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Home My WebLink About05-1649 . -- JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE JEFF A. NIBLETT, Defendant NO. 05- /&,<.;q CIVIL TERM 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 right 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 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 Street Carlisle, PA 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. -.J JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE JEFF A. NIBLETT, Defendant NO. 05- I(PH CIVIL TERM COMPLAINT UNDER 23 Pa.C.S. !I!I 3301(c) & 3301(d) OF THE DIVORCE CODE The plaintiff, Julie A. Niblett, by her attorneys, the Family Law Clinic, sets forth the following cause of action for divorce: 1. Plaintiff is Julie A. Niblett, who currently resides at 62 North 10th Street, I st Floor, Lemoyne, Cumberland County, Pennsylvania 17043. 2. Defendant is Jeff A. Niblett, who currently resides at 808 Sherwood Road, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on June 25, 1983, in Camden County, New Jersey. 5. Plaintiff and Defendant have lived separate and apart since November I, 2003. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff or Defendant may have the right to request that the court require the parties to participate in counseling. ~ ,. " WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. jdJkll ,X ilWJTmf>J ~/ essica L. Bowman Certdied Legal Intern ( ',fl!. THOMAS . PLACE ROBERT E. RAINS ANNE MAC-DONALD FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 I 3 717/243-2968 VERIFICATION Understanding Ihat the making of any false statement would subject me to the penalties of 18 Pa. C.S. 94904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. Dated:~ F\ ~h/:u..() .f~ 1J~~ Jtfe A. Niblett ", \.0 -:'1': (;~:: _<! r~~. ~- ~::; '" 2:~~ c..r, c; -<1 ::,' .,. ni-"']-' ~;t,"} (-'.... ;~ ~.'~), t", f"q JULIE A. NIBLETT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE JEFF A. NIBLETT, Defendant : NO. 05- if-Lf"l CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Julie A. Niblett, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date -3 J&q/()C) I / Respectfully submitted, J CflMJ'r'rLcX. '{j()~ Jessica L. Bowman v Certified Legal Intern ~~~-f! ROBER . RAINS J THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 -;1 i \~ (") (" ,-.., ~i_ ,::.:;.-::\ ?:; :::;;:J 1"''',) 1.0 ':'? t<) <.., :0-~ " -------- JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE JEFF A. NIBLETT, Defendant NO. 05- ~649 CIVIL TERM CERTIFICATE OF SERVICE I, Jessica L. Bowman, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Complaint for Divorce on Jeff A. Niblett, at 808 Sherwood Road, New Cumberland, Pennsylvania 17070, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested on March 30, 2005. Service was complete upon receipt by Jeff A. Niblett on the day of March 31, 2005, as evidenced by the attached certified mail receipt card and the United States Postal Service Record of Shipment. ,essica L. Bowman Certified Legal Intern THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Office: (717) 243-2968 Fax: (717) 243-3639 o rn I'- ru U.S. Postal Service", CERTIFIED MAIL". RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) ::r- I'- I'- U1 ,}"3o 17 :; co0D ::r- Cl CertifIed Fee g ~ Return Recl8pt Fee ndorsemenl A6quired) D estrtcted De\~ Fee r-=l ndorsemenl Required) ..... rn Tolal Postage & Fees $ :3 rn D ntTo ~ "!:"/f/;:t::-:/J~:;;Q-;._nn~.' ;'/ ..nmmnnnnn CitY.'Siaia:ZiP;4nm'f?.~K..m.~~.nmQ9gmH.~,.- ---VU..u.J ~~ J 0 A- /', tnt> PS Form 3800 June 2002 See Reversf' for Inslruchon<; Complete items 1, 2, and 3. Also complete item 4 jf Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1, Article Addressed to: C. ignat x \j nt from item 1 . del very acklress below: D. '-==.3 iftO. . G/l ~~. :?(?E~wQlld K<'--dj ~(/.v.U (~d2cnd ) {H-7 I/IOiL') 3. Service Type ~Certified Mail o Registered o Insured Mail o Express Mail ~eturn Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) Kyes 2. Article Number (Copy from service iabel) IL>~$ 3/10000</ ,S;-'771 ,).7S?> PS Form 3811, July 1999 Domestit Heturn Heceipt 102S9S.99-M.17S9 USPS - Track & Confirm Page 1 of 1 ... UNITED STl.iTES ~ POST/J.LSERVa~ Track & Confirm Shipment Details Track & Confirm Enter label number: You entered 70033110000457742730 Your item was delivered at 11 :28 am on March 31,2005 in NEW CUMBERLAND, PA 17070. Here is what happened earlier: Track & Confirm FAQs . ACCEPTANCE, March 30, 2005,11:41 am, CARLISLE, PA 17013 Notification Options . Track & Confirm by email What Is this? G.