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Home My WebLink About01-4164 ;Ii;li;li;li;li;li;li;li;li IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ANNIE M. WINTER. 01-1.{ H." No. {)! lirA CIVIL Plaintiff VERSUS TlMJIlIY A. WINTER, Defendant DECREE IN DIVORCE AND NOW, N4V~ . , IT IS ORDERED AND qr , Zoo I DECREED THAT ANNIE M. WINTER , PLAI NTI FF, AND TlMJIlIY A. WINTER , 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; #IIJ~ ~;;i. ATTES C~~ PROTHONOTARY "';Ii"'''''''''' '" J. /h'~.~J",~vt.1 1().Il//( f#d' ~ ~w 4) n /0/1(-// ~ , ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO. .e1-716~IVIL 01 ..J.f 110 L./ (IN DIVORCE) TIMOTHY A. WINTER, Defendant PRACECIPE 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 ~3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: August 3,2001 by process server. 3. Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code: by plaintiff October 3, 2001; by defendant October 3,2001. 4. Related claims pending: None. 5. Date of plaintiffs Waiver of Notice in ~3301(c) was filed with the Prothonotary: October 3, 2001. Date defendant's Waiver of Notice In ~3301(c) Divorce was filed with the Prothonotary: October 3,2001. lli.M..t m. LOu.:h..r Annie M. Winter, Pro Se (717) 237-6721 401004,1 CERTIFICATE OF SERVICE I hereby certify that on this "3~ day of October, 2001, a true and correct copy of the foregoing "Praecipe to Transmit Record" was served by means of United States mail, first class, postage prepaid, upon the following: Timothy A. Winter 436 Market Street New Cumberland, P A 17070 ~rn.~ Annie M. Winter o ,.- o r> -+- -+:- N , . o ():) '" ~ --, ~. t. ( ;~) ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LA W I NO. 0/- ~/(P4 C~A.-~ (IN DIVORCE) TIMOTHY A. WINTER, 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 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. 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 office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013-3387. 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. LAWYER REFERRAL SERVICE Cumberland County C ill .IiI; _Ge 'lSc-t r A~s tXA c>t,+-r'."Y\ Carlisle, P A 17013 2. Gb-e I- "(., ~'L.... (717) ~1Q f'l()Q 24 Ci-i 1(, (0 ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO. 0/- t/ / (, 'j TIMOTHY A. WINTER, Defendant (IN DIVORCE) COMPLAINT UNDER ~3301(C) OF THE DIVORCE CODE NOW COMES Plaintiff, Annie M. Winter and files the within Complaint Under ~3301(c) ofthe Divorce Code, as follows: 1. Plaintiff is Annie M. Winter, an adult individual currently residing at 823 D Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Timothy A. Winter, an adult individual currently residing at 436 Market Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 3, 1999 In Duncannon, Perry County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 393203,\ 6. Neither of the parties in this section is presently a member of the Armed Forces. 7. The Plaintiff and Defendant are both citizens ofthe United States. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. The Plaintiff and Defendant have produced no minor children. COUNT I - DIVORCE 10. The Plaintiff avers that: (a) the marriage is irretrievably broken; and, (b) the Defendant has offered such indignities to the Plaintiff as the innocent and injured spouse as to render Plaintiffs condition intolerable and life burdensome. 