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HomeMy WebLinkAbout05-3576 CATHERINE M. WEEKS Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. !)..([)5" 3-5'7(, ROBERT E. WEEKS, JR. Defendant : CIVIL ACTION - LAW : 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 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 Court Administrator, 4th Floor, Cumberland County Courthouse, Carlisle, Pennsylvania. 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: Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 CATHERINE M. WEEKS Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 05- :J.!'7" Cc..::,..:...( ~ ROBERT E. WEEKS. JR. Defendant : CIVIL ACTION - LAW : DIVORCE COMPLAINT AND NOW, comes Plaintiff, Catherine M. Weeks, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Camp Hill, Pennsylvania, 17011, and files the following: COUNT I - DIVORCE (Pursuant to 23 Pa.C.S.A. Section 3301(c)) I. Plaintiff, Catherine M. Weeks, is an adult individual who currently resides at 56 Pine Ridge Circle, Enola, Cumberland County, Pennsylvania. 2. Defendant, Robert E. Weeks, Jr., is an adult individual who currently resides at 56 Pine Ridge Circle, Enola, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 28, 1983 in Nashville, North Carolina. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably bfoken. 7. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are not members of the Armed Forces of the United States. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. COUNT II - INDIGNITIES 9. Paragraphs I through 8 are incorporated herein by reference. 10. Defendant has caused such indignities against Plaintiff which has made life burdensome and intolerable for Plaintiff, the innocent and injured spouse. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter a decree in divorce dissolving the marriage. Respectfully submitted; ~~ James W. Abraham, Esq. Abraham Law Offices 2157 Market St. Camp Hill, PA 17011 (717) 763-1700 Attorney for Plaintiff. Catherine M. Weeks DATE; 7/15/05 VERIFICATION I, (l,f1tl~tL1ur;- /if Wt;TI<-s , the undersigned, hereby verifY and confirm that I have reviewed the foregoing document and the statements made therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: 7-;;-0!:' ~cJ\,~J:\\, \~"tJ~~ CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, upon the following person at the following address on the date stated herein: Robert E. Weeks, Jr. 56 Pine Ridge Circle Enola, PA 17025 DATE: 7/15/05 James W. Abraham, Esquire '(;<J -~ R _. -!.> ~ G tt:: '-1 - (j ~ ~ ~. '- '" <...."':> -\) ~ ",'r..., "'" 5' ~ <,- (') ....., r.:~ 0 ~~.. c.-:;:> " en L. :;:J c.: ,-'71 'T] r- r= -':".1 ~r: 0 CJ1 C,') I !"~) ;::-'" -,-- ~', ~ ('..,----' :L: ~':"~ (") C) ~5in ;2 N :0 -< CATHERINE M. WEEKS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 05 - 3576 ROBERT E. WEEKS, JR. Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 15,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE: ~ \ ?'\l\)\Q ~,~~m.~~ CATHERINE M. WEEKS WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SETION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE: ('\\~ '\ \ ';lIlDL. ~~ffi_~~~ CA TIffiRINE M. WEEKS o c: __ S <) ,.~" f~r' ~ j~;~' ..~, Pc Z :3 ... r-..) <= = 0"' ::J'l': ;;:;.. -< o " ~:o ~.fn :09 ~6 ~~~ om ~ -< N :2 ....l... N -..J Catherine Weeks, Plaintiff V. IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA NO. O~ - 351(, Robert Weeks, 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 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: 7"-/~...od' ~~,-4~ Robert Weeks 2 ~ ~ (::::) c:r' ~;:. ::3t %:n -t:' rr_~ rf', I'; ~ -om 7:::~J~ ,,/:.c - ::rl1 ~~.~ '" 0' r::: ,- ::;~ ..:(, :.-:;:- -0 .._-n y~_. :s:. (4<5 ~" ~C\ - (Sf\' c: __I -7 ~ :2. t" -1 ABRAHAM LAW OFFICES 2157 Market Street. CamD Hill. PA 17011 (717) 763-1700 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05 3576 CIVIL CATHERINE M. WEEKS Plaintiff ROBERT E. WEEKS, JR. Defendant : CIVIL ACTION - LAW : DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section (x) 3301(c) ( ) 3301(d)(l) of the Divorce Code. 2. Date and manner of service of the Complaint: July 20, 2005; see attached Affidavit of Acceptance of Service. 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 on 5/4/06; and by Defendant on 6/6/06. (b)( I) Date of execution of the affidavit required by Section 330 I (d) of the Divorce Code: (2) Date of filing and service of plaintiff's affidavit upon the Defendant 4. Related claims pending: None. 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: . (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: 5/12/06. (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 6/16/06. 4"00 James W. Abraham, Esquire Abraham Law Offices 2157 Market St. Camp Hill, P A 17011 (717) 763-1700 Attorney for Plaintiff, Catherine M. Weeks DATE: 6/16/06 ~ c;:;J d' {-c ~ ~,.. .- 0' C) "" .-' ~:"""n \ti"f~, <l\~' ";'-( ^";',() '~::-'~:..-\~ ,~. ~,~,<:,~~, ::>: ';-0 ':.4. ~ ....'"~ -~ .- ('-> (;0 IN THE COURT OF COMMON PLEAS. CUMBERLAND COUNTY. PENNSYLVANIA CATHERINE M. WEEKS Plaintiff : NO. 05 - 3576 v. : CIVIL ACTION - LAW ROBERT E. WEEKS, JR. Defendant : DIVORCE AFFIDA VII OF ACCEPTANCE OF SERVICE I, Robert E. Weeks, Jr., Defendant in the above-captioned action, hereby accept service of the Complaint in divorce as of July 20, 2005, which Complaint was filed herein on July 15,2005. DATE: / eo-ct-()ct ~-'// ct~o 6J ROBERT E. WEEKS, JR., D dant 0 ....., r' r.::;, c: = ~, -n ,.,:; c..... ,-- -.... (! S'; :1: "T1 "",,- rn r-- \T1 " 0' C_' \:! , , :L' -"..... '-. ,--, ;--,-; "'-'t '"J:>> 1') :':1:1 Ct) -< CATHERINE M. WEEKS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05 . 3576 : CIVIL ACTION - LAW : IN DIVORCE ROBERT E. WEEKS, JR. Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 15, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE: c't-c: -d~ ~/C::~tk ROBERT E. WEEKS, JR. Cl WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SETION 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! 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE: <:b -6 -cJ~ L/~bo4. ROBERT E. WEEKS, JR. o s-.; l'--> = c;::;:J cf' S= ~"."~ .,;.- <'.::) :':'n .-\ Ji:o ., r :"~je :"";, (-.1 c;r. ~"' .,--,..., ~::t?~ ~:~-~l ~I::; ;~ (.,) c:> \ " . . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY . STATE OF . . CATHERINE M. WEEKS VERSUS . ROBERT E. WEEKS, JR. . . . . . AND NOW, . DECREED THAT AND . PEN NA. No. 05 - 35'76 DECREE IN DIVORCE .:r~ ,xl': )s:4.,41 . 2006 , IT IS ORDERED AND ~ eATHERINE M. WEEKS , PLAI NTI FF, ROBERT E. WEEKS, JR. , 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; ~ 1J,l ~ . . . . . . . . . . . ATTEST: J. PROTHONOTARY . . . . .. . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' ~jp ~ ~~ ->>Le.') ~ ~# ,.,-7...; ~I"'? 917.[e. #) .... '. . ." .. J .~. ..1i' ,"','. \ '. .,..:1 .