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HomeMy WebLinkAbout05-0956 fl\d~v\PROUDFOOTccm~~ai~t GREGORY L. PROUDFOOT Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. o .5- <fS-{; Defendant CIVIL ACTION LAW IN DIVORCE HELEN E. SAVIO COMPLAINT 1. The Plaintiff in this action is Gregory L. Proudfoot, an adult individual, who currently resides at 8 South George Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant in this action is Helen E. Savio, an adult individual, who currently resides at 6 Megan Court, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on December 27, 2003, in 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 Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is -1- . irretrievably broken. 7. The Plaintiff avers that no children have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of di- vorce. Date: /' 'J-/?'J- /D \ , STONE LaFAVER & SHEKLETSKI Box E Plaintiff / -2- Fl\div\l-verifi.aff VERIFICATION GREGORY L. PROUDFOOT states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. ~k~V ~REGORY L. PROUDFOOT Date: ~/ -Z-l.-,ot ~C", ......... ~ Cl ~ l..r "",I ~ ~ ~. )-.. ~ "'4, ~ *'" -- ~ ~ c:\ ~;,r' -n '.:~~ \'. I"~ ' ~ ~ '..,"> "'..,} c,) ,.,.,'., ~.-^ 1".,' C"\ C' L' \div\ ,c'f\(:'C.mFOOT'Jn~gory a.f1:"idavi tofservice GREGORY L. PROUDFOOT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-956 HELEN E. SAVIO, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, HELEN E. SAVIO, at 6 Megan Court, New Cumberland, PA 17070, by United States Certified Mail, postage prepaid, restricted delivery,/on February 28, COMMONWEAlTH OF PENNSYlVANIA NOTARIAL SEAL KATHLEEN KEIM, Notary Public New Cumberland Boro. Cumberland Co. My Commission ExpIres Dec. 5. 2006 I receipts. 2005, as evidenced by the attached Certified Mai SWORN TO AND SUBSCRIBED before me this 3"'1-.. day of rr 2005. ~ If ~ 0.. > "0.. E -g ~ ::i ~ 8 .!:::~ 0 E om+-' >- 0) ~1'Jl::.8.s ~.~ ~"Eo.~ M~~~TIE -g>"'O\l,)<tl& n:l~"O.c...o -0 tI:l +-' <ll \D ~""O-g~:5~ ';,S('ljlil.95r E.g~~"2~ 2t)<'\:lctltUC ._QlCOOO 2a:::; ID.~~ ~~o3:::5~ u."'<f" :::"'~..c +-' EE1::'coC 0- ID";::..... ~ 0 ():t:Q 2<l:: 6: . . . . . '6 c m ~ ~ . :> 2 li "ffi "ij) :> ~ .cr: ~ Ed ~~ U'. - Q) ~ "ffi 0.-0 :> ~.~ "0 Q) ~ ~ a? .2 as ~ tl h ~ j '" o 8 oi li .. ~ c 5 0; cr: u t; . E o Q ~ c r- r;::, ~ -+-~- ,S> ~J 3cJ- . ,) j~'~ ~ <;: '-P "Y .:j ;;=- ~-r-.,) .~ '7 ~ o c..; 0{ ~ ~ .--' ;;2 cJ N ~ gJ :i 6 ~ ~ i(J o '[060 /.ODD D22E iC if" iC ir- :-. I J " 66DL Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] L prior to the entry of a Final Decree in Divorce, or _ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of , and gives this ?,;ea;.r:w1/ J.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Mdt! /J RJrJ '7 Plaintiff Vs FileNo, .').S" - Y'J"tp IN DIVORCE }k(FJ.j E <.J}; (/ I r) Defendant NOTICE TO RESUME PRIOR SURNAME written notice avowing his / her intention pursuant to the provisions of 54 P .S. 704. Date: ..;;1.?l.3/()5 ~~ ~hdAfP, #&W~#-~ Signature ' ~.L.1.. -f.tJ#t"".I~ _~~ Signature of name being resumed COMMONWE~L~YLVANIA COUNTY OF On the )!.3 day of ) , 2005 , before me, the Prothonotary or the d the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained, In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. CB~p -- ~. L, i' ex> ,., ~ G--' r-:'? ~ Cf fl\div\PROODFOOTcomplaint GREGORY L. PROUDFOOT Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-956 Defendant CIVIL ACTION LAW IN DIVORCE HELEN E. SAVIO PETITION TO AMEND CAPTION IN DIVORCE COMPLAINT 1. The Plaintiff in this action is Gregory L. Proudfoot, an adult individual, who currently resides at 8 South George Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant in this action is Helen E. Proudfoot, formerly known as Helen E. Savio, an adult individual, who currently resides at 6 Megan Court, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. The Plaintiff and Defendant were lawfully joined in marriage on December 27, 2003, in Cumberland County, Pennsylvania. 