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HomeMy WebLinkAbout05-2753 LARRY E. WRIGHT, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LA W ~ No. O~ - ;l/~3 {!t~~L RA....~ KATHY J. WRIGHT, Defendant IN DIVORCE NOTICE 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 arumlment 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 the CUlllberland County Court House, High and Hanover Streets. Carlisle. 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, P A 17013 Phone: (717) 249-3166 (800) 990-9108 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, LARRY E. WRIGHT, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION LAW No. Os- - ~ '7~.3 (Ju~L~'( KATHY 1. WRIGHT, Defendant IN DIVORCE COMPLAINT UNDER SECTION 330Hd) OF THE DIVORCE CODE I. Plaintiff is Larry E. Wright, Jr., who currently resides at 45 Scrafford, Street, Cumberland :>h'l'r~"s6u.l"1' Pt,. County, Penmylvania, SInce March 15,2005. 2. Defendant is Kathy J. Wright, who currently resides at 4 West Main St., Apartment #2, Walnut Bottom, Cumberland County, Pennsylvania, since March 15.2005. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 2, 1998, in Newville, Pennsylvania. 5. There have been no prior actions of divorce or for armulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. .. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: 11~ V 2 ~ 2o(jJ- Respectfully submitted, / / Rominger, Bayley & Whare ;2 K.irl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme CourtLD. #81924 (717) 241-6070 .. LARRY L. WRIGHT, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION LAW No. (<)5"-.2 75'3 6.;;J' ..,;:;~ KATHY J. WRIGHT, Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 330Ud) OF THE DIVORCE CODE I. The parties to this action separated on March 15, 2003, 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 rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 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. ~ 4904 relating to unsworn falsification to authorities. - - Date: J -d:)-OS t7?~ Larry E, Wright, Jr. Plaintiff . VERIFICATION I verity 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. ~ 4904, relating to unsworn falsification to authorities. Date: J -;) 5-0 e;- - . -.l. l'-.:. ~. ~-;-, t t. 1.-\ ....... ~ 't 1 ) ~' Jl ( " , 'i>9. ~ ......... ....() C> f::- ..!:::: ~ ..c:: \) U( (AJ ~(-1 -u F= ~ ~ ,") ~'r'l c"..' __1 --,' -'l~ :-.~ i'~,r.c: '..j \,.~.~. ), t: ... ., ~ ~. - .. - C__"' :.:: <'..1.:' AFFIDAVIT OF SERVICE !~\(. _':::qi~ ' ." (' '- Commonwealth of Pennaylvania County of Cumberland Common Pleas Court Case Number: 05-2753 CIVIL TERM Plaintiff: Larry L. Wright. Jr. vs. Defendant: Kathy J. Wright For: Karl Rominger Rominger & Bayley Law offices Received by ROMING~R LEGAL..!!/ be served on Kathy J. Wright. 4 W88t Main St. ~2. Walnut BottoJTI. PA. 1,~/J~.i9,,1U:r-~, being duly sworn, depose and say that on the _~J Wday of yV)14 Y , 2 at. :~., executed service by delivering a true copy of the Defendant's Counter-Affidavit Under Section 3301(d) of the Divorce Code; Notice; Complaint Under Section 3301(d) of the Divorce Code; Affidavit Under Section 3301(d) of the Divorce Code; Verification in accordance with state statutes in the manner marked below: ~DIVIDUAL SERVICE: Served the within-named person. /( ) SUBSTITUTE SERVICE: By serving as ( ) POSTED SERVICE: After attempting service on --1_ at _ and on --1_ at_ to a conspicuous place on the property described herein. ( ) NON SERVICE: For the reason detailed in the Comments below. Military Status: ( ) Ves or ~o If yes, what branch? Marital Status: ) Married or ( ) Single Name of Spouse COMMENTS: --_._~--~------,----~-------_.-.._--~._~-_.- -,,-_.._-'- ,-.----.----.-.----.--.'--- -- -,'-.---- --,.------'--.-..---------.-- -.- - -- _.---- ---.--.---,.-'--'- ,-------.-'-..-.- -'---- -- ---"-.--' -'- - _.--------,--_.-._---------- - _.-, -,--_.'- -- '--"--'---- - ---.- -...------- ---'-'- -,----"----, -.----.-"---- ------,--------_._----"----- ----,-_.