> . POSTAL INSPECTORS Preserving the Trust site map contact us government services Copyright@1999-2002 USPS. All Rights Reserved. Terms of Use Privacy Policy http://trkcnfrml.smi.usps.com/netdata-cgi/db2www/cbd 243 .d2w/detail 4/5/2005 ~> C:--',) ':-.," .'."", ~. ;-; :""-) C' C) ~n ::: __L..- rllrc= -"'j:c3 , -,:\ .:.! , - v_ - JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JEFF A. NIBLETT, Defendant NO. 05-1649 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under S3301(c) ofthe Divorce Code was filed on March 29, 2005 and served on the defendant on March 31, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. s4904, relating to unsworn falsification to authorities. Date: /t/:joc: r-' = s~ c:-"'l 2::; C) ~'(1 ....,". (jl -cJ ,!;;~ c::> OJ JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JEFF A. NIBLETT, Defendant : NO. 05-1649 CIVIL TERM 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. ~ 4904 relating to unsworn falsification to authorities. Date: IO/oJos' / I I"'~~ fA ~::~ ?1 , C-i', -'" ~r ' ,- .> JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JEFF A. NIBLETT, Defendant : NO. 05-1649 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on March 29,2005 and served on the defendant on March 31, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 subjec to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authoritie. " '/~ J Date: {Ol ~{~o< .1 \ / / \ , "'" (') '" c') c::. f-~ c,:} "., C;'J" z 0 ...,,;;:: I -.J .." -;i",- C:;'> 1'.' - JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JEFF A. NIBLETT, Defendant NO. 05-1649 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301(c) OF THE DIVORCE CODE I. 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! 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. 9 4904 relating to unsworn falsification to authorities. f Date:~ /1 I , ,/ \ \ , \ . \j .....' c? :i,;. ~ q ~ (~\ .-\ -::r:-n ,np -c"'-'\ :~~<:1' (::J,() \ _1 ~l'. -<>; -n ,. , -'-../. .0'-, :-2 C;,? f'o) - -":,,,,-,.; ~~,:';\' ~2. ~'~ JULIE A. NIBLETT, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W IN DIVORCE JEFF A. NIBLETT, Defendant : NO. 05-1649 CIVIL TERM PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: March 31, 2005, by U.S, mail, certified, restricted delivery, return receipt requested, postage prepaid, 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, October 3, 2005; by Detendant, October 31, 2005. 4. Related claims pending: none. 5, Date Plaintiff's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: October 5, 2005, Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: November 7, 2005. Date 121/~/2tJor F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 -------- - JULIE A. NIBLETT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JEFF A. NIBLETT, Defendant NO. 05-1649 CIVIL TERM CERTIFICATE OF SERVICE I, Douglas James Boorstein, hereby certify that on this 14th day of December, 2005, I have served a true and correct copy of the following on Jeff Niblett: Defendant's Waiver of Notice ofIntention to Request Entry of a Divorce Decree Under S3301(c) of the Divorce Code; Defendant's Affidavit of Consent; Plaintiffs Waiver of Notice ofIntention to Request Entry of a Divorce Decree Under S3301(c) of the Divorce Code; Plaintiffs Affidavit of Consent; Praecipe to Transmit Record; and Divorce Information Sheet Service was accomplished by first class U.S. mail, addressed as follows: Mr. Jeff A. Niblett 808 Sherwood Road New Cumberland, PAl ames Boorstein Legal Intern Date: lZ!lY/ZOCj- f I F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 -;\ ., ~. ------- :+.:+.:+.:+.:+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , , -, . . . ... . :+.:+.:+.;1; . . .. . 'fOOf.:+':+::+' :+:'+;f.;-:+::+':f. :+::+ +.Of + +.:+:Of +:+:+ Of+ +:+. +:+.:+:+:+:+ 'f + . , . . . . . , . . . . . , , . . . , . . . . , . , , . . . .. . IN THE COURT OF COMMON PLEAS STATE OF JULIE A. NIBLETT, Plainiff VERSUS JEFF A. NIBLETT, Defendant . , , . . , . . . . , . . . . . . . . . . , . , . . . . . , . . . . . . . . . . . . . . , . . . . , . . , . . +:+::+::+::+: Of.:+: AND NOW, DECREED THAT AND OFCUMBERLANDCOUNTY PENNA. No. 1&'-/7 -~ ?OO') DECREE IN DIVORCE ~ OZ-\ \ .- "lJ.1I' '--' IT IS ORDERED AND JULIE A. NIBLETT , PLAINTIFF, JEFF h. NIBLETT , 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 OROER HAS NOT . :+::+::+:+:+::+::+::+::+ NONE Am,??~ PROTHONOTARY . :f.:+:'f:+. :f.:+:+: 'f:+::+ +:+::+:+: :+:+::+::+.:+: +'t:+:+:+:'f++++:+++++:++ :t::+.:+::+ :+:+:+::+:+ . . . . . . . . . . . . . . , . , . . . , , . , . . . . . . . . J. . . . . , . . . . . . . . . . . . , . . . , . . . . . . . . . . , . . . . . . . . . " ~? ~r-- ??;2-<3'L; /~ f?~??Y/ ~~ . . .. . . . <;:/ 0:'& Wi::'C'c:"/