11. The parties to this action have been separated and living apart since March 1,2001. - 2 - WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order of Divorce in her favor. Respectfull y Submitted, By: ~M rn LV~ Annie M. Winter, Pro Se Date:~ - 3 - VERIFICATION Annie M. Winter, deposes and says, subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities, that the facts set forth in the foregoing Complaint Under g3301(c) of the Divorce Code are true and correct to the best of her knowledge, information and belief. Date: -%-", JObl _{Jnnil 01Ji1du- Annie M. Winter ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO. TIMOTHY A. WINTER, Defendant (IN DIVORCE) AFFIDAVIT OF SERVICE The undersigned hereby certifies that on~ a true and correct copy of the Complaint Under ~3301(c) of the Divorce Code in the above-captioned matter was served upon Defendant pursuant to Pa. R.Civ.P. 412 by United States Certified Mail, Return Receipt Requested, postage prepaid, addressed as follows: Timothy A. Winter 436 Market Street New Cumberland, PA 17070 By: Onnu m. U)~ Annie M. Winter 0 " ~~ D .- ,...../ ' r - - 0 ~ -- -b ~ -t::- L i ~ .J {5', ~ ~ "", ~ ~ N 1 ~ , ., (~, C/'i - -. 0 ~ -~ -..1 0iQ '"b ~ b U\ } 'V C, ' ) 4../'. C: '~ --------------- . () 1- .v / & ,L/ ~ (Type of Document) IN DIVORCE ACTION PROOF OF SERVICE (Requesting Agent) ANNIE M. WINTER P.O. BOX 72 NEW CUMBERLAND, PA 17070 (Plaintiff) ANNIE M. WINTER (Defendant) TIMOTHY A. WINTER (Witness Fee) (Case No. & Jurisdiction) CUMBERLAND COUNTY COURT COMMON PLEAS (To Be Served On) TIMOTHY A. WINTER 436 MARKET ST NEW CUMBERLAND, PA 17070 (Accepted By) TIMOTHY A. WINTER 436 MARKET ST NEW CUMBERLAND, PA 17070 (Date Served) 3 AUG 2001 (Time) 6:20 PM (Process Servers Name) NATHANIEL P. RAFFERTY (Process Server's Report) Description: ~ale [ ]Female []Black Hair MBrown Hair [ ]Blonde Hair [ ]Gray Hair [ ]Red Hair []White Hair [ ]Balding ~Moustache Beard [ Glasses ief. [ ] 14-20yrs [ ]21-35yrs p(36-50yrs [ ]51-65yrs [ lOver 65yrs []Under 5' [ ]5 '0"-5 '3" [ ]5'4"-5'8" [ ]5'9"-6'0" }aOver 6' []Under 100lbs [ ] 100-1301bs [ ] 13 1-160lbs [ ]161-200lbs l<:JOver 200lbs Sworn to and subscribed before me this 3 /JUt] day of A :/ Z!'f ~ ~ omm;"mn E:~ - NOTARIAL SEAL JOSEPH F. JOHNSON, Notary PubRc Harrisburg, Dauphin County My Commission. =xE~~~s Feb. 3, 2003 : 0> o S ~~:~; (J) -< ~~: ~~~ ~ ~ - c.f\ .,;-~ l"J N CO ~ J ,::-, :c::- .-- G') c: (0,.-' ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION LAW NO. 01 7164 CIVIL 01 "I..W.. 'f (IN DIVORCE) TIMOTHY A. WINTER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under 93301(c) of the Divorce Code was filed on ~. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 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 ofIntention 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.A. ~4904 relating to unsworn falsification to authorities. Date: CCAobLr"3 j dOD I (1uLu m. W~ Annie M. Winter 0 0 r-, + +. - "v ( ~,~: 0 CP ~ 3 ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO.-61-7164 CIVIL Ol-lill.'f (IN DIVORCE) TIMOTHY A. WINTER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(C) OF THE DIVORCE CODE 4. I consent to the entry of a Final Decree of Divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a divorce is granted. 6. 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. ~4904 relating to unsworn falsification to authorities. Date: ~ J)~\dOO\ D..ru:u (1) - LDuhr Annie M. Winter .~-) ) . ._, C') ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION LAW NOAH 71&4 CIVIL 0/.. '1/f.H (IN DIVORCE) TIMOTHY A. WINTER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under S3301(c) of the Divorce Code was filed on ~. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 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. 4. Pursuant to Pa.R.Civ.P. 1920.72(c), I have waived servIce of Notice of Intention to Request Entry of the Divorce 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.A. ~4904 relating to unsworn falsification to authorities. Date: Ccloku S.~\ i~erfl_t"J~ ------- :.._~ ( ,^, N -------- ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LA W NO. 9-1 716-4 CIVIL O/"JfII.Y (IN DIVORCE) TIMOTHY A. WINTER, Defendant 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! 