__.-,-_.,----_._._..._._,-'_._.,-_._'~----_._--,----------- I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. -:</sf Subscribed and Sworn to b~ore me on th&--' _ day of ,@~ ,..9N ~ by the affiant who is personall known to me. N~L;r~ .-.. . _...._.~ ~~~f:.;.Ji:,;...~..,.Jl LIlda J. J"""",. NolaIy PebIic c.Ili1lIe Bonl. Clmbet1ard ColRy Myc......laeicln El<jlIres JUy 23. 2006 .........~~I~~.~~se Services, Inc. ~Procet.8 Server's TooIboxV5.5i ROMINGER LEGAL 48 W. High St. P.O. Box 1148 Carlisle. PA 17013 (717) 960-9260 Our Job Serial Number: 2005000165 () s--~, "'" c=o r-..:;:) "-,, t._ ~, ,. :,': ,-0 C") -'11 -' -r:,..... fnr.:. -n~ <~\ ?;J, :-.." -~"~ ;.,.:~ i:"") .<:-rn ,:.> ::::.~ .~~ 1''' U:l LARRY E. WRIGHT. JR, Plaintiff v. KATHY J. WRIGHT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION : NO. 05-2753 CIVIL TERM CERTIFICATE OF SERVICE . . . . Complete items 1, 2, and 3. Also complete Item 4 if 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 mailplace or on the front if space permits. . 1. Article Addressed to: ~~ WD~ l\ \N t'i>\- Ro:.\~ ~\-. ~. d, , 'N~~ ~ n~u~ \ 2. Artlcte Number (Ttansferfrom servIce !abet) PS Form 3811, February 2004 COMPLETE THIS SECTION ON UtLlVtHv A Signature 3.. Service Type JB(pertlfled Malr o Reglster<>d 01 o Express Mail ,5tReturn Receipt for Merchandise l-' ... r::-:~~ _ '" -.-" ~~ 7004 1350 0003 7142 5b59 Domestic Return Receipt 102595-02-M-1540 EXHmIT A ., -r"Jr;: rnr ~~:: ~)':: r::c <- :?;( ~~ ~ f"'-.) ,--~ \J) () -/I ;~f; '~J 1<:,":) '.-'1', .-,' ;-) I'll f'.)o UJ v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 05-2753 - CIVIL TERM : IN DIVORCE LARRY E. WRIGHT, JR., Plaintiff KATHY J. WRIGHT, Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Kathy J. Wright, Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiffs affidavit. Therefore, on or atter June 21, 2005, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, 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 will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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, PA 17013 (717) 249-3166 LARRY E. WRIGHT, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVlL DIVISION KATHY 1. WRIGHT, Defendant : NO. 05-2753 CIVlL TERM 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(d) of the Divorce Code. 2. Date and manner of service of the Complaint: May 31, 2005, was served Defendant by Process Server, Affidavit of Service is attached hereto. 3. (a) (I) Date of execution of the Plaintiff's Affidavit required by ~3301 (d) of the Divorce Code: June 21, 2005; (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: filed on May 26,2005 and served on May 31, 2005. 4. Related claims pending: None. 5. (a) Date and manner of service of the Notice ofIntention to File Praecipe to Transmit Record, a copy of which is attached (Exhibit A): July 15, 2005, via certified mail, return receipt restricted delivery. Date: ) c... ! '1 / t 200] ;:; Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 Attorney for Plaintiff (') c ,....., <:;':':' = <;;.r' <-- c:.~_ ,-_. o"D - - ,-" --' :..:'+':f.;f. . ,+:,+::f.:.+; . :f.o+::f.:f "" :t::f.+: 'f.:f.'f.;f.'f.OfOj.;Of'f: iO:f.ii Of. ;+;'f.:f. :f.+++++ . . . . . . . . . . :f.:f.:f.:+::+: .. . . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . . . PENNA. STATE OF . . . . . Larry E. Wright:, Jr. . . . . . . No. 05-2753 VERSUS . Kathy J. Wright . . . . . . . . . . . . . . . . DECREE IN DIVORCE AND NOW'~ z7 ..-- ~ IT IS ORDERED AND . . . . . . Larry E. Wriqht. Jr. , PLAINTIFF, DECREED THAT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Kathy J. Wriqht , DEFENDANT, AND 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; n . . . . . . . . . . . . . . . . . :f.:f.'f.:+: :+: 'f. '+' '+ Of ;f :l':f.:+: :+: Of' OJ.; OJ.; Of 'f 'f:f.:+::+: '+:f;f I\' +,,+, 'to Of. +'f+'f.:f.+;+:+'f.++'++++ . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . jrp f ~ ~ 5OL'L ~ P ~~ ~,7 J"9 50' LTeL , ~ ... ' . . ~ .