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Home My WebLink About01-4235 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS CFCUMBERLANDCOUNTY STPTE OF NEIL P. SUNDAY VERSUS AMI M. HAND-SUNDAY PENNA. No. 01-4235 Civil Term 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; I I DECREE IN DIVORCE 1'1 4 ;):'-1' ~.,4f , AND NOW, N~ 2001 , IT IS ORDERED AND DECREED THAT NEIL P. SUNDAY , PLAI NTI FF, AND AMI M. HAND-SUNDAY , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRI MONY. None ", ATTEST: PROTHONOTARY J. . ~\Y' I of''/ 1/ ~'1"''''fl"'vJ-~ 9J-~ .' .' ~"'J ,"t1"Cl ~~V ) ~. ( r'~ r..u~' rJ - IQ{ !i1{1I I ~ . ~~ -'7-- ro'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILP. SUNDAY Plaintiff No. 01-4235 Civil Term vs. AMI M. HAND-SUNDAY Defendant In Divorce - S3301(c) 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 S(3301(c) of the Divorce Code 2. Service. Date and manner of service of the complaint: July 13, 2001, by Acceptance of 3. Date of execution of affidavit of consent required by S3301(c) of the Divorce Code: by Plaintiff October 12,2001 ; by Defendant October 12, 2001 4. Related claims pending: between the Plaintiff and Defendant None. All claims settled by written agreement 5. Prothonotary Date Plaintiffs Waver of Notice III 8(3301(c) Divorce was filed with the October 18, 2001 Prothonotary Date Defendant's Waver of Notice in 8(3301(c) Divorce was filed with the October 18, 2001 o o C :? ~~; CF' . -< ' ~ ~~ _,_I -< o n + N ...c. N ~ "'\:) 3 c o C") -...., ,.......?) -;-:t i:,-:-! :J1 (;:::) :;-; -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILP. SUNDAY CIVIL ACTION - LAW Plaintiff vs. NO. 01 - J..j~ CIVIL TERM C;u~l T~ AMI M. HAND-SUNDAY Defendant 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 foregoing 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 also 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania, 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXIENSES BEFCRE THE FINAL DECREE OF Drv'ORCE 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 Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEIL P. SUNDAY CIVIL ACTION - LAW Plaintiff vs. NO. CIVIL TERM AMIM. HAND-SUNDAY Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302( d) ofthe Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days ofthe date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEIL P. SUNDAY CNIL ACTION - LAW Plaintiff / /. '/ --re., ,/ ,"'- NO. 0/- f/:23.5 L',v, Ie. CNIL TERM vs. AMI M. HAND-SUNDAY Defendant IN DNORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, NEIL P. SUNDAY, by his attorneys, Blakey, Yost, Bupp & Hershner, LLP, and seeks to obtain a Decree in Divorce from the above-named Defendant. 1. Plaintiff is Neil P. Sunday, who currently resides at 119 ih Street, New Cumberland, Cumberland County, Pennsylvania 17070, having resided there since 1999. 2. Defendant is Ami M. Hand-Sunday, who currently resides at 6163 Spring Knoll Drive, Harrisburg, Dauphin County, Pennsylvania, having resided there since February 2001. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing 01 this Complaint. 4. The Plaintiff and Defendant were married on October 3, 1998 in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests your Honorable Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests your Honorable Court to grant the relief requested. BLAKEY, YOST, BUPP & HERSHNER, LLP By VERIFICA nON I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. -- /' Dated: ,/'/ ~\ F~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILP. SUNDAY Plaintiff CNIL ACTION - LAW NO. OJ _ l..f~dS CIO'L c I~ CNIL TERM vs. AMI M. HAND-SUNDAY Defendant IN DNORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint. / Dated: o --- ~ ,. ~ ,..... ~ N U'I N } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA W NEIL P. SUNDAY NO. 01-4235 Plaintiff vs. CIVIL TERM AMI M. HAND-SUNDAY IN DIVORCE Defendant AFFinAViT OF CONSF.NT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 11, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the initial 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. 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. 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. 94904 relating to unsworn falsification to authorities. Date: Odoher 1?, ?001 ------.-.'. ^."._~ (") ~~ -O~,~; 929~' ~:~.~ ~;:C._ ~c j; <;;:; (.,.- ~ ----- C:J - c:? (') """""'t cr.) i'V f'0 , J ':.1 -!~.. ~:J -< - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NEILP. SUNDAY NO. 01-4235 Plaintiff vs. CIVIL TERM AMI M. HAND-SUNDAY IN DIVORCE Defendant W AlVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301 (c) OF THF, OTVORCF, COOF, 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 ofthe 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. Section 4904 relating to unsworn falsification to authorities. Date: Odoher 1), )OO! (') ~ "' -u;:;o- rni'l: 2 iT' ~t, j>~, ~f.2 z; =< C) ("::) :.-, --I ,...., 1..-...-..1 ; c-- ~ .......:,.. tv r,1 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NEIL P. SUNDAY NO. 01-4235 Plaintiff vs. CIVIL TERM AMI M. HAND-SUNDAY IN DIVORCE Defendant AF'FiDA \in 0'11' CONS~~NT 1. A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was filed on July 11, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the initial 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. 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. 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. 94904 relating to unsworn falsification to authorities. Date: Octoher 1), 2001 c;.) -- (") C. -r:;rs' . r[\ ~~,' '-?" "",. !::::i<" tf1> ..4. \/ '~~~, 2 s?-, - . --''> 0>'.""" c:: -'" -- ...." p.) ------- , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW .... __._,N 8\L-__f~ U N0A-f Plaintiff .t File No. 01 - +2-35 vs. IN DIVORCE AN.. \ M, -t\'~b- SU~DA-x.~ Defendant NOTICE TO RESUME PRIOR SURNAME Notice 1S hereby given that the Plaintiff/Defendant 1n the above matter, having been granted a Final Decree in Divorce on the \~-t-l day of_~()Vl?M.(be1t- 2ml . hereby elects to resume the prior surname of __~~ ' and gives this written notice pursuant to the provisions of 54 P.S. S 704. If ~I rJ DATE: -4Z<Or f)2__.___ ~~~AMJ(>. ) _ . / \~re ~ C-AI^A~~U:>~- __ signaYure\ ~~~ being resumed A 11-\..' }./ flll/.{ COMMO~~EALTH OF PENNSYLVANIA: COUNTY OF 8J~~~~;r~ND On the ~~% day of ~NL,L<U-" . ~()O~, before me, a Notary Public, personally appeared the iiJ.bOVe affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. SS. seal. In Wi Lne~;s Wher-eo[, 1 hi'\ve hereunto set my hand and official n 0 :b s; r'~ 0 " -,., (- N -of:; :r1 I-rl iT~ f::.J ~ ~ /::~j I r ~ Z[ GO ,: 0- -< r.::: :~.::': . ~ ....... ~ ~ );;; c::' ~ ~ -..... --0 C\ o,J ~ ...t:: 1'\ en ~ h. ~ } ~----.,-----"-~~ -