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HomeMy WebLinkAbout05-0413 PETER BRIGGS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. C>.t -4J.3 Civil Term ROSE M. BRIGGS, 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 St. Carlisle, Pa. 17013 (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PETER BRIGGS, vs. No. OS- - .l..j.tJ Civil Term ROSE M. BRIGGS, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Peter Briggs, a competent adult individual, who has resided at 210 Frost Road, Gardners, Cumberland County, Pennsylvania, 17324, since 1990. 2. Defendant is Rose M. Briggs, a competent adult individual, who has resided at 324 South Columbus Ave., Littlestown, Adams County, Pennsylvania, 17340 since August 2004. 3. Plaintiff and Defendant have been bona fide residents ofthe Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 12, 2000 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 no 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, Plaintiffrequests 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. 94904 relating to unsworn falsification to authorities. \)~~ Peter Briggs, Plaintiff ~ Date: I--~I -(j~ ams, Esquire I.D o. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~ ~ ~ ", c..":::. C) --. c..;::) ~ (:..""1 -n '- r!'i <- -, V) ~ -r ..... ~-;,. z f'!'i:D -;,' 'r ~ CI') '0 (J] N :pr:I.~ ~ ~ () u ,t.- o'2Y r:: '>:,~~{.J ~ -> -0 --r -'~., ~~1 :Ji:: ~;;:? ~~ [fj i:jrt, w I -j w ~17 -> W .< ~ PETER BRIGGS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05 - 413 Civil Term ROSE M. BRIGGS, : ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICI~ AND NOW, this February 7, 2005, I, Jane Adams, Esquire, hereby certifY that on February 3, 2005, a certified true copy of the NOTICE TO DEFEND and COMPLAINT IN DIVORCE was served, via certified mail, return receipt requested, addressed to: Rose M. Briggs 324 South Columbus Ave. Littlestown, Pa. 17340 DEFENDANT . Complete Ilem8 1. !" 8I1d 3. AIeo compIllIlt Rern 4 If RestrIcted DelIverY Is deolred. . Print yoU-nsm& end addMs on the_ so that we can rvtum lite ClIId to you. , . Attach this ClIId to the back of 1lle maltplece, or on the front If spece perm/Ill. 1. ArlIcle_Io: Rose 11. B'r;~l~ J 2. 4- S~ CoJv,..ica Ave. L\tt1t'S~, eA.17::J40 a. 1iIIoIol....... ~--.... PS fOrm 3811, I'ebn8y 2004 _.._...... Respectfully Submitted: ~ /;/. ((/0 ..J e Adams~qUlre .D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 7003 3110 0004 5775 4351 ( fT...... <:;.:J - .- .. ,,~..~ C) PETER BRIGGS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05 - 413 Civil Tenn ROSE M. BRIGGS, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT I. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 24, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date ofthe filing and service ofthe 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. 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: S Iii /0:::,- WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(0\ AND &330I(d) OF THE DIVORCE CODE I. I consent to 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. ~4904 relating to unswom falsification to authorities. Date: 5 ~ ( 100- ~ r-.:I <::;;;;I C~) CJl -:::7 -',~ r'J o Cl Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PETER BRIGGS, vs. No. 05 - 413 Civil Term ROSE M. BRIGGS, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT I. A complaint in divorce under section 330 I (c) of the Divorce Code was filed on January 24, 2005. 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 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 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: ::>1 {I /0-::,- ~.m, WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) AND &3301(d) OF THE DIVORCE CODE I. I consent to 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 [ 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. ~4904 relating to unsworn falsification to authorities. Date: 911/ (IS- ~(Vl) ~ Rose M. Briggs, Defendant r"_" C:.:;' ;j~~ C'; _':i'1 :;:;:! i";iFJ --, -, ,-;'~ J'_! 'J~2: -'t,'" l' r,'! en \.0 Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PETER BRIGGS, vs. No. 05 - 413 Civil Term ROSE M. BRIGGS, : ACTION IN DIVORCE 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 &330I(c) of the Divorce Code. 2. Date and manner of the service ofthe Complaint: Certified mail. restricted deliverv, return receiot reauested. on: February 3, 2005. 3. Date of execution of the affidavit of consent required by 3301 ( c) of the Divorce Code: By Plaintiff: May 11,2005 By Defendant: May 11,2005 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: May 11, 2005 Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: May II, 2005 Date: S /16>) 6~ ~ R~spectfullY SUbmitte~l ~ an Adams, Esquire ~D No. 79465 6 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff r-:) Ci .:::? -n ~ <f' ..- W -: t ~"'z.j r " ..~ + + + + + + . + . . . + + . + + . . . . . . + . . . . . . . + . + . . + + + . . . + + + . . . + + . + + . + + . + . + . . . . + . + . . + + + . + + + . . + . + . + + . + . + . + . + + + . . +'f "';+: "" Of. ;+:'+'itiCf.:+::t::f. . :+::f.:t: :+ ... :+.:t'f:t; :+: :f.:f.:+ :+: :f. :of. :+: ;f.:f.;+i:f.:+::t; :+ :+::+:++:+::f.:f.:+:+:f.+':f.:f.:f.:f.~+:f. +.:f. :f.++++:f.+~ + . . . + . + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. Peter Briggs, Plaintiff No. No. 05 - 413 Civil Term VERSUS Rose M. Briggs, Defendant DECREE IN DIVORCE AND NOW, /1' ,,2411" , IT IS ORDERED AND "-""4; DECREED THAT Peter Briggs . PLAINTIFF, AND Rose M. Briggs , DEFENDANT, 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. :t'f.+:+:+ + . . . . + + . + . + . + . + . + . + . . + . 'f:+;++++:f.'f.+:+:+:+:+:f.+.:+:'f+:f.+;+::f.:f. :f.++ +:f. 'f++:f.+;+::f.'f+++++'f. 'f.:f.++++ ? By THE COURT: / A~ ~ ( . PROTHONOTARY :+: Of Of Of. Cf:-f. ""of . + + . + + + . . + + + . + . + + . + + + + + . + + . + + + + . + . . + . . + + + + . + . . . + . + + + . + + . + + + + + + + + + + + + + + J. _ ~ -2- ~<?uf j)~vi,>(7 j/ S Pnto/-V it.V ~ ~l1.I .q~ -J-"7? SO b/" .