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Home My WebLink About01-3547 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. KATHY A. DONOVAN, Plaintiff No. 2001-3547 VERSUS ROBERT P. DONOVAN, Defendant DECREE IN DIVORCE AND NOW, {~ 2- KATHY A. DONOVAN -:J.J'I:) 1, I TIS 0 R D ERE DAN D DECREED THAT , PLAI NTI FF, AND ROBERT P. DONOVAN , 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. /~ By TH E COU RT: ." J",J.' '- , -tt."-/ .i' ',;~~ , ,'" - ,"'- ATTEST: PROTHONOTARY ~ ~ ~ ~ ~~~~~+'T.T.~T.+'+'+T.~T.~~~T.+'+'~+'+'+'+'+'+'T.+'+'+'+'T.~T.+'T.~T.~+'T.+'+'+'+'+'~ J. _~ '% r:'" ~ 117-[0/ t1TTf Y ~ ~ ~?;:1J jt?ItJ/ l. > .. . ' ------. KATHY A DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3547 CIVIL TERM ROBERT P. DONOVAN, Defendant : CIVIL ACTION - LAW : 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: 1. Ground for divorce: irretrievable breakdown under 9 3301(c) JJ81(J) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on June 11,2001 by an certified, restricted mail signed for by the Defendant. 3. (Complete either paragraph (a), or (b).) ( a) Date of execution of the Affidavit of Consent required by 9 3301 (c) of the Divorce Code: by the Plaintiff: September 19,2001; by the Defendant: September 23,2001. (b) (1) Date of execution of the Plaintiffs Affidavit required by 9 3301 (d) of the Divorce Code: (2) Date of serVIce of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: None. 5. (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required. by 9 3301(c) of the Divorce Code: by the Plaintiff: September 19, 2001; by the Defendant: September 23, 2001. Date: September 27,2001 GJVJJ Thomas S. Diehl, Esquire Attorney for Plaintiff o f" -+- ':-.') o - '- :-: ~ o -0 ) KATHY A DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001- J~LIJ CIVIL TERM ROBERT P. DONOVAN, Defendant : CIVIL ACTION - LAW : 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 foHowing 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 2 Liberty A venue Carlisle, Pennsylvania 17013 (717) 249-3 166 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001- 35'17 CIVIL TERM KATHY A DONOVAN, Plaintiff ROBERT P. DONOVAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Kathy A. Donovan, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Kathy A. Donovan, is an adult individual who currently resides at 235 West Willow Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Robert P. Donovan, is an adult individual who currently resides at 235 West Willow Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 12, 1993 in Charleston, South Carolina, 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The 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. WHEREFORE, the Plaintiff, Kathy A. Donovan, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. ~ 3301(c) or 3301(d) ofthe Divorce Code. Respectfully submitted, / /. Date: 'J. /' , i . \\ / /f. !~/ .../> . , -"+. Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX 7. The 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. WHEREFORE, the Plaintiff, Kathy A. Donovan, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. ~ 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, ,/ / I Date: ~- "'- \ I I i v / \. '/' ---- - / ."'C / I. Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX VERIFICATION I verifY 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. S 4904, relating to unsworn falsification to authorities. KATHY A DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3547 CIVIL TERM ROBERT P. DONOVAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDA VIT OF SERVICE AND NOW, this Ith day of June 2001, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Kathy A. Donovan, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Robert P. Donovan by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on June 11,2001. submitted, _~ /JilJ;' Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX .::r- ['- U1 U1 IT' CJ CJ CJ CJ ru ru Name (Pleaae Print Clearly) (To be completed by mailer) rn ROBERT P. DONQy'~______..