The URL can be used to link to this page

Home My WebLink About05-4405 DAVID J. ADAMS, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. OS -1..JLJDS C-IU~L'-T9l-.~ CIVIL ACTION - LAW IN DIVORCE JULIE M. ADAMS, 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, 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: Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 800-999-9108 CLECKNER ~7l:~N BY~~ s 1. Shatto Attorney I.D. No. 25675 119 Locust Street P. O. Box 11847 Harrisburg, P A 171 08-1847 (717)238-1731 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 - .L.J^loS c.~t;J:::-r'E/2-..."'l CIVIL ACTION - LAW IN DIVORCE DA VID J. ADAMS, Plaintiff JULIE M. ADAMS, Defendant COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is DAVID J. ADAMS, who currently resides at 465 Old Ferry Road, Millerstown, Perry County, Pennsylvania, since June 29, 2005. 2. Defendant is JULIE M. ADAMS, who currently resides at 331 Stoner Road, Mechanicsburg, Cumberland County, Pennsylvania, since October of 2003. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 21, 2001, in York Springs, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. 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 l8 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. Dated: //)JJA. ~ 1&, 'tooS - Plaintiff By ennis J. Shatto Esquire Attorney I.D. N . 25675 l19 Locust Street P.O. Box l1847 Harrisburg, PA 17108-l847 (717) 238-1731 Attorney for Plaintiff -fA f:) ~ ..c ~ C> r~ .J::. l.I\ . ,.' ~ I - C) () ()- 4 C> -U ,.(J ~ p=- i- ,....) 0 ~~ -n t.::..>' .....-t .,...,... -r: -ri c:_~ f1'F J..,'~ _'::! p:; ~,,") "';.1 'T '0' )!f;~'~ '-J '.',~ .~.c"'h ::-"" :-... '-:-::::\ -r,.. '0 c::> ::< N ~ - DAVID J. ADAMS, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VB. NO. 05 - 4405 CIVIL TERM JULIE M. ADAMS, CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 26, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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.~4904, relating to unsworn falsification to authorities. Date: /'f/ r0.5- , 2005 (" ~. \ ., - ," C', . --- - DAVID J. ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA : vs. NO. 05 - 4405 CIVIL TERM JULIE M. ADAMS, 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 August 26, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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.s4904, relating to unsworn falsification to authorities. Date: /2)(p , 2005 I:> -i' .--\ .,(\ -- r',,' ',') c:., - ~ DAVID J. ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VB. NO. 05 - 4405 CIVIL TERM : JULIE M. ADAMS, 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 in this affidavit 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. Date: /;?~~ -, 2005 , , ~- DAVID J. ADAMS - Plaintiff ----- ---- ,---, -- 'i;'......' '-? ':./.. - DAVID J. ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05 - 4405 CIVIL TERM JULIE M. ADAMS, Defendant CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) 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. 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: /2-1 lp , 2005 , ::::;1 \\c-\ - ~'.~.' , '". (.,) '-- DAVID J. ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05 - 4405 CIVIL TERM JULIE M. ADAMS, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I accept service of Complaint Under Section 3301(c) of the Divorce Code. Dated: q/(f/O) .~~ . , :...:;'\ c") -- f"''::' '.- c."! . <.-.,. DAVID J. ADAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA va. NO. 2005-4405 CIVIL TERM JULIE M. ADAMS, Defendant 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: By Acceptance of Service dated September 2, 2005, and filed as of the day and time of this Praecipe. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on December 6, 2005; by Defendant on December 6, 2005. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice dated December 6, 2005, and filed with the prothonotary on the day and time of this Praecipe. Defendant's Waiver of Notice dated December 6, 2005, and filed with the Prothonotary on the day and time of this Praecipe. 6. Plaintiff's social security number is 191-60-3939. Defendant's social security number is 178-52-0563. Date: hl7 , 2005 ::.C~.~ Dennis J. Shatto, Esquire Attorney I.D. No. 25675 119 Locust Street P. O. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 Attorneys for Plaintiff ----------- , ~., , -- "'.' " ~~. ;' <' c - --- ~ +.~~~+.~+.+.+.~+.+.+.+.+. +.~+.~+. +. ~~~+.+.+.+. ~+.+.+.~+.~+. +.+.~+.+.~+.+.~+.+. +.+.~+.+.+.+.~+.+.~~+.+.+. ~+.+.+.+.~+.~ . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . . . . . . . . +. . . . DAVTn ,T AnAM!';, Plaintiff NO. 4405 VERSUS ,TfTT.TF. M ~nAM~, . . . +. . . . . . . . . +. . +. . . . +. . . . . . . . . Defendant DECREE IN DIVORCE "J)~ I '1~ 2-<>oS --' AND NOW, DECREED THAT DAVID J. ADAMS . . JULIE M. ADAMS AND . . . +. . ARE DIVORCED FROM THE BONDS OF MATRIMONY. 