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HomeMy WebLinkAbout05-0422 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Jason E. Jumper Plaintiff : No. O~ - J..jJ..~ /J /---r;;,n. L lu:l l~rv; : Civil Action - Law vs. : In Divorce Nicolle D. Jumper 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 FILE A CLAIM FOR ALIMONY, DIVISION 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 COUN1Y - PENNSYLVANIA Jason E. Jumper Plaintiff : No. OS ~ 4'"\ '"\ f) I~,., . "'-"'- L.t'Qc(, LS"-j : Civil Action - Law vs. : In Divorce Nicolle D. Jumper Defendant COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Jason E. Jumper who currently resides at 5221 Orrstown Road, Orrstown, Franklin County, Pennsylvania, 17244, since May 16, 2003. 2. Defendant is Nicolle D. Jumper who currently resides at 208 North High Street, Newburg, Cumberland County, Pennsylvania, 17240, since January 4,2005. 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 9, 1995 at 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. Wherefore Plaintiff requests that she be granted a divorce from the bonds of matrimony. Respectfully submitted. ~~~ H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 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. Section 4904 relating to unsworn falsification to authorities. Date: / -d. J-o~ ~ Je'So . Jumper \.:) -6Q. t -- 'l --Cl \) ~ lI{ ........ () -... ~ ~ -vi -.() w F- ~ g --L.. 0. ~ --'0\::..< -(..,'1(;,': '~'4'S ~~1.~ t~ (p c." ~Y'-,~ 7:y \>:., 7<:;' ~.?,. :2. r;;t, q, i~ ...... ~ '1;,-n ~ -,'Z'fq{&J ~ c:,<"" D V. "i~""0 "0.,(>_ <?;-';-" f" .....- ~ q:: ')'(1 ......- -;2. ...! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNIY - PENNSYLVANIA Jason E. Jumper Plaintiff vs. Nicolle D. Jumper Defendant : No. 05-422 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 Nicolle D. Jumper, of 208 North High Street, Newburg, Pennsylvania, 17240, certified mail, return receipt requested on January 26, 2005 and was accepted on delivery by Nicolle D. Jumper on February 1, 2005. I {I ~l Ii a! ete t. !!1! I"': iJ !! I ~: I .. ""': I' 0' -.:, ~ l: 0, o UJ ~ .; ~1'~ j' ~ (\ !~!! [.$. ~ II 8S*" .l:-/'I '<:'!llrt :.J /:.1 d. ~I~~J ~~ 0: ~J~isi ~ tJ t FV IJ~iiil~~ ~ hi~li i 8 r;l ] ~i~ ll~ ~ ! 6 ~ ~ C#~ ESquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this ~'=- day of kbrelary, 2005. ><3~.e4d~ ~~..~ Notary Public My Commission Expires: COMMONWEALTH OF PENNSVLVANIA NOTARIAL SEAL BRENDA L. BREHM. NotaIy PublIc CIIIIIIe Borough, Cumberl8nd County My Conanlllllon ExpireI...., 8. 2008 , "'11 , c:.) -',~.., , " ,. co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Jason E. Jumper Plaintiff : No. 05-422 Civil Term : Civil Action - Law vs. : In Divorce Nicolle D. Jumper Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 25, 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: a, ~c'2I~ #' Plainti Q ...., 0 = , ~;:;;) ., ,~ c_ :::l s:~ rh::!] r -nn~ '" :",C;:; -. LV CJ,L, :'_J ~:'.~ "'"'\) ;~~ :;) -'.~ ::'~:: h~ f".::' 0 :;:;~ ..r.- ~D OJ -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Jason E. Jumper Plaintiff : No. 05-422 Civil Term : Civil Action - Law vs. : In Divorce Nicolle D. Jumper Defendant WAIVER OF NOTICE 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:---19 -() /-O<j J~~ Plainti , .-) = c".:Jo C....4 o -n ,-I :T:--- C'1 " 'r: ---.rr. ::'jq '>?I!:; 1.... -- ., (:_:~iq c:5fn -I \->- ~D -< ,-... S':;~ N W -\J :n: ~? .r- eo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Jason E, Jumper Plaintiff : No. 05-422 Civil Term : Civil Action -- Law vs. : In Divorce Nicolle D. Jumper Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 25, 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:Lo.Old'05 ~~~~~rrf10h , Defendant (') ~~~ !-:. ...~ <= c.:::> <on '- o -n :r!." n1r= --Ji-r, -::'0 ~~i~ ~~ <",(,' Or;:. "):,; :;1 -~ t'.) -' 2:;,: -,.~ cs IN THE COURT OF COMMON PLIEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Jason E. Jumper Pia i ntiff : No. 05-422 Civil Term : Civil Action -. Law vs. : In Divorce Nicolle D. Jumper Defendant WAIVER OF NOTICE 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. DateJ O'~ .05 J7 - nn_ CX) ~'/YYlP.O-L ~per Defendant C) r;::' ~ c::.-' cJ' ~ ~ N -' o -1'1 ?? .c- ~~, jl'\':"': -on....., :"y '~2\f~'>t ~ ]~~ :r; "--...(; (S'i'n -~:\ :'6 -< - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Jason E. Jumper Plaintiff : No. 05-422 Civil Term : Civil Action - Law vs. : In Divorce Nicolle D. Jumper 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 Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on January 26, 2005 and was accepted on February 1, 2005. An Affidavit of Service was filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff, June 21, 2005 filed June 23, 2005; By Defendant June 22, 2005 filled June 27, 2005. 4. Relating claims pending: None 5. Plaintiff signed a Waiver of Notice on June 21, 2005 which was filed with the Prothonotary on June 23, 2005; Defendant signed Waiver of Notice on June 22, 2005 which was filed with the Prothonotary on June 27, 2005. \~~ c H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 ~ P"-:t = ~ =:0 -uS, c.n II' cr c:..... :r! 2fT'. c: .~. nl:I1 ...J..' :z 2': ~- r-- W):, (..) "~ _#" :" 0 :0 r:: c' ~~ :.:::: ..' ;'>C -0 :r: -H ,z:(~ ::J:: Ct- 5> '. ?~ C. N ~ c-, .. -I =< r- ~ .s:- -< " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~~ ~ ~ ~~ ~~ ~~+ ++++ ++ + '+: :f.++ +.'f +. +. :+:++++++++++++++++ +++++++~ . IN THE COURT OF COMMON PLEAS ; . OFCUMBERLANDCOUNTY : PENNA, STATE OF Jason E: Jumper No, 05-422 Ci vil PlAintiff VERSUS Nicolle D. Jumper Defendant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +"" +. '+ DECREE IN DIVORCE ~ ....- b ~ , , IT IS ORDERED AND AND NOW, Jason E. Jumper , PLAINTIFF, DECREED THAT Nicolle D. Jumper , 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; By ++++:t'l-: ++++++ '+ +;!''+' +'+' ++'+' ++++:+: ++ '1':+'4;++ ++;+:++++'f.+ +'+' + ;f.:t'++ ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 'f'''f':+: Of .~~ ~ ~ 5011-t.. ~!/ p~ ~~~/'~ 5C/'//'L .