HomeMy WebLinkAbout05-0279
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2005 - "<:7'7
CIVIL TERM
STEPHEN K. DAVIS,
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 Court House, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU
DO NOT HAVE AN ATTORNEY 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) 249-3166
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
STEPHEN K. DAVIS,
Defendant
NO. 2005 - ),,'79
CIVIL ACTION-LAW
IN DIVORCE
CIVIL TERM
COtJIPLAINT UNDER SECTIONS 3301(1<)
AND 3301 (d) OF THE DIVORCE CODe
1. Plaintiff is Pamela L. Davis, an adult individual who is represented by Michael A.
Scherer, Esquire.
2. Defendant is Stephen K. Davis, an adult individual who currently resides at 209
Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania 17050-1762.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 16, 1993 in Cumberland
County, Pennsylvania.
5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above.
6. There have been no prior actions of divorce or for annulment between the
parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised of the availability of counseling and that she may
have the right to request that the court require the parties to participate in Counseling.
9. Plaintiff requests the court to enter a decree of divorce.
10. Plaintiff and Defendant have been living separate and apart for over two years.
"
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of
the Plaintiff and against the Defendant.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
Date: January ( { , 2005
ich el A. Scherer, Esquire
I.D.# 61974
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff.
Pamela L. Davis
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II
PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
STEPHEN K. DAVIS.
Defendant
NO. 2005 -
CIVIL ACTION-LAW
IN DIVORCE
CIVIL TERM
VERIFICATION
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.
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Date: January II ,2005
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PAMELA L. DAVIS,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005 - a "/1 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
STEPHEN K. DAVIS,
Defendant
AFFIDAVIT UND_ER Se~TION 3.301(dj
OF THE OJVORCE CODe
1. The parties to this action separated on August, 2001 and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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. Section 4904 relating
to unsworn falsification to authorities. , /7
Date: January II ,2005 "::Z1f1:u1d ~ flu;;)
Pamela . Davis
(e}(1) The counter-affidavit prescribed by Rule 1920.42(d)(2) shall be substantially in
the following form in a Section 3301(c} divorce:
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2005 - 279
CIVIL TERM
STEPHEN K. DAVIS,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty days after this affidavit has been served on you or the
statements will be admitted.
AFFIDAVIT UNDER SECTION 3301/dl
OF THE DIVORCE CODE
1. The parties to this action separated on August, 2001 and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concernin~l alimony, division of property,
lawyer's fees or expenses if I do not claim them before a dilvorce 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. Section 4904 relating
to unsworn falsification to authorities. /7
Date: January I d , 2005 ~ ;' 4 / (
~ Pamela L.
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
II
V.
STEPHEN K. DAVIS,
Defendant
NO. 2005 - 27tj
CIVIL ACTION-LAW
IN DIVORCE
CIVIL TERM
COUNTER-AFFIDAVIT UNDER' 3301(d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
_ (a) I do not oppose the entry of a divorce decme.
X (b) I oppose the entry of a divorce decree because:
(Check (i), (iI) or both):
X (I) The parties to this action have not lived separate and
apart for a period of at least two years.
-.X.. (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_(a)
I do not wish to make any claims for economic relief. 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- (b)
I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my economic
claims with the prothonotary in writing and serve them on the other party. If I fail to do so
before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce
decree may be entered without further notice to me, and I shall be unable thereatter to file any
economic claims.
I verify that the statements made in this counter-alfidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
(e.b
Date: JaRl:Iary /0 , 2005
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tephen K. Davis
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND
YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT
FILE THIS COUNTER-AFFIDAVIT.
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005 -279 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
V.
STEPHEN K. DAVIS,
Defendant
MOTION FOR APPOINTMENT OF MASTER
Pamela L. Davis, Plaintiff moves the court to appoint a master with respect to the
following claims:
(x) Divorce
() Annulment
() Alimony
() Alimony Pendente Lite
and in support of the motion states:
(1) Discovery is complete as to the claims for which the appointment of a master is
requested.
(x) Distribution of Property
() Support
() Counsel Fees
() Costs and Expenses
(2) The Defendant has appeared in the action personally.
(3) The statutory grounds for divorce are irretrievable breakdown and indignities.
(4) Delete the inapplicable paragraphs:
(a) The action is contested.
(b) An agreement has been not been reached with respect to any claims.