4. The Plaintiff filed a Complaint in Divorce on February 23, 2005, which was served upon the Defendant by certified mail on February 28, 2005. 4. The Plaintiff realized the typographical error in the caption on or about February 27, 2005, however, the Defendant accepted service of said complaint one day later. -1- - 5. The Plaintiff now wishes to amend the caption to read the Defendant in this case as "Helen E. Proudfoot", as the Defendant did change her name to Proudfoot upon marriage, and the record should be reflected as same. 6. The parties are now ready to finalize the divorce by filing their consents and waivers and pray that this Court permit the parties to amend the docket caption, and allow the proceedings to move forward. Wherefore, it is respectfully requested that this Honorable Court grant the relief requested, permit the Plaintiff to Amend the Caption in the Complaint in Divorce, and grant any other such relief as deemed fit and proper. STONE LaFAVER & SHEKLETSKI E (2' ~:.c- ',,"~ ".- ::~ -< ...., c:::> r:;;:~ c.n (-~. ~~ Si~ ..~ -1: -r; rl'lp :3 t::1 [::,:J, (~) :~~; d,:', .-'-,;.. "- Ul -1:" ::r: CJ .[..- - fL\di~\PROUDFQOTc~mplaint GREGORY L. PROUDFOOT Plaintiff IN THE COURT OF COMMON PLEAS OF CUMB);:RLAND COUNTY, PENNSYLVANIA v. NO. 05-956 Defendant CIVIL, ACTION LAW IN DIVORCE HELEN E. SAVIO ORDER AND NOW, this 2.. 0 tI, day of June, 2005, the Plaintiff's Petition to Amend the Caption in the Compl,~int in Divorce is hereby --fl. tn~j The Docket at 05-956, shall be amended as follows: Gregory L. Proudfoot v. Helen E. Proudfoot" ~ti 'the Court -1- ALNr;C'Y1 ~", "(" ':'":~~.'H1J 61 :1 Hd I Z tinf' SOOZ AtIV1Ui\jOi-LLOUd 3Hl dO j~)!~:-~o-03l!:J fl\div\PROUDFOOTgregory-consent GREGORY L. PROUDFOOT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-956 HELEN E. PROUDFOOT, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 5 330l(c) of the Divorce Code was filed on February 23, 2005, and served on February 28, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90} days have elapsed from the date of filing the complaint 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. 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. 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. 5 4904 relating to unsworn falsifica- tion to authorities. JUL\t J3. )005 ~2a~R.~ GR GO Y L. PROUDFOOT, Plaintiff Date (') ""' ~ <=> c: <=> ?:: c.n <- ~F1 ~g\ c:: :z: t]5r ... CN -om . ~l"' c::> ~3~ 2'" c ~~ ,< . ",. ~c ::J: -CI Z >c <2 ~ z ~ :z .r:- .c- .< fl\div\PROUDFOOTgregory-waiver GREGORY L. PROUDFOOT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-956 HELEN E. PROUDFOOT, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY ~. OF 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. & 4904 relating to unsworn falsifica- tioD to authorities. JI..I.IAt ~. Qoo'5" Date tf:gjp'~P~ GRE OR ]J. PROUDFOOT, Plalntlff I' g ~ ~ ~::. ;:;;\0: <- %~ tJ,.Q.: ~ 2f'~ (".) ~~~: 0 ~c ~-<i ~C ~ . -;5 ~C, - -\"11 c:: S' 9 ~ .r:- "po .r:- ??: fl\div\PROUDFOOTgregory-consent GREGORY L. PROUDFOOT, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 05-956 : HELEN E. PROUDFOOT, Defendant CIVIL ACTION - IN DIVO~CE AFFIDAVIT OF CONSENT 1. A complaint in divorce under s 3301(c) of the Divorce Code was filed on February 23, 2005, and served on February 28, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 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. 