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Home My WebLink About05-3304 JEFFREY S. MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; NO. OS-J.3or : IN DIVORCE CIVIL TERM TERESA D. MERCER, 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association P.O. Box 186 Harrisburg, PA 17108 (800) 692-7375 JEFFREY S. MERCER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW : NO. (JS- - 330~ : IN DIVORCE CIVIL TERM TERESA D. MERCER, Defendant COMPLAINT IN DIVORCE NO FAULT I. Plaintiff is Jeffrey S. Mercer, an adult individual currently residing at 336 Zion Road, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Teresa D. Mercer, an adult individual currently residing at 35 Brian Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 27, 1994, in Cwnberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) ofthe Domestic Relations Code. Respectfully submitted, '-'\..< I, Mary 0 atas, Esquire Attorney' or Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document 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. DATE: G~O) ~s,~ JEF REY S. MERCER """"\:) ~ J ~{\ ~ ~ - (;\ c - V v ...j \ ~ ' ~ ~ ~ ..... -..J o f,= '" C::::l (::~.-;. ~:".+"l ( o " .-4 ~ r-tl:c1 r'"' :..-..q ~ eL\ :r. ~ r,.' C:) -;1 ~~? 0''; JEFFREY S. MERCER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW TERESA D. MERCER, Defendant : NO. 05-3304 : IN DIVORCE CIVIL TERM ACCEPTANCE OF SERVICE I, Robert L. O'Brillll, Esquire acknowledge that on or about ~V'-k:.. 3::,0,Zr:(X;:>-- received a copy of Plaintiffs Complaint for Divorce directed to Defendant, in the above captioned action and acknowledge that I am authorized to do so on behalf of Teresa D. Mercer. Date:~ f::::~ (\..U./L-' Robert 1. O'Brien, Esquire 19 West South Street Carlisle, P A 17013 (') C'. ,- ';5 = eJ' (/) ,,,, -"0 ~ ~:!:! hi _ :g t:? 0.0 u:> :b;~ q'b 3m -., f.? ~ a'> -0 ::;:; ;::- .. -;,C j"'::'f',' 2~':":- ,,:..- ~ (1:', r:;C ~):: (' (~~ (> :;'V'C: -'7 ~ -<. SAlOIS SHUFF, FLOWER & LINDSAY AITORNEYS.AT-LAW 26 W. High Street Carlisle. P A JEFFREY S. MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 05-3304 TERESA D. MERCER, Defendant : Civil Action - Law : In Divorce PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301 (c) of the Divorce Code was filed June 28, 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 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 to the best of my knowledge, information and belief. 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: I04tJS- , . ~~~ Jeffrey S. Mercer Q C;, ~ c;.::.') <:1' c:> " -' t--'- ~ ~ fl1~ :?,~ }.-. ~::),Cl ......... ---'-r. -i- -'n -U (~5 C) > :Z:rn .r;: ~ - ~ :-.; --< .' _, _,.,...._"'_' .e;;.".. ' CI' If SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT.LAW 26 W. High Street Carlisle, P A II JEFFREY S. MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 05-3304 TERESA D. MERCER, : Civil Action - Law Defendant : In Divorce PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER~ 3301 ee) 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 to the best of my knowledge, information and belief. 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: lod:o~ , ~~-~ Jeffrey . Mercer ^, ^,..,,^' ...., "'" 0 = en "T) C:> 'i! C> -I f11.::n I -oFT; W ::oC' ~;)(~i '> -:rJ-r. (^ -..~ 92J ".. ^. .r:- e) fn .,::...- ::< ^c-I :'t 0> .< 11 SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS.AT-LAW 26 W. High Street Carlisle. P A II JEFFREY S. MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 05-3304 TERESA D. MERCER, Defendant : Civil Action - Law : In Divorce D~FENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301 (c) of the Divorce Code was filed June 28, 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 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. D t ( I .-') ~?CD~-~- a e:(-- ~ ~,~ o c ( ( :;-,~ ~ "'> c;:,. = CJ' o " -< I W ~ :? --"T'l m~ :nO ~~) I ~,C1 :-i: ~~1,; ~~~ f~ ::....; ~ ~ -0 ::I; .r" Q^\ ,C".", " " ,~" , '51;"';"-- SAIDIS SHUFF, FLOWER & LINDSAY AlTORNEVS-AT-LAW 26 W. High Street Carlisle. PA Ii JEFFREY S. MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 05-3304 TERESA D. MERCER, Defendant : Civil Action - Law : In Divorce DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER6 3301 eel 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 to the best of my knowledge, information and belief. 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: Cc\ :~ '2 CDS ~~wJ () ....> 0 c= ~~~ .;;;::;. -n <..n C> :r " rl-l :IJ -1 -Vij:fl I ""9 w ()c- -r; ,~S~I\ ::i: -"7(") r- arn -, C', ~ " ,Cc ""W""""" " ,,,,,J,,, ",' z',- ',co' c . " SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS'ATtLAW 26 W. High Street Carlisle. P A 1[ JEFFREY S. MERCER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 05-3304 TERESA D. MERCER, Defendant : Civil Action - Law : In Divorce PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel accepted service of the Complaint on June 30, 2005. Proof of service was filed with the Court on September 19, 2005. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was filed with the Prothonotary: By Plaintiff: October 3, 2005 By Defendant: October 3, 2005 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated September 13, 2005 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was filed with the Prothonotary: By Plaintiff: October 3, 2005 By Defendant: October 3, 2005 Ma I SAlOl ,SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle. PA 17013 (717) 243-6222 Dated: October 3,2005 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. P A II CERTIFICATE OF SERVICE I hereby certify that on this 3rd day of October, 2005, a true and correct copy of the foregoing document was served upon the party listed below, via First Class Mail, postage prepaid, addressed as follows: Robert L. O'Brien, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 J nne M. Bartley aralegal to Marylou Matas, Esquire "'u.."",",^""d, ,.. .,. "' c ,,~ = >i? ;;; ~ <oM C) :r Cl rn:n -i -Or:;:; J ::J? '-'" c,-.l( . " ::~j -i:; ~ <?~;: C~. ., aliI m_f ;.", ?t; -- '-, co -< -,- .. :f. ;to :';;t;:f. Of. IN THE COURT OF COMMON PLEAS .. . .. OF CUMBERLAND COUNTY . .. STATE OF .. . JEFFREY S. MERCER . No. . .. . .. VERSUS TERESA D. MERCER . . . .. . .. DECREE IN DIVORCE . . . . . .. .. . . . .. . . Iht Ii AND NOW, JEFFREY S. MERCER DECREED THAT . . . . . . AND TFRFSA n MFRCER . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. PENNA. 05-3304 ;" 2..0~, IT IS ORDERED AND PLAI NT! FF, , DEFENDANT, 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; The terms ofthe Separation and Property Settlement Agreement dated September 13, . . . . . . .. . . . 2005 are incorporated, but not merged, into this Decree in Divorce. .. .. . . .. .. . .. . .. .. . T: c.. t~- , --- . . " , .. PROTHONOTARY .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . .. .. .. .. .. .. .. .. .. .. .. .. .. .. J. .. .. .. .. .. .. .. ~ (? ~ $' /'P:"''' ~ .519' Ii Ilt ~ r "I ~4w F'l 5(/ 6/iJI - ..' .,,;.. ,.~ '" .! ~ ,. -