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take one day.
(7) Additional information, if any relevant to the motion: None.
DATE:
'1- 2,). Q S'"
!!:fI.:!tsct;;, Esquire
1.0.61974
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
ORDER APPOINTING MASTER
AND NOW, this _ day of March, 2005, , Esquire is
appointed master with respect to the following claims: irretrievable breakdown and indignities
BY THE COURT,
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II
PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005 -279 CIVIL TERM
V.
STEPHEN K. DAVIS,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
,
,
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II You have been sued in court. If you wish to defend against the claims set forth
II 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
I other claim or relief requested in these papers by the Plaintiff. You may lose money or
I property or other rights important to you, including custody or visitation of your children.
I
I
I
II
II
I
NOTICE TO DEFEND AND CLAIM RIGHTS
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,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
I, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU
II DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR
,I TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
i GET LEGAL HELP.
,
i
I
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
II
PAMELA L. DAVIS,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005 - 279 CIVIL TERM
STEPHEN K. DAVIS,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
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II Michael A. Scherer, Esquire.
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AMENDED DIVORCE COMPLAINT
Plaintiff is Pamela L. Davis, an adult individual who is represented by
2.
Defendant is Stephen K. Davis, an adult individual who currently resides
at 209 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania
17050.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately previous to the
I filing of this Complaint.
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4.
The Plaintiff and Defendant were married on May 16, 1993 in Cumberland
County, Pennsylvania.
5.
There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of counseling and that
she may have the right to request that the court require the parties to participate in
Counseling.
8. Plaintiff requests the court to enter a decree of divorce.
'I
9. Plaintiff and Defendant have been living separate and apart for over two
years.
10, As alternate grounds for this divorce, the Plaintiff alleges that in violation
of her marriage vows, the Defendant has over a period, in Cumberland County, and
other places offered such indignities to the person of the Plaintiff as to render her
condition intolerable and life burdensome.
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11, This action in divorce is not conclusive.
WHEREFORE, Plaintiff prays your Honorable Court to enter a decree in divorce,
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
5 ,'I '0 ,;
Date:
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Micha I A. cherer, Esquire
1.0.# 61974
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff,
Pamela L. Davis
mas,dirldomesticldavislamendedivorce.pld
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VERIFICATION
I verify that the statements made in this Amended Divorce Complaint 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 falsification to authorities.
0l/h ~ iJaii:-'
Pa ela L. Davis
Date:
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2005 -279 CIVIL TERM
STEPHEN K. DAVIS,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A complaint in divorce under Section 330 1 (c) of the Divorce Code was
filed on January 13, 2005.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a final decree in divorce without notice.
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.
5. 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.
6. I have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling. I do not request that
the court require counseling.
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. Section 4904 relating to unsworn falsification to authorities.
Date:
7/ Ie /()j-
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
v.
No. 05-279
STEPHEN K. DAVIS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under S 3301 (c) of the Divorce Code was filed on March 14,
2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of 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 ofthe decree.
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 falsification to authorities.
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Steph n K. DaVIS, Defendant
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
v.
No. 05-279
STEPHEN K. DAVIS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 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 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. Section 4904 relating to
unsworn falsification to authorities.
DATE: 7-[, "of)'
~4" /I){(~.;J
Stephe K. DaVIS, Defendant
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
v.
No. 05-279
STEPHEN K. DAVIS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
MARRIAGE COUNSELING AFFIDAVIT
The Defendant, being duly sworn according to law, deposes and says:
I. 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 are made subject to the penalties of 18 Pa. C.S. ~ 4904
relating to unsworn falsification to authorities.
Dated: '7 - C:, -OS
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Stephe K. Da~s, Defendant
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 05 - 279 CIVIL
STEPHEN K. DAVIS,
Defendant
IN DIVORCE
RE:
Memorandum
DATE:
Tuesday, July 6, 2005
THE MASTER: This is the date set for a
hearing in the above captioned divorce proceedings.
Present
in the hearing room are the Plaintiff, Pamela L. Davis, and
her attorney Michael A. Scherer, and the Defendant, Stephen
K. Davis, and his attorney Andrew H. Shaw.
This action was commenced by the filing of a
complaint in divorce on January 13, 2005, raising grounds
for divorce of irretrievable breakdown of the marriage. No
economic claims were raised in the complaint. Subsequently
an amended complaint was filed adding an alternative ground
for divorce of indignities.
