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Home My WebLink About05-0681 " CHERYL A. NASH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2005 - t,S I CIVIL JOHN G. NASH JR, Defendant 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 CHERYL A. NASH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2005 - ("fl CIVIL JOHN G. NASH JR., Defendant IN DIVORCE COMPLAINT UNDER SECTIONS 3301(Cl AND 3301 (Dl OF THE DIVORCE CODE 1. Plaintiff is Cheryl A. Nash, an adult individual who currently resides at 333 Zion Road, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is John G. Nash Jr., an adult individual who currently resides at 127 Long Road, Apartment 3, Newville, Pennsylvania 17241. 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 June 29, 1984 in Clay Florida. 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. 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 J By t:...:.--"~ Robert L. O'Brien, Esquire Attorney for Plaintiff 1.0. # 28351 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 j, VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. r [ eM" ( !LU~ .. )G~j;\ eryl A. Nash Date: 4u'. Il, '1; D5- F~ -c. ~ "" -<:) .... .... c ..-:: - -'l. ~ ?- ~ '" --- -<:> ~ 'G \.,'" C') <'\1. -~'l ~-i'l 'C,t.) \ cO (:.. ":t::.) \'-./ CHERYL A. NASH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2005- 681 CIVIL JOHN G. NASH JR., Defendant IN DIVORCE I II I i ACCEPTANCE OF SERVICE~ AND NOW, this /0 day of ft:.huC(7 ,2005, I, John G. Nash, Jr., Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. ?~ -;;--- John G. Nash Jr. ~ \ tJ~/ -"I-l ::;:1 1;1 (,.,:~ II CHERYL A. NASH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005-681 CIVIL JOHN G. NASH, JR., Defendant IN DIVORCE DEFENDANT'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 3301 (C) of the Divorce Code was filed on February 8, 2005. 2. Defendant acknowledges receipt and accepted service of the Complaint on February 10, 2005. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. 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. '"'\ ,,1/) Date: June ~ , 2005 ~~ (-:) C;;:> -(1 c_" f r.~ <;";"i f"0 CHERYL A. NASH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-681 V. CIVIL JOHN G. NASH, JR., Defendant 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 3301 (C) of the Divorce Code was filed on February 8, 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: June f , 2005 ~fA,~ Ch ryl A. Nash "" = ~ = <:.n fT) <-.. ::c .-;;.' c:: ..c~ ~..... :;;;~ m:!l (j) I -o~ ,.," 0:> :J;J r'''-'' ~:: j!~r ~f:~ "" ::ll: ~;:~ Z .. Om :'.2 .--1 c:> ~ .::- CHERYL A. NASH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005-681 CIVIL JOHN G. NASH, JR., Defendant 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: Defendant signed Acceptance of Service on February 10, 2005. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on June 1, 2005, 2005; and Defendant on June 2, 2005. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 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, I -:[2f)6~ Robert L. O'Brien, Esquire r-' c::- ~.'::;;) c..n C. -n -I ::r::n nl,.- --orn ..,0 <:~\~~ ~8 ::< N ~~. :~ r:'? N U' ~~~ ~~~~~~~~~T.~+~~~~~T.+~~~T.~T.~+T.T.+~++++~+T.++T.++T.T.+++T.T.+T.~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++++++ +++++++++++++++++++ +++++? :+:+~T.~T.+T.+ ~ . . . . . ... .. IN THE COURT OF COMMON PLEAS STATE OF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+:+:+: + '" CHERYL A. NASH Plaintiff VERSUS JOHN G. NASH, Defendant AND NOW, DECREED THAT AND OF CUMBERLAND COUNTY PENNA. No. 2005 - 681 CIVIL JR. DECREE IN DIVORCE ~ .....~ /.''10 p.P! cJOOS , IT IS ORDERED AND J-r' CHERYL A. NASH , PLAINTIFF, JOHN G. NASH. JR. , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT The parties Marital Settlement Agreement dated NOvember 1, 2004 is incor . . PROTHONOTARY B ATTEST: ++++ ++'+'+++++++++++++ J. ~C7 ~ ~ pc'~>1< ~u, fvPJ- ~ ~ ptJ .. . . . \. ,f" .r , 5O-je-? Srlbt'-?