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HomeMy WebLinkAbout05-1012JAMES M. LINDSEY, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA V. CIVIL ACTION - LAW y FM NO. MINDIE S. LINDSEY, 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 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. When grounds 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 Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013. 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 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, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - tab EAST KING STREET - SHIPPENSHURG, PA 17259-1397 JAMES M. LINDSEY, Plaintiff V. MINDIE S. LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, James M. Lindsey, by and through his attorneys, Weigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, James M. Lindsey, is an adult individual presently residing at 21 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257, since 1992. 2. Defendant, Mindie S. Lindsey, is an adult individual presently residing at Dykeman Road, Shippensburg, Cumberland County, Pennsylvania 17257, with a mailing address of PO Box 515, Shippensburg, Pennsylvania 17257, since 2004. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on September 3, 1994, in Shippensburg, 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 the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. & The parties have lived separate and apart since October 12, 2001. 9. The Plaintiff requests the court to enter a decree of divorce. WEIGLE 6 ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1597 WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID # 49634 126 East King Street Shippensburg, PA 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. § 4904, relating to unworn falsification to authorities. Dated: a "a3' bS James \M. Lindsey, Plaintiff WEIGLE & ASSOCIATES. PC, - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPEN56URG, PA 17254-1394 A' 'sue (`l ? -?. ?4 0 ? ?? U? c 0 JAMES M. LINDSEY, Plaintiff V. MINDIE S. LINDSEY, Defendant IN THE COURT OF COMMON I OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-01012 IN DIVORCE ACCEPTANCE OF SERVICE I, Mindie S. Lindsey, do hereby depose and say that on the - ? ( r a / , 2005, I received and accepted service of a true and Divorce Complaint and Notice to Defend and Claim Rights in the I verify that the former statement is true and correct. I understand herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to authorities. Date: /rlfl '7 /7 Mindie L Lindsey J "*day of tested copy of a tied action. false statements n falsification to WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPOENSBURG. PA 17a57-1397 c N ? o __ ? ? R7-.. r- y:.. ?r N ?!'? ?-•ii ( 9 v ?= t. °? rsi . c W °: tf! -a: JAMES M. LINDSEY, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2005-01012; MINDIE S. LINDSEY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on February 28, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Dated: James M. L sey, Plaintiff WEIGLE 5 ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 c u. V;, T. Fn ? 1 5 . - C Cj'7 4)m ? 1 N r JAMES M. LINDSEY, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2005-0101:: MINDIE S. LINDSEY, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 3301(4) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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 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 falsification to authorities. Dated: L James-,Lindsey, Plaintiff WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 r1i 7 . ? % -C tV •< N JAMES M. LINDSEY, Plaintiff V. MINDIE S. LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-01012; IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 28, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Dated: d3 d S? Mindie S. Lindsey, Defenda WEIGLE 6 ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 N d a W -?t? X 7 j§'; N ;Y7 1, , JAMES M. LINDSEY, Plaintiff V. MINDIE S. LINDSEY, Defendant IN THE COURT' OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-01012 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 3301(c) AND 4 3301(d) OF THE DIVORCE CODE 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 unworn falsification to authorities. Dated: &3 le) s Mindie S. Lindsey, DefendanWEIGLE 6 ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 a ', vn . 7 y r. N '-?? C'? J CE) L N N JAMES M. LINDSEY, Plaintiff V. MINDIE S. LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-01012 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: March 17, 2005, by mailing postage paid, at Shippensburg, Pennsylvania. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff, June 25, 2005; by Defendant, June 23, 2005. 4. Related claims pending: None 5. Date Plaintiff's Waiver in § 3301(c) Divorce was filed with the prothonotary: June 29, 2005 Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: June 29, 2005 WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, PA 17257 Telephone (717)532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSSURG, PA 17257-1397 °v- O C." t'7 n ?i O .G D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JAMES M. LINDSEY, ,'"' PLAINTIFF I I No. _2005-01012 VERSUS MINDIE S. LINDSEY, DEFENDANT DECREE IN DIVORCE AND NOW, 2005 IT IS ORDERED AND DECREED THAT JAMES M. LINDSEY PLAINTIFF, AND MINDIE S. LINDSEY ,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; BY THE COURT C ATT S i J. PROTHONOTARY w _,V.1/-L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1 ?/ Plaintiff Vs : IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/ defendant in the above matter, (select one by marking'Y prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated Od JUA- hereby elects to resume the prior surname of 104 )L , and gives this written notice avowing his / her intention pursuant to the provisions o 54 P.S. 704. Date: V A o Signature File No.?Jr ignature of name b ' g resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF &-),M b - ) On the,=o7 day of &J , 200 before me, the Prothonotary or the notary public, personally appeared 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. ' Notary Pu lic COMMONWEALIh Ur Poii,,6irLVANIA NOTARIAL $EAL WENDS L. SHATZER, Notary Public Shippensburg TO, Cumberland County My Commission Expires Uit J, 2009 C ? -n ?• ? N ?Fq vf cS Z sue, rn O ?