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Home My WebLink About05-2686 MICHAEL L. BANGS, ESQUIRE 1.D, NO, 41263 429 SOUTH ISTH STREET CAMP HILL, P A 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF CHRISTINE H. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. DAVID M, MURPHY, Defendant CIVIL ACTION NO, 2005- ,;)/Pfb CIVIL TERM 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 foregoing 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 in 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 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 at; Office of the P J'othonotary Cumberland County Court House Carlisle, Pennsylvania 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 Telephone: (717) 249-3166 . CHRISTINE H. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION DAVID M. MURPHY, Defendant NO. 2005- IN DIVORCE CIVIL TERM NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, This notice is to advise you that in accordance with Section 3302( d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania, You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse, If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice, Failure to do so will constitute a waiver of your right to request counseling. CHRISTINE H. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. DAVID M, MURPHY, Defendant CIVIL ACTION NO.2005- J (p r, CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW comes the aboye-named Plaintiff, CHRISTINE H. MURPHY, by her attorney, Michael L. Bangs, Esquire, and makes the following Complaint in Divorce: I. The Plaintiff is CHRISTINE H. MURPHY, an adult individual who currently resides at 507 Mulberry Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2, The Defendant is DAVID M. MURPHY, an adult individual who currently resides at 3049 Canby Street, Apartment 28, Harrisburg, Dauphin County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and Defendant were married on January 1,2000. 5, There have been no prior actions of divorce or annulment between the parties, 6. This marriage is irretrievably broken. 7, Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling, 8. The Plaintiff requests this Court to enter a Decree of Divorce in this matter pursuant to Section 330 1 (c) of the Divorce Code. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to Section 330 I (c) of the Divorce Code. I verify that the statements made in this Complaint are true and correct I understand that any false statements in this Complaint are subject to the penalties ofl8 Pa. C.S, Section 4904 (unsworn falsification to authorities), .5 //9/0S- Date ~ CHRISTINE H. MURPHY YVk~ ill MICHAEL .BA~S Attorney for Plain f 429 South 18th Street Camp Hill, P A 17011 (717) 730-7310 Supreme Court 10 #41263 '\ ~""' ~ ~, -. '" ~ ''',. ~~ ..J;::,,' "\:, v 'f..J ...... ..;3, ~ \,..... vz ~ ,', \ ~~~ '-:> ~ """ ~ ~'" " ""'- ~ " .. ~~ t ~ Ci t<) :;::::, -;;::1-1 :;.:'~ -"'.. T'-,) v.> (:~) c) c:.::) I.:"") -01 -\ 4- _,_-'"""r1 \-\"1'''-::- ':'7:~'j I:) MICHAEL L. BANGS, ESQUIRE 1.0. No. 41263 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF CHRISTINE H. MURPHY, Plaintiff v, DAVID M. MURPHY, Defendant ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO, 2005-2686 CIVIL TERM IN DIVORCE DEFENDANT'S ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce in this matter in accordance with Pa, R.c.p, 1920.4 and 402(b), DATED: Mailing Address: 43 W, Willow Terrace Road Mechanicsburg, P A 17050 (") ..... = ~ c = ~;,. <.n l..'IT <- :r!.." rT] i c: , Z n1F UJ) I ~g~ -<~ . co 0 r::r^ ::--1 J ~f, -0 T-r. (,5:r.J ::I, -.,,('") C N f3m :;.i::: ~ :;J N \.0 -~ MICHAEL L. BANGS, ESQUIRE LD, NO. 4] 263 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF CHRlSTINE H. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO, 2005-2686 CIVIL DAVID M. MURPHY, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT Pursuant to Pa, RC.P, Rule 1920.72 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 23,2005, 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 in Divorce either after service of a 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, Section 4904 relating to unsworn falsification to authorities, /7-/-0 ,- Date MICHAEL L. BANGS, ESQUIRE 1.0. NO. 41263 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF CHRISTINE H. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 2005-2686 CIVIL DAVID M. MURPHY, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I, I consent to the entry of a final decree in divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses ifI 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 veritY 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, Section 4904 relating to unsworn falsification to authorities. ,}- ;}OC: ated vs. ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINE H. MURPHY, Plaintiff DAVID M. MURPHY, Defendant CIVIL ACTION NO.2005- 2686 CIVIL TERM AFFIDAVIT OF CONSENT Pursuant to Pa, R.C,P, Rule 1920.72 L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Mav 23. 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 in Diyorce either after service of a 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!8 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. A ,:/7'" . / l1;~- c. c'/L/ CHRISTINE H. MURPHY ; l-Ll-OS Date . vs, ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHRISTINE H. MURPHY, Plaintiff CIVIL ACTION DAVID M. MURPHY, Defendant NO. 2005- 2686 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a final decree in 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, Section 4904 relating to unsworn falsification to authorities. 12 -- S . (.is Dated 0,,- /'" /, .4.- /~' / /", '!7/ ----,.,. / / - / (0 / CHRISTINE H. MURPHY - MICHAEL L. BANGS, ESQUIRE 1.0. NO, 41263 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 ATTORNEY FOR PLAINTIFF CHRISTINE H. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2005-2686 CIVIL DAVID M, MURPHY, Defendant CIVIL ACTION - LA W 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: ], Ground for divorce: irretrievable breakdown under Section 3301(c) 33111(8)(1) of the Divorce Code, (strike out inapplicable section) 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on May 31, 2005; his acceptance of service has been filed with the court, 3, Complete either paragraph (a) or (b), (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff: ]2/5/05; by Defendant: 12/2/05, (b)( I) Date of execution of the affidavit required by Section 330l(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 paragraph (a) or (b), (a) Date and manner of service ofthe notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: MAILED 12/9/05. Date Defendant's Waiver of Notice ill Section 3301(C,) Divorce was fil7ith the Prothonotary: MAILED 12/9/05. V\Ar--L.JAi- ? //} / Attorney for Plaintiff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~. .. *,"'~;F,:t;:f."':f.:f. ~~"':f.~:f.~ :f.:f.~:f. :f.:f.~:f."':f.:f.:f.:f.:f.:f.:f.:f.~:f.:f. if. ~:f. :f.:f.:f.~:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f. :f.:f.:f.:f.'f.:f.:I';+: . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ST ,ATE OF PENNA. CHRISTINE H. MURPHY Plaintiff No. 2005-2686 CIVIL VERSUS DAVID M. MURPHY De~endant DECREE IN DIVORCE AND NOW, 'Z>~ z/" z..en.s'"', IT IS ORDERED AND DECREED THAT CHRISTINE H. MURPHY ,_, PLAINTIFF, DAViliD M. MURPHY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f.:f. 't: Of. + Of T. if. +:f.'f. AND , 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; NONE PROTHONOTARY ... +:+'+:+:'F.'+' 'f. T.:f.:Ii"'''':f.''' 'fT.T.'+' '1;'+'+'" . "''fT.'f'fT.'+' '+''+'+'+'T'f.'+''+''+''+'+ if. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J, * }? /"jT"r>"/ r.;krJlL, 50. ze cf ~~V If?:"' %- ,tf'r"l@iJp7) yJ' c:" l.'.y ~