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. ~4904 relating to unsworn falsification to authorities. Date: ~~J\ d'\, dOc { -1~ A u1nL Timothy A. Winter --------.... Q --- o f'> ..-r c.' ..t:- N .' o CP -<:::> .~ >~"'; ) ~..~ ( ";. -,....;... - - & . ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW O/-"-(Ivl..( NO..o1 71€i4:-CNIL (IN DNORCE) TIMOTHY A. WINTER, Defendant PRAECIPE TO SUBSTITUTE AFFIDAVIT OF SERVICE TO: THE PROTHONOTARY Kindly substitute the attached Affidavit of Service for the Affidavit of Service attached to Plaintiffs' Complaint which was filed on or about July 6,2001. By: ~ rn.L0uJ:.u- Annie M. Winter, Pro Se (717) 237-6721 396467,\ AFFIDAVIT OF SERVICE I hereby certify that on this 3~lJJf~ay of August, 2001, a true and correct copy of the foregoing "Compliant Under ~3301(c) of the Divorce Code" was served by means of Hand Delivery, upon the following: Timothy A. Winter 436 Market Street New Cumberland, PA 17070 396467,1 CERTIFICATE OF SERVICE I hereby certify that on this l'-{.tk- day of August, 2001, a true and correct copy of the foregoing "Praecipe to Substitute Affidavit of Service" was served by means of United States mail, first class, postage prepaid, upon the following: Timothy A. Winter 436 Market Street New Cumberland, P A 17070 CLu...u rn. lUuJ:u- Annie M. Winter 396467,\ -------- Cl <;'C, o ,-- """';'=;\:' \~?;: \ ,,:-,-.... (),/ --". , ,-:> -,. <r 'c}l \-:." ')7 '-/~~ ~ /.-L- ~ ...0 .~ 't Co( ") '1_~~_ " .-< -"Y \.)) ..- - .... ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO. 01-4164 CIVIL TIMOTHY A. WINTER, Defendant (IN DIVORCE) PRACECIPE 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 g3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: August 3, 2001 by process server. 3. Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by plaintiff November 2,2001; by defendant November 2, 2001. 4. Related claims pending: None. 5. Date of plaintiffs Waiver of Notice in g3301(c) was filed with the Prothonotary: October 3,2001. Date defendant's Waiver of Notice In g3301(c) Divorce was filed with the Prothonotary: October 3,2001. 6 n ~1 i m 11)0L:h.r Annie M. Winter, Pro Se (717) 237-6721 401004. ] CERTIFICATE OF SERVICE I hereby certify that on this ;;?rP day of November, 2001, a true and correct copy of the foregoing "Praecipe to Transmit Record" was served by means of United States mail, first class, postage prepaid, upon the following: Timothy A. Winter 436 Market Street New Cumberland, P A 17070 ClJl/LLf rn. W~lf Annie M. Winter 0 c; (~. ,- - ~ t C> < C ~ .' ~ ,"\ ~ '." 0J 4" ):- '? ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO. 01-4164 CIVIL TIMOTHY A. WINTER, Defendant (IN DIVORCE) AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under ~3301(c) of the Divorce Code was filed on 9~ bl d{l>1. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 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.A. ~4904 relating to unsworn falsification to authorities. Date: n6UJ. nlLttt ex I :AOD I ~ rn. W~tr Annie M. Winter a '- -~ C: q ( c 6' en ,,~. - .- >.:l .^ \ --)- \IV -<.. C~ v-i !> <; ANNIE M. WINTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LA W NO. 01-4164 CIVIL TIMOTHY A. WINTER, Defendant (IN DIVORCE) AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under ~3301(c) of the Divorce Code was filed on ~L&-d !O, Xo.l 2. The marriage of Plaintiff and Defendant is irretrievably broken and 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. 4. Pursuant to Pa.R.Civ.P. 1920.72(c), I have waived servIce of Notice of Intention to Request Entry of the Divorce 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.A. 94904 relating to unsworn falsification to authorities. Date: I(-O;>-D/ ~1~ ?I lJ~ Timothy A. W er G ~ QJ C ()'. CQ V\J ~ D ''( :. ) -<. c<