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Home My WebLink About05-3411 SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, PA JOEL WORRALL, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. LINN WORRALL Defendant CIVIL ACTION - DIVORCE : NO. CIVIL TERM : 0S--.34// : 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 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 the Cumberland County Court House, Carlisle, Pennsvlvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 <;;ET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 32 BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAlDIS, SHUFF, FLOWER & LINDSAY Attorneys for PIa' tiff By: Carol 1. Lind Attorney ID# 3 26 West High Street Carlisle, P A 17013 Phone: (717) 243-6222 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A JOEL WORRALL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. LINN WORRALL Defendant CIVIL ACTION - DIVORCE NO'//);:'-3 CIVIL TERM \\AI 'f II IN DIVORCE COMPLAINT JOEL WORRALL, Plaintiff, by his attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: I. The Plaintiff is Joel Worrall, who currently resides at 106 North Market Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since December 2, 2004, 2. The Defendant is Linn Worrall, who currently resides at 805 Grantham Road, Grantham, Cumberland County, Pennsylvania, 17027 where she has resided since August 2000, 3, The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing ofthis Complaint. 4. The Plaintiff and Defendant were married on June 12, 1999, at Saegertown, Crawford County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. SAlOIS lUFF, FLOWER 8< LINDSAY .nORNEVS'AT-LAW 6 W. High Street Carlisle. P A II I , 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff ) By: Caro J. Lind a , Esquire Attorney ID 44693 26 West High Street Carlisle, P A 17013 Phone: (717)243-6222 Date: 1/ r; /t)5 I I SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A VERIFICATION I, the undersigned, hereby verifY that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, Ii 4904, relating to unsworn falsification to authorities. Date: /)(,/';).ou;- I , ~ -i-P ~ ---1J1 Joel Worrall ~ ~ ~ ~ \\ ~ --- RJ 1) - 0 t' ~ '" ..{) ~ 0 (\ ~ r () c: ~~~ ""'t.\ c;~ ,'"'n..' ,._, ":"":' r:~ (: ?tc' ~~f: z =<! ,;.'. ......, = = c.n L. c: ,- I en '::> V1 \.D o " S:!" n,p -om '221' ::'!CJ -,J~T' f:.:;:-d -"7 C) (srn :~ ..0 -< ~ -0 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 w. High Street Carlisle. PA JOEL WORRALL, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : CIVIL ACTION - DIVORCE : NO. 2005-3411 CIVIL TERM LINN WORRALL Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, DAVID R GETZ, attorney for the above named Defendant accept service of the COMPLAINT IN DIVORCE on behalf of Linn Worrall and certify that I am authorized to do so, Dated: ::s- 0 ~ j):;2 ) ,~ U I, uG,::> I By: f" David R. Getz, Esquire Wix, Wenger & Weidner, P.C. 508 North Second Street Harrisburg, PA 17101 ",> C:::-J t::;::::> w"' '- c.'..:. j"-- \"0 co "-R o -" cr, '.... ~::D ,.,'-;.. '''l\:-: ~ ':~J '-..j ), ,).~ _, ~-'i .:~~: 7:~ .',c'\"'\ .-' .<--~ 5) C< SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLAW 26 W. High Street Carlisle, P A JOEL WORRALL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3411 v. LINN WORRALL, 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 July 8, 2005. An Acceptance of Service was filed with the Court on July 28,2005. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was filed with the Prothonotary: By Plaintiff: October 9, 2005 By Defendant: October 11, 2005 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated August 1, 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 9, 2005 By Defendant: October 11, 2005 Dated: to f/1l OE Carol J. Un sa , SAlOIS, S , FLOWER & LINDSAY 26 West H ig h Street Carlisle, PA 17013 (717) 243-6222 SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLA W 26 W. High Street Carlisle. P A CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual(s), via first class mail, postage prepaid, addressed as follows: David R. Getz, Esquire Wix, Wenger & Weidner, P.C. 508 North Second Street Harrisburg, PA 17101 SAlOIS, SHUFF, FLOWER & LINDSAY Carol J. in say~ E Supreme Co o. 44693 26 West High Street Carlisle, PA 17013 717 -243-6222 II -0 \..... .< c (.-f " SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A II !. I; II It I' I' II JOEL WORRALL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 2005 - 3411 CIVIL TERM LINN WORRALL, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on July 6, 2005. 2, The ma:-riago of plaintiff and defendcmt is ;rre~rievab!y b~oken 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 J1!/:ipOU) -J ~ P ~ JOEL WORRALL, Plaintiff 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 wi!! 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. iJJ --.J J7f 0 ~~~ JOEL WORRALL, Plaintiff Date: 16 /1 / ,?-{JU\ I I ~___~. cr. .. ,;f\ ....------- JOEL WORRALL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-3411 LINN WORRALL, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complalnt in Divorce under Section 3301 (c) and (d) of the Divorce Code was filed on July 6, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of the Final Decree of Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I participate in counseling prior to a decree being handed down by the Court. I verify that the statements made in this Affidavit are true and correct. 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: :~b.u- /0 1...{x)s ~~2d~ t1 Worrall ~=) -n :=:J \ ,\ \. ~, I.,_J~ Ul c: JOEL WORRALL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-3411 LINN WORRALL, Defendant CIVIL ACTION - LAW IN DIVORCE 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsifications to authorities. Dated: &robe//- 1/, 2..&:J5 '" ,-:-' :-;1 t, \\ \,D o -n (.C\ (;:~ , .. :to;,;,..,;+;:+. ~~~;f. ;f.~~;f. ~~~ :f. ~ '" :f'f+. :4' '+ :+; ;f. :+: 'f '+ "'''' ++' +.'++ . + .. , , + . + . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . + . PENNA, STATE OF + . + . + + JOEL WORRALL 05-3411 No. . . . + . . . + VERSUS LINN WORRALL . . . . . . . . . . . . . . . . . . . . . . . . . . . DECREE IN DIVORCE ~'f- 2-"1 0u-.-- JOEL WORRALL AND NOW, IT IS ORDERED AND ,--, DECREED THAT . PLAINTIFF, LINN WORRALL , 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; The terms of the Separation and Property Settlement Agreement dated August 1, . . . . . . 2005, are incorporated, but not merged, into this Decree in Divorce. . . . . . . . . . . . . . . . . . . . . PROTHONOTARY :to: +:t: +':+. +' ++. 'l':t + 'to '" +:+. :+ +: i' +. 'Ii '+ "l' '" '+' i' .. Of:+ "" Of . + . . +.. .. + . . . . . + . . . . + + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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