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Home My WebLink About05-1887 .. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 05"- I <an Civil Term SHEILA R, FOX, vs. JAMES B. FOX, : ACTION IN DIVORCE 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 St. Carlisle, Pa. 17013 (717) 249-3166 : Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SHEILA R. FOX, vs. No. 05 ~ {7?1 Civil Term JAMES B. FOX, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Sheila R. Fox, a competent adult individual, who has resided at 120 E. Louther St., Carlisle, Cumberland County, Pennsylvania, 17013 since September 1, 2003. 2. Defendant is James B. Fox, a competent adult individual, who has resided at 24 Bentley Place, Carlisle, Cumberland County, Pennsylvania, 17013, since 1995. 3, Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 2, 1996 in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for alll1ulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8, Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member ofthe Armed Forces of the United States of any of its allies. ...' 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 1 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. 94904 relating to unsworn falsification to authorities. ~ '--Q, ~l( '4\1.\0'5 Sheila R. Fox, Plaintiff D", y/II/OZ; ams, Esquire J.D. 0.79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~~ - ~ C' D cO oD -& 'J' ___ 'B ~~ i: :<> 3 '" 'O'r- d 1'1,-\ o c::; 1-' = ~ ~ :;:>;;l N -_/ I ~: ::;;;-"\ .p,~~~ -~ -~ €J !~~ -- - - ~ :1 rr'\~ _,",1"1"1 ,,,,0 ~?tC} --:-;::~'; s,:~r) ~;~1(f\ ?i> ,<. r.- (;:) Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA SHEILA R. FOX, vs. No. 05 - 1887 Civil Term JAMES B. FOX, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this April 19, 2005, I, Jane Adams, Esquire, hereby certify that on April 16, 2005, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE was served, via certified mail, restricted delivery, return receipt requested, addressed to: . Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. . prtnt your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailplece. or on the front ~ space pennits. 1. Article Addressed to: CAgonl James B. Fox 24 Bentley Place Carlisle, Pa. 17013 DEFENDANT e. ~1ve<I by (PrinfeJjl NsmeJ. y. pate of Delively.... '-.lA ;es 6. ft>, l..,I'-;(./--(;)Y D. Isdel1vely__"""'lt.m1? EJ.!! H YES, enter delivery adc:Iress below: ~ J ztl'\fs, B. Fo)( 24 Bt'<\\-\('j ~11.tc.e... Ca,t'lisle, PA /70/.3 C I;xpms Moll C Relum ~ for MeId1and1Ie 2. Artfcfe Number (ll8nsfw""'" - label) PS Fonn 3811, February 2004 7003 3110 0004 5775 4542 Domestic Ro!um Recelpl 102S85-02-M-1540 ane !Adams, Esquire LD o. 79465 South Pitt Street Carlis]e,Pa. ]7013 (7] 7) 245-8508 ATTORNEY FOR PLAINTIFF (2 ~, :~~:'~ <-..rI ::::; -n :::~~; ~~v -- I,j:) -- en '"" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COlJ'JTY, PENNSYLVANIA SHEILA R. FOX, vs. No. 05 - 1887 Civil Term JAMES B. FOX, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSEN1: 1. A complaint in divorce under section 3301(c) ofthe Divorce Code was filed on April 12, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken :md ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal 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 corr :t:) also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, ati))!l'to unsworn fal fication to authorities. /' Date: /b~f.lC' o.s:" B ~/James B. Fox" Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE UECREE UNDER 63301(.) AND 63301(d) OF THE DIVORCE CODE I. I consent to entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 ;';:~~~derstand that herein are made subject to the penalties of 18 Pa.C.S. }4904 relating /~brn falsification to ,U3 . ames B. Fox, Defendant .~ Date: /b 4c.t6- '6~ ~, .':. ~ ';J. ~ G-') C,:::; o q. "t 4". p'\e: --nl'!.i }J"--? ::;~?\ ....""'11 '~]f~5~ ..~:.\ :J';~ .:0. ..... -c~ .:,.~ '-P. C ...0 - Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SHEILA R. FOX, vs. No. 05 - 1887 CivJil Term JAMES B. FOX, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT: 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on April 12, 2005. 2, The marriage of Plaintiff and Defendant is irretrievably broken ,rod ninety days have elapsed from the date of the filing and service of the Complain!. 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 correc:!. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.s. 4904, relating to unsworn falsification to authorities. -- Date: 0; I / J- - 0 ; ~~~~r Sheila R. Fox, Plaintiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(0) AND &3301(d) OF THE DIVORCE CODE I. I consent to 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 Prothonotmy. 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 unsw<,rn falsification to authorities. Date: 7' (~ -0 S '-- ~~~ "Q:>\( Sheila R. Fox, Plaintiff ,...., C:5 c;;; ~'l o -n -0 ::;:-_. nlp ;,-: c.::, (/? '" '" w -r.: i:? '-...... 0', Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SHEILA R. FOX, vs. : No. 05 - 1887 Civil Term JAMES B. FOX, : ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following infomlation to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under il3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Served via constable, on September 12,2003. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: September 12,2005 By Defendant: August 16,2005 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: August 30,2005 Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: September 13, 2005 Date: OJ I (01 Os- Respectfullly S~mi~"d~. ~ ~~ e Adanls, Esquire . No. 79465 4 S, Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney tor Plaintiff ~ --1'j1T~, ~"\.J' ~t;.", '!l~:, ,.-;~ ' '~.., "';,- '" ~'c;; y~ ~~ ~ ~ ~~ -;-~\ --0 ~~ ':$ "91 o ~ ~ Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA SHEILA R. FOX, vs. : No. 05 - 1887 Civil Term JAMES B. FOX, : ACTION IN DIVORCE 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 &3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Served via certified mail, restricted delivery, return receipt requested, on April 16, 2005. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: September 12,2005. By Defendant: August 16,2005. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: August 30,2005. Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: September 13, 2005. ~. I ~{or ~ e Ad , squire . No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ( , c ~ ..... = = <J" (/) rn 'V N N ~ -I ::I:,::!J n,- "0'" :1'19 S-.?\~~ :r:-i'i C.) 0 :2:rn o -.. S5 '-< -u ~ {:J w CJl . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . , . . . . . . , . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . "'Of'f'f ++:+';1;++:+.+:+.:+.:+.+:+ . . . . . . . . . . . . . . . . . , . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . ,.,'f:+''f . . . . . . . . 'f++;+; :+::+. 'f'f+:+. 'f "";t;:+. :+. Of. :+.;f.:+. ;f.:+. Of. :+.:+.:+. '10; +.:+.:+. 'f;tO :+. 'f :+: Of.:+. Of:+.;+, IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Sheila R. Fox, Plaintiff No. No. 05 - 1887 Civil Term VERSUS James B. Fox, Defendant DECREE IN DIVORCE AND NOW, }J: .....,L"r.' LeoS , IT IS ORDERED AND 23 .J DECREED THAT Sheila R. Fox , PLAI NTI FF, AND James B. Fox , 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 ENTEREO; None. BY THE COYRT: _t//;f( . . . . . . . . . . . . . . . . . . 'f++:f.'f'f'f'f'+''f'f+++:'l' I . / i (. /l-- I . . A'7ST: -' J. PROTHONOTARY Of:+:f Of. :+. Of. 'f'" Of. Of Of ;to Of;t;:+. +.:f + +'f+'f'f. +'+;f'f+ +:+.+++ +:+. +:+.+ :+.+++ '*';+:;+:'I' :+. , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -*.~ /'7~??pit, ..f.o<;e'j ~ fP $~~,7 'P9 5r?'FC'.(? . '. .t