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 falsifica- tion to authorities. '- )~IU...):6, ~<{" Date U//4f/ c:-Ao HELEN E. PROUDFOOT '2 ~- --0\'," ....,p' '7.:""' zf m},' ~( ~~("; be 'Y'C: '7 2. ~ ~ 'B> ~~ o ~~q, 'JJ ~ z~ 6 ~ ;. ~ s::- fl\div\PROUOFOOTgregory-waiver GREGORY L. PROUDFOOT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-956 HELEN E. PROUDFOOT, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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. ~ 4904 relating to unsworn falsifica- tion to authorities. j\f-IAL ",}~\ ~ Date ~~~ HELEN E. PROUDFOOT Defendant a c- ~, ..-o\,~, '0"\-1"" ze %(),;T; -;..;"" 0(..-' Le, \\ ~ q.. 'B- ~ ~ ~~ ~ ,~ ~ ~f<' -- -' ~ ~ ~ GREGORY L. PROUDFOOT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL DIVISION HELEN E. PROUDFOOT, DEFENDANT NO. 05-956 CIVIL TERM PRAECIPE TO TRANSMIT RE,CORD 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) 3301(d) (1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the c,omplaint: FEBRUARY 28. 2005 VIA UNITED STATES CERTIFIED MAIL, POSTAGE PREPAID. RESTRICTED DELIVERY. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code: by E'laintiff JUNE 23, 2005; by Defendant JUNE 23. 2005. (b) (1) Date of execution ~3301(d) of the Divorce Code: and service of the Plaintiff's of the affidavit required by ; (2) Date of filing affidavit upon the respondent: 4. Related claims pending: NONE 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: was (b) Date Plaintiff's Waiver 0" Nottc~ in ~3301 (c) filed with the Prothonotary: ?Lf.lDf25 . Divorce Date Defendant's Waiver was filed with the Prothonotary: of Not~E~n ~3301(c) ("PO(~Lb' ELIZABETH B. Attorney for Divorce 'i'" s;f. ~ ~ ~~ ";:> c;::, ~'r!l. -Q.\.n ~ ,'C.( q{~;c: c;> - b ths" 0 ~~ 2t', ':S": - ~ "':'.0 ~ :::;\ ~2:, <? ~ Yo;? s:- :;z. ::2 Q~ GREGORY L. PROUDFOOT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL DIVISION HELEN E. PROUDFOOT, DEFENDANT NO. 05-956 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infor.mation to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~3301(c) 3301 (d) (1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: FEBRUARY 28, 2005 VIA UNITED STATES CERTIFIED MAIL, POSTAGE PREPAID, RESTRICTED DELIVERY. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code: by Plaintiff JUNE 23, 2005; by Defendant JUNE 23, 2005. (b) (1) Date of execution of the affidavit required by ~3301(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: NONE 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of No;z.ce in ~3301 (c) Divorce was filed with the Prothonotary: ~/J() 0:) Date Defendant's Waiver of Not/Ze~n ~3301(c) Divorce filed with the Prothonotary: ./"" was GI]O 0) /' , l /' ELIZABETH B. Attorney for ,// /~ o c: :2' -oG'J n,{n Z7' z( ~".. r::: C~i ~c 52 ~ -<.. _._~__,_",,~",",__..m..._......._._. "" ~- eJ'I <-- c:. ~ e,..) o ~ C5 ., ~ 0.... o -n -\ ::r:..." tor==: -om :oY 0' ;"'10 :I..-:r;, r"'...-:::: ~(/ (5frl -\ 1;; :~ .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 'f . . . . . . . . . . . , , , , , . , . , . , , . , . . , , . . . . , . . . . , . , . . . . , . . . . . , . . . . Of"" Of Of Of. ... Of. :+:+;t; ... :+;:+:l; :+:+:+:+ :+ . +:f.:+:+:.f.,.,"'''''++ :+ if.:+:f.:+:.f.:+:t::f.'+' :Ii:+:+:Ii:+ Of.:+:+ '+' :+ +:+;:+ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF GREGORY L. PROUDFOOT, PLAINTIFF VERSUS HELEN E.PROUDFOOT, DEFENDANT AND NOW, .TV\1 PENNA. No. 05-956 DECREE IN DIVORCE ~ 2..6oS.~ IT IS ORDERED AND DECREED THAT GREGORY L. PROUDFOOT , PLAINTIFF, AND HELEN E. PROUDFOOT , 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; +'1':+ :tot: :+:+ :+:+ :+:f. Of;tO:+ Of:+:+ "":+:+:+ Of. . . . . . , . . . . . . . . . . . . . J. ATT0 .~ < _ PROTHONOTARY . . . . . . . . . . . :+:+:++:+:++++:t:+ .n :+ Of Of.:+ Of:+ Of.:+::+ :+:+ Of. :+ Of.:+:+: :+ .n , ~ z~ ~ Sr? 1/ -( ~-p~~~.rr; _W-ilL . . . , ' . ":, ...."