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HomeMy WebLinkAbout05-0781 HAROLD E. WHITE, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION - LAW : NO.~ ~ 1jJ{ : IN DIVORCE CIVIL TERM v. DONNAD. WHITE, NOTICE 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 50, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. Ajudgment 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. When 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 in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MA Y 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, P A 17013 Phone: (717) 249-3166 HAROLD E. WHITE, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. ot ~ '7;>( : IN DIVORCE CIVIL TERM DONNA D. WIDTE, COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE I. Plaintiff is Harold E. White, Jr., who currently resides at 118 Big Spring Terrace, Cumberland County, Newville, Pennsylvania, 17241 since January 2004. 2. Defendant is Donna D. White, who currently resides at 33 Mountainview Terrace, Cumberland County, Newville, Pennsylvania, 17241 since around 1990. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on January 13,2002, at Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. 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. S 4904, relating to unsworn falsification to authorities. Date: d"/CI~r;)J- ~,tJ~/ Harold E. White, r., Plaintiff ANDREWS & JOHNSON By: Ronald E. Jo Attorneys for intiff 78 W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 ('~ -tq. -,., f-) r':l ^i "'- C) 1... ~ -- . ,((;) - - G -'-'. , -- ...... .. ;'''1 ... ....... "-' .-,,( r;-;' 0 -- rr:! (J'1 f'"' --. - fA,) ~ 1- ~ ~ HAROLD E. WHITE, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DONNA D. WHITE, Defendant : NO. 05-781 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 11,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have Date: J:,~J J ,:J /O-:Y ~ E lr ).Ln ~--'- Harold E. White, Jr., Plaintiff elapsed from the date of filing 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. ~}.y':, ~~-;:- (J/ ' () (: ~ '.~ ~~';~~:_: 7-; :-': ~ ~, ,- c:. ;;L.: - <...:> Q, ~~ ~. :is.c;J OCl t~; ~~~ />ro o ,_I .V" ":~ "'" :::% t:? .- u:> - HAROLD E. WHITE, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DONNA D. WHITE, Defendant : NO. 05-781 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 330 1 (c) ofthe Divorce Code was filed on February 11,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.s. S 4904, relating to unsworn falsification to authorities. Date: Do ~. ~ ~ <e, -j<" ~- .- "" -0 .,.. t>> .- q, i-~ :16(::1 bb ::?;;~ (~8 -:'a(\\ .-\ ..". '?t. ..- cP HAROLD E. WHITE, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DONNA D. WHITE, Defendant : NO. 05-781 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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 veriJY 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. 94904, relating to unsworn falsification to authorities. Date: s,-)) 0 jo 0~ -;..L#LU~;-~ -If Harold E. White, Jr., P1ai!1tft'f (") c; ---,.. ~";71i'\', '~? . "0,/ ".n. ~ "" c.1" ,- c::; ;.~ l;~\ ~;:~ i__. t~f~,"~ Z. :2. - o "'<1 ~ (niB .-("18 -:0 i db ...-J..1,"' ~,L "'1"\ ('::In -7 fl1 (2\ ?;5. ..<:: w -0 :'1: Cf! - '" HAROLD E. WHITE, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DONNA D. WHITE, Defendant : NO. 05-781 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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. S4904, relating to unsworn falsification to authorities. Date: \ Donna D. White, Defendant J -1C ~5)r ..:.;:;, (r] '~ ;i~~, :;:>~~ ~-;; :< Q s~ ~ 'tA <--, c-; ~... - ~ q. ~~ r 'rIJ ~~, :.-~C -\'"'I. <4z?, 61 ::;J ~ -tJ ~ c.;> .. - cP - HAROLD E. WHITE, JR. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DONNA D. WHITE, Defendant NO. 05-781 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following infonnation, 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: Restricted. certified. return receipt requested on Februarv 18. 2005. 3. Date of execution of the affidavit of consent required by Section 330 I ( c) ofthe Divorce Code: by the Plaintiff Mav 20. 2005; by Defendant June 10. 2005. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in 9330I(c) Divorce was filed with the Prothonotary: ~;1I (- Date Defendant's Waivet of Notice in 93301(c) Divorce was filed with the Prothonotary: ~!JJ/bJ/ { ANDREWS & JOHNSON Date: ~_~ ,2005 By: R nald E. Johnso sq. 7 West Pomfret reet Carlisle, PAl 7013 (717) 243-0123 --- n c ....., => c;-::) en L. ~~; ~"'- o 'Tl ..... :J:-n rnp "ell -jrr) '-::> ~..~~ ~i -)-'1 :~)(~ :'--')rn ::.::.~ "(':=" "n :< w -0 ::;::I: '1? r-> - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+'"., ;+;;F.:f .. . . .. :t::+:if.:+: :+: :f.:+: ;t;;F. ;F. . .. . . ;F. iF.;F.;+; :+::f.;F.;Ii:+::f.:+::t; + +:1' . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Harold E. White, Jr. Plaintiff No. VERSUS Donna D. White Defendant DECREE IN DIVORCE AND NOW, 1-. /5"- DECREED THAT Harold E. Jr White, Donna D. White AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. PEN NA. 05-781 , PLAINTIFF, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f.;F.;F. 'f;+ '+' '+' ++ . ..200J, IT IS ORDERED AND , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD YET BEEN ENTERED; IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT ;?~~ PROTHONOTARY OURT: /-1 ';:>". ~ .. . . . . ;t;,!::+':+:'f;!; . . . .. NONE . . . :+.:+::f.:+: J. -,W ~ ~ 7)( sc? 1/1 147~~ ~ ~ ~.~ - ri7 ~)C'- 1( l' '... ,.'.......-II.,~. , . v" _,,', --. .. -- ~ '-..,J. .".