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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' : . - > . . ': ' , ' '!'