ~ ~e., -=\'\\:r:1 <~(l" -L",~ 1 .\~. \. 0) "" co " ~ )-{-) ":::':"11'-(\ ':~:,\ "-~ ~-;"'". JILL L BAIR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 2004-06402 WILLIAM H, BAIR, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RE:CORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: I. Ground for divorce: irretrievable breakdown und~", Section (XX) 3301 (c) ( ) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: January 3, 2005 by restricted, certified mail number 7004 I 1600002 1106 0704, 3, Complete either paragraph (a) or (b), (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Code: by Plaintiff: August 18,2005; by Defendant: August 8, 2005, (b) (I) Date of execution of the Plaintiffs Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4, Related claims pending: None 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: 6, Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: or, date of execution of Waiver of Notice ofIntention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code: by Plaintiff: August 18,2005; by Defendant: August 8, 2005. and, date of filing of the Waiver of Notice ofIntention to' Request Entry of a Divorce Decree: Plaintiff's and Defendant's Waiver are being filed simultaneously with this Praecipe. JAMES, SMITH, DURKIN & CONNELLY LLP Date: ./fr <?~ .{d'd J /tA4? adel, Esquire Attorney for PlaintilT, Jill 1. Hair Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PA J.D. No. 44837 ~ ~ CJ' .,::~ c: G') \'-~ .J) ~\ .-I"" "'5.;..,.;.;; ,'\ (.-,\ -("/'~ ~<) ......,. /_., :l_') '"<:,')S-\;, ,<)'t) -~- ':~: {'n ~~:~\ 2: ,>:?- ,~ '"E;~_ .' cP. ~ <f 'f. 'f.:t+.'f. . . + + . . + + . . . . . . . + + . , . . . + . . . . , + . + + . , , . + , + , . . . . . , . + . . . , . . + . . + + + + . . + , , , . . . + + . + . . + . + + +,.,:+:+:+ ~~+.+.+.~+ ++:t+++++:+:+:+:+:+:+ :+~+'f.:+:+:+ +.+.+.+.+:++~ . + + . , + + . . :+:f.:+:++:f. :+;;Ii + + ;Ii '+' '+' Of. Of':f :f. + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA, JILL L. BAIR NO. 2004-06402 VERSUS WILLIAM H. BAIR DECREE IN DIVORCE AND NOW,J/vcrt- ?\ 2005 , IT IS ORDERED AND DECREED THAT JILL L. BAIR AND WILLIAM H. BAIR ARE DiVORCED FROM THE BONDS OF MATRIMONY, , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT BEEN RAISED OF RECORD YET BEEN ENTERED; tJo~ ....., >; v ,,'" .I / pJOTHONOTARY . . + . . . . , . . . . + . + + . . . . . + + . . . . . + . . . + . . . . + . + . + . . . + . + . . + . . . + . + + J. . . + . . + . + + + . . . . + . . . . + + . + + . + , . . + + + + . + + " :+:+:+:+ :++++ . Of' 'f 'f + +:+:+ +.+ + + +:+ + + 'f + +:+ +:+:+:+:+ ~~:+++:+ +++.++++:+++++:++ _-d it:" 7' ~ ~ 5'J.-c6 ;;;:/ p :? /f/- ~ /9 5" (> .b . ..;~. ,../ .,."", ,.' ;~'"... ,< , .