HomeMy WebLinkAbout05-0378
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNlY - PENNSYLVANIA
David L Mason
Plaintiff
: No. Of{ - 3'lcY
Ciu~tr~
: Civil Action - Law
vs,
: In Divorce
Lori L Mason
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 in
divorce or annulment may be 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 the custody or visitation rights 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 at the Cumberland
County Courthouse, Carlisle, Pennsylvania.
If YOU DO NOT ALE A CLAIM FOR ALIMONY, DNISION OF PROPERlY,
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
(717)..249-3166
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNlY - PENNSYLVANIA
David L. Mason
Plaintiff
: No. oS' - .3'7P (I,)" L ~ V2...~
: Civil Action - Law
vs,
: In Divorce
Lori L. Mason
Defendant
COMPLAINT UNDER SEmON 3301(c)
OF THE DNORCE CODE
1.
Plaintiff is David L. Mason, who currently resides at 218 West King Street,
Shippensburg, Cumberland County, Pennsylvania, 17251 since April 15, 1999.
2.
Defendant is Lori L. Mason, who currently resides at 4188 Sycamore
Grove Road, Chambersburg, Franklin County, Pennsylvania, 17201 since
November 10, 2003,
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 September 13, 1990, in
Orrstown, Franklin County, Pennsylvania.
5.
There have been no prior actions of divorce or for annulment between the
parties.
6,
The marriage is irretrievably broken.
7,
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,
8.
Plaintiff requests the Court to enter a decree of divorce,
Respectfully submitted.
L~~
H. Anthony Adams, Esquire
Attorney for Plaintiff
49 W, Orange Street, Suite 3
Shippensburg, PA 17257
(717)-532-3270
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
Po. C.5. Section 4904 '.Iilting tD """""CO ~~~ ,M
Date:l-7-Q)- ~
David L Mason '-
G -<a..
~ 1l --
.....0
\)
.
1) ........ &
- 8
}J (-) 0_'
c..::. 0
"'(j >v ;;...;? -T1
pI! CJ'
~ 0- L -....
:-1':..,..,
~ rnF
- - nl
........ r,,) I..:J
$ CJ ,
s~~
..~ --,.~
(~.)
:;~ .i;
~j.'J
o~\
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
David L. Mason
Plaintiff
vs.
Lori L, Mason
Defendant
: No. 05-378 Civil Term
: Civil Action - Law
: In Divorce
AFFIDAVIT OF SERVICE
H. Anthony Adams, Esquire being duly sworn according to law deposes
and states that a complaint in divorce was mailed to Lori L. Mason, of 4188
Sycamore Grove Road, Chambersburg, Pennsylvania, 17201, certified mail,
return receipt requested on January 24, 2005 and was accepted on delivery by
Lori L. Mason on January 25, 2005,
I
.e
!I
IJg I
ODD!
! - i
Ulh
oj ...
~;'
till . ~~'.~:
(~lh t:. tC
!.91h~~ ~ 'C ~
iiill~K cc r .:a
cifoll~1l8 ~.-o
":1.1!S~ ji "'" ~ ~
h h1j 1 ...:.\.~~
ia:~;~ "'9\-
,!;g,1;j'611 ~ . - ""- ,
~ i'E:5! a ~ ~.=..!.
o..u<!; ~ ~ ~ ()
~
i nthony Adams, Esquire
Attorney for Plaintiff
49 W, Orange Street, Suite 3
..D Shippensburg, PA 17257
:r
..... (717)..532..3270
I'-
[J'"
CJ
:r
[J'" Sworn to and subscribed this
rn 1"-' day of reb'>.ill'( .2005,
CJ
CJ ';((.?uNc-/' c:Y'/~ L-
CJ a.
CJ J'
Ul Notary Public
I'- I
CJ My Commission Expires:
:r I
CJ
CJ COMMONWEALTH OF PEHNSYLVANIA
I'- NOTARIAL SEAL
BRENDA L BREHM. Nol8ry PublIc
ClIIIIIle Borough. Cumbert8nd County
My Commlseion ExpIree .len, 8. 2008
I
If
i u-
tI ::
fl it
N ~
r~.)
.',,";,..,
v..l
I
lll~
f
-orn
:ijr:::J
(")r1
l."J
~I;~ ~~~7
-.;")
-~.,
(>)
n'-,
"
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUN1Y - PENNSYLVANIA
David L. Mason,
Plaintiff
: No. 05..378 Civil Term
: Civil Action - Law
vs.
Lori L. Mason,
Defendant
: In Divorce
AFFIDAVIT OF NON MILITARY SERVICE
I, David L. Mason, being duly sworn according to law depose and st te
that Lori L, Mason, is not a member of any United States Military Service 0 in
the military service of any country nor has she ever been a member of an
United States Military Service or the military service of any country,
Shu.JJj} ~~~) i
David L. Mason .
Sworn to and subscribed
This ;)\s~ day of March, 2005.
~,~~-,
Notary Public
My Commission Expires:
--
No,"ri,,' Seal J
H. i\nihony Adams, Notary Public
Shipp~.~nsbllrg Bom, CnmberlJ!ld COiwty
My C01l\I!liSS\OI; i-:xplres tyby i5, 2.d06
-- -
r \8: ;j~:I, PennS)IIV,~fllllA::;::;OG:iJlIDnot Nolar;C5,
,",','
C)
c-
-..1
-<
"',
=
(~...,
~,
:!(:
:0.--
=
N
~.
.~
o
.,
--l
:r:-.
rnj=;:
~~
:~.i;~~
f'~5h'~
::.:,-t
~-D
.~
-:j
<;::'
o
r-~
.."
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNlY - PENNSYLVANIA
David L Mason
Plaintiff
: No, 05-378 Civil Term
: Civil Action - Law
vs,
: In Divorce
Lori L Mason
Defendant
AFFIDAVIT OF CONSENT
L A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on January 20, 2005,
2, The marriage of Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of filing of the Complaint and
service on Defendant.
3. I consent to the entry of the final 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
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:~ 1J:::oS'
~ ':::\ 'W\n~
Lori L Mason
(")
S
lJ~i~
n~r\.~
~~.~2}
.~~, \.....
(f) ,,'~::,
_.~ .c'
r;:C
~
0':C~
,~n
PC
;-..::
::.<
.....,
=
=
en
<-
c:
Z
I
-.l
-0
:x:
~
~
rr>:!l
.off;
:09
(~O
_____-{"1
<25
/.-rn
~
?n
-<
(..)
en
A
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY - PENNSYLVANIA
David L. Mason
Plaintiff
: No, 05-378 Civil Term
: Civil Action - Law
vs,
: In Divorce
Lori L. Mason
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEsr
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 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:~" no "2..,1. DOb
~ ~ '1-1\C\.~._
Lori L. Mason
o
~
,",',-,..
4:~i~f'
d'("';'
_7 '-,
~/>:'
,-
~r2~
:v->;;
:".\
-
.,;;
eo,
'e.
........
-
\
-'
-C
::J"
Q,
1.:!!
n'r::::
--o1'TI
:0 s:'
0,0
::;-:y.
'5-0
\?:~
o
q
~
-
<>-'
(.fl
,-, .
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNiY - PENNSYLVANIA
David L. Mason
Plaintiff
: No, 05-378 Civil Term
: Civil Action - Law
vs,
: In Divorce
Lori L. Mason
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on January 20, 2005,
2, The marriage of Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of filing of the Complaint and
service on Defendant.
3. I consent to the entry of the final 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
understand that false statements herein are made subject to the penalties of 18
Pa, C.S. Section 4904 relating to unsworn falsification to authorities,
~cu%flcl1J/~
David L. Mason
-
Date: 67 -0;)-0'>
(')
~::;
,,},J.I:::";
I!!""
:;:::::: c.:l~'
~~::~":
S::C
~:.;C,
::> ;~~
?~
=<'
......,
=
=
CJ"
c....
c:
z
o
"n
:r
rn::!J
lTi
=.80
06
g:a
-,.0
om
,"-I
55
.<
f
co
-u
:x
l:-?
N
00
,..
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNn - PENNSYLVANIA
David L Mason
Plaintiff
: No, 05..378 Civil Term
: Civil Action - Law
vs.
: In Divorce
Lori L Mason
Defendant
WAIVER OF NOnCE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 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: IJLr0;2-D5
~~ (/11 OM-f'-
David L Mason
-o;:,"i
lJ)r;,-
;z:.C,
(.':1'
~.t-
:::;(-,
:.s-C~'
~;;%
Q
~;:;;;
""-"
~
~
B
-:c
I
CO
~
~~
~~
-,-a
-'-
<;'~
t::?,
>"=
:~
-0
:s:.
N
..
~
cP
IN THE COURT OF COMMON PLEAS
OF THE 39TH JUDICIAL DISTRICT
OF PENNSYLVANIA - FRANKUN COUNTY BRANCH
David L Mason
Plaintiff
: No. 05-378 Civil Term
: Civil Action - Law
vs,
: In Divorce
Lori L Mason
Defendant
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 3301(c) of the Divorce
Code,
2. Date and manner of service of the complaint: Service was made by Certified
Mail Return Receipt Requested on January 24, 2005 and received by
Defendant on January 25, 2005,
3, Date of execution of the Affidavit of Consent required by Section 3301(c) of
the Divorce Code; by the Plaintiff June 2, 2005; by Defendant June 2, 2005,
4, Related claims pending: None,
5. Plaintiff's Waiver of Notice was signed on June 2, 2005 and was filed June 8,
2005 and Defendant's Waiver of Notice was signed June 2, 2005 and was
filed on June 7, 2005.
c
\~ ~
--'--'" _3-
H, Anthony Adams, Esquire
Attorney for Plaintiff
49 W. Orange Street, Suite 3
Shippensburg, PA 17257
(717)-532..3270
------
-("1""
l~~) i
"--.
C/,i
~~~C
o
c
.,."~
~
"'"
GJ"
<-
c::
-"
-
-
~
"
.~ '~-
.;;= (.,~
;:::-c
-7
=::
-<.
~
-!Y.
Q,
~:D
"'r-:
-Om);
:9
(.)
.-,-", :!.:
:T-;!J
\,,,20
:"Sm
~~
"13
:..::
co
.'
C-'"
-
,
,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
,
PENNA.
STATE OF
David L, Mason
,
Plaintiff
No, 05-378
Ci vB
VERSUS
Lori L. Mason
Defendant
DECREE IN
DIVORCE
.
AND NOW,
Jvt'1e 2-3
, _ 2.00.';;: IT IS ORDERED AND
DECREED THAT David L. Mason
, PLAINTIFF,
.
Lori L. Mason
, DEFENDANT,
AND
.
. 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
.
.
PROTHONOTARY
By THE COURT: ~
lJ/~ >~
.
J,
.
ATTES
---
.
.
.
,
.
,
,
,
.
,
,
,
,
.
.
.
.
.
,
,
.
.
.
,
.
,
,
,
.
.
,
.
.
,
.
.
,
.
.
,
,
,
,
tIP ~ ~??'I'lL 5V,Le}
~ % _ __ 4W - Pi? 519- L-e-}
"'''-1~ '''1' : . - >
. . ': ' , ' '!'