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Home My WebLink About05-2111 .. (.,1 ~ SHANNON J. MURPHY, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05- ;)11/ Civil Term BONITA D. MURPHY, Defendant ACTION 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 t e 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 y the Court. A judgment may also be entered against you for any other claim or relief requested these papers by the Plaintiff. You may lose money or property or other rights important to ou, 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 t 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 LAWYER AT ONCE. IF YOU 0 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, T E OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HEL Cumberland County Bar Association 32 South Bedford St. Carlisle, Pa. 170 I3 (717) 249-3166 ~ vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0)' ,}.IJ ( Civil Term SHANNON J. MURPHY, Plaintiff BONITA D. MURPHY, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Shannon 1. Murphy, a competent adult individual, who resides at 216 S. 2nd St., Dillsburg, Pa. 17019. 2. Defendant is Bonita D. Murphy, a competent adult individual, who resides in Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for t least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married in August 19, 1995 in Cumberlan County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the partie . 6. Plaintiff has been advised that counseling is available and that plaintiff may hav 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 of the Armed Forces of the United tates of any of its allies. oj 10. The Plaintiff avers that the grounds on which this action is based are: That th marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verity that the statements made in this Complaint are true and correct. I underst d that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to u sworn falsification to authorities. Date: L1/ ?\ 1\ I 0 S- // ( Jane ~dams, Esqmre I.D o. 79465 4 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~ ~ kJ ~ r0 ~ ~ ~ Il,) ~ --, ~ <> v l)d ~ ~ ~ \t\ CJ ,-......> f." ~::.,.; CJ ':.II -n ~.. . . ~'-' \",., N -,' c t:~} '-, :~~ 0 f'-.) @ SHANNON J. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 0 s-- (;11 \ \ ACTION IN DIVORCE Civil Term BONITA D. MURPHY, Defendant NOTICE If you wish to deny any ofthe statements set forth in this Affidavit, you must file a cou ter- affidavit within twenty days after this affidavit has been served on you or the statements .11 be admitted. AFFIDAVIT OF SEPARATION I. The parties to this action separated in 2000 and have continued to live separate d apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verifY that the statements made in this affidavit are true and correct. I understand hat false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to worn falsification to authorities. Date: 020-6 . :t:'-"'2'4:dC..cc,. Shannon J. Murphy, ~ <-' ~~ ,,;;.rl o -n _--1 --c" ':"", 1",) i:-? . .(-. :2 c:> C,.,) SHANNON J. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. ; No. 05' - ~ III Civil Term BONITA D. MURPHY, Defendant : ACTION IN DIVORCE ACCEPTANCE OF SERVICE PURSUANT TO PA.R.C.P 4 02(B) AND PA.R.C.P. 1920.4 I, Bonita D. Murphy, Defendant in the above-captioned matter, hereby accepted service of the Notice to Defend, and Complaint in Divorce, and Affidavit of Separation on May 16, 2005, I hereby waive any and all defects in service of the aforementioned Complaint or any amendments hereto. Date:, . ~ ~\ ) ] Bon~~~ i\1ufphy, Defendant (-) -.n -' -- , ...~? ~ ~\ l..n -." . , SHANNON J. MURPHY, Plaintiff vs. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. OS - '~ II J Civil Term BONITA D. MURPHY, Defendant : ACTION IN DIVORCE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE TO: Bonita D. Murphy. Defendant via personal servicelhand-deliverv. DATE: Mav 16. 2005 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit Therefore, on or after June 5, 2005 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary ofthe Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFlDA VIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 St Carlisle, Pa, 17013 (717) 249-3166 . SHANNON J. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term BONITA D. MURPHY, Defendant ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) ofthe DIVORCE CODE 1. Check either (a) or (b): L(a) I do not oppose the entry of a divorce decree, _(b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) ~(i) The parties to this action have not lived separate and apart for a period of at least two years. ~(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): x..(a) I do not wish to make any claims for economic relief I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses ifI do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party, IfI fail to do so before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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: :: / ,< -- , ",' -... : >l " / Bonita D/M?1rphy, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. ~ c: ' .",.c'- c:) ---- - SHANNON J. MURPHY, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. ; No. 05 - ~ /II Civil Term BONITA D. MURPHY, Defendant ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~330Hc) AND &330Hd) 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 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: 5. / b ' ()~ -- 1 /) Bont(~D, Murphy, Defendant v:' - SHANNON J. MURPHY, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. os- ;X/!/ vs. Civil Term BONITA D. MURPHY, Defendant : ACTION IN DIVORCE C) c: ~" = ,;:::) en "'" ':1 ;:-"';J ", N NOTICE .' -- Ifyou wish to deny any of the statements set forth in this Affidavit, you must file a ~untJ?-' affidavit within twenty days after this affidavit has been served on you or the statementS wili1e admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated in 2000 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand .that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verilY 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: if 2crC6 ~::: .' U Shmmoo J. MWl'hy,-G&; 'Y o " ---1 -~ f'tj~ ell ....~. vs. No. OS - 2111 Civil Term SHANNON 1. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BONITA D. MURPHY, Defendant ACTION 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. Ground for divorce: irretrievable breakdown under &330 I (d) ofthe Divorce Code. 2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted- deliverv. Delivered on: Mav 16.2005. 3. Date of execution of the affidavit required by ~3301(d) of the Divorce Code: By Plaintiff: April20, 2005. Date of filing and service of the plaintiffs affidavit of separation required by ~3301(d) of the Divorce Code on respondent: Filed: Aori122. 2005. Served on Defendant: Mav 16.2005. Affidavit of Service filed: Mav 17. 2005. (Acceotance of Service) 4, Related claims pending: No claims raised. 5, Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary: Served via hand-deliverv. and Defendant signed Acceotance of Service on Mav 16.2005: Defendant signed Counter-Affidavit and Waiver of Notice on Mav 16.2005. Date: \0. "'1 ' Db- dams, Esquire . 79465 S, itt St. Ca . Ie, Pa. ]70]3 (717) 245-8508 Attorney for Plaintiff Q c <; -Oi:r~l ~fT 0\~~.- <;':'- - -, ~;"\_' 6.-c, $c:: ~ ~ ~ I Ct> ~ "3- ~ ~ ~.." f"hj ~~, 6:P 7-~ S\ 2.0 N :..:; -' ------- .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. Shannon J. Murphy, Plaintiff No. No. 05 - 2111 Civil Term VERSUS Bonita D. Murphy, Defendant DECREEINI DIVORCE AND NOW, ..-.- J,.hc... 2.60.s~IT IS ORDERED AND 7_ <. - DECREED THAT Shannon J. Murphy , PLAINTIFF, AND Bonita D. Murphy , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONV. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE . BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT VET BEEN ENTERED; None. BvTHECOURT: / 6.12 j 'T~O U ~=- ( PROTHONOTARV ........ ... . . . . ... . . . . . . . . . . . J. . . . . . . . .' .h ~ ~ ~ 5'1/. Le-1 """'?P p #- ~ k,; -P'7 5'7. Le~ .' u .. .~ .. - ~.,...... ... -... -