________..._..._______..______. st;e;i;Api.-No:;-o;.~pci"tjoi-NO'-- - g: 235 WEST WIILOW STREET CJ ciiY:si.ti,.ziji;"4---------.--.-.--....----.---..---------..-----..--------. ['- CARLI Postage $ Cenifled Fee RetUrn Receipt Fee (Endorsement Required) $3.20 Restricted Delivery Fee (Endorsement Required) .7.15 Total Postage a Fees $ r:O ['- rn CJ :11 .... ..... .. . . Complete ite item 4 if Restnct . Print your name so that we can re . Attach this card to the back of the mailpiece, or on the front if space permits. 1, Article Addressed to: o Agent ee DYes o No ROBERT P. DONOVAN 235 WEST WIlLOW STREET CARLISLE, PA 17013 3, Service Type Xl!I Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Copy from service label) 7099 3220 0009 5574 0378 PS Form 3811 , July 1999 Domestic Return Receipt 102595.00.M.0952 ,r/ -rJ ~._' 12.c1 i, . ;~(-. ((J -< r;-...: ~~ f-~j p(= Z __I -< (') C ~~. :::-) tv -1 "'-f -.;..,~ .< KATHY A DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3547 CIVIL TERM ROBERT P. DONOVAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under 9330 I (c) of the Divorce Code was filed on June 8, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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 veri fy 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. 9 4909 relating to unsworn falsification to authorities. Date ~rcr --Ztt> I WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 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. 94909 relating to unsworn falsification to authorities. Date: <'t~( . . Y7 I~F~6V\ KA . ONOV AN, Pla~ff o (/'I f" ~ -+ N -4=:.. r;~1 ;~ ~;~:: (F!; -<... , f~t" '. , ~;; ~~~ :'::3 -, "!Y 6 ",,";I -; c:. ~; ~f) ""',) ....)<, .. c=, KATHY A DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3547 CIVIL TERM ROBERT P. DONOVAN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under 9330 I (c) of the Divorce Code was filed on June 8, 200 I. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C .S. S 4909 relating to unsworn falsification to authorities. Date: c; -ZS-.e:?co( 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 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 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. S 4909 relating to unsworn falsification to authorities. Date: 9 -23 -ZL/O/ a. - 0 r --+-- - 0 ..:} vJ .c j) ~ ,. KA THY A DONOVAN, Plaintitl : IN THE COURT OF COl'vIMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA v. : NO. 2001-3547 CIVIL TERM ROBERT P. DONOVAN. Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Nohce is hereby given that the Plaintiff in the above matter, Kathy A. Donovan, having been grm'1ted a Final Decree in Divorce on the 2nd day of October 2001, hereby elects to resume the prior surname of SIMES and gives this written notice pursuant to the provisions of 54 P.S. ~ 704. Date: (Jet. 15 ZL14 COMMONWEAL TH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the il.P'Tr7 day of Cc.:rof3 tf2... , 2001. before me, a Notary Public. personally appeared the above affiant known to me (or satisfactorily proven) to be the person whose name is subscribed to the within document and acknowledge that she executed the foregoing for the purposes therein contained, IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~c~ 0 J)avVh Notar~ NOTARIAL SEAL SHIRLEY O. DURNIN. Notary Public CariIIe Boro., Cumberland County Commiesion Ex 'res Au .9.2003 (CCOfV 0 c.:; ...... '" .' ~ c '.' ~ "'" I:::) .....:.;;.. -n: ...;~ C"J rnic; , --4 - ~ :;~ ::r-~ i',,) ~ Z\. ..-- UJ ~". .r::' 04 ~ ..' ..-:: ~C-' ~:" 0 2~\~) -t:: L-(--'l ~ :sl >c ~i Z :::l 2:;- ~ .JJ ~ \0 -< , , .eo.. "r~ "-~ 1Mo.. ,...."1'..'::.....\ ft_.... V'" ..,. ".-\ l".~ '\ -' ~. -1\ .. .,......"."- t, 1 . ('1\ 1\ , ( ....~.J. : i . , \ '-'U \ ,1",' I.. _. 0,' ~ I.. :' .t" ......." ' . i \~- ~.. -..'~. '~