The parties were married on May 16, 1993, and
separated August 2001. There were no children born of this
marriage.
The Master has been provided affidavits of
consent and waivers of notice of intention to request entry
of divorce decree which have been dated and signed today.
The affidavits and waivers will be filed with the
1
Prothonotary's office by the Master's office. The divorce
will be able to be concluded under Section 330l(c) of the
Domestic Relations Code.
Inasmuch as no economic claims are
filed by either party and the divorce is going to conclude
under the no-fault section of the code with the filing of
the affidavits and waivers, there are no further proceedings
which the Master is required to undertake in this matter.
However, in order to complete the record, Mr. Shaw and Mr.
Scherer will engage in a short examination of each of their
clients with respect to the current status of this case and
the willingness of the parties to proceed to a conclusion
under the no-fault section of the code and without having to
address any economic issues. Mr. Shaw.
----------------
BY MR. SHAW:
Q Mr. Davis, if you could, please just state
your full name for the record.
A Stephen K. Davis.
Q And you acknowledge that you are a party to
the divorce here today -- Pamela Davis is the Plaintiff and
you are the Defendant?
A Yes.
Q The purpose of today's hearing is to
establish your desire to complete the divorce, are you under
medications that would affect your judgment?
2
A No.
Q Are you taking anything else that might
impair your judgment today?
A No.
Q Did you sign earlier this morning an
affidavit stating that you are consenting to finalize the
divorce?
A Yes.
Q Is that still your intention?
A Yes.
Q Now, under the divorce the law could provide
that you would have the right to pursue equitable claims,
meaning property issues, are you agreeing to waive the right
to pursue that today?
A Yes, I do.
Q So it is your intention to finalize the
divorce?
A That's correct.
THE MASTER: Mr. Scherer.
BY MR. SCHERER:
Q Would you state your full name, please.
A Pamela L. Davis.
Q Did you ask me to file a divorce complaint
for you here in Cumberland County on January 12, 2005?
3
A Yes.
Q Is it your desire to be divorced today?
A Yes.
Q And did you sign an affidavit of consent and
waiver earlier today relative to this divorce?
A Yes.
Q Do you wish to raise any property issues in
connection with this divorce?
A No.
cc: Michael A. Scherer
Attorney for Plaintiff
Andrew H. Shaw
Attorney for Defendant
4
PAMELA L. DAVIS,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 05 - 279 CIVIL
STEPHEN K. DAVIS,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
11'tc day of
J:!1: .
2005, the parties having appeared before the
indicated that they wish to have the divorce proceed under
Section 3301(c) of the Domestic Relations Code, having signed
affidavits and waivers allowing the divorce to proceed under
that section of that code, and further acknowledging that
neither party wishes to raise any economic claims in the
divorce proceedings, the matter can now proceed to conclusion
and the appointment of the Master is vacated.
BY THE COURT,
cc:
Michael A. Scherer
Attorney for Plaintiff
Andrew H. Shaw
Attorney for Defendant
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PAMELA L. DAVIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2005 - 279
CIVIL TERM
STEPHEN K. DAVIS,
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 breakdown under Section 3301 (C) of the
Divorce Code.
2. Date and manner of service of the Complaint: Service was made via Certified
Mail on January 21, 2005.
3. A. Date of execution of the affidavit of consent required by Section 3301 (c)
of the Divorce Code: by Plaintiff on July 6, 2005; and Defendant on July 6, 2005.
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4. Related claims pending: None.
5. Indicate date and manner of service of the notice of intention to file praecipe to
transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce
Code: None.
Respectfully submitted,
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Micha I A. Sch rer, Esquire
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IN THE COURT OF COMMON PLEAS :
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OFCUMBERLANDCOUNTY
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PEN NA.
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STATE OF
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PAMELA L. DAVIS,
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Plaintiff
No.
2005 - 279
CIVIL
VERSUS
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STEPHEN K. DAVIS,
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Defendant
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DECREE IN
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DIVORCE
AND NOW,
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PAMELA L. DAVIS
, PLAINTIFF,
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DECREED THAT
STEPHEN K. DAVIS
, DEFENDANT,
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
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PROTHONOTARY .
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YET BEEN ENTERED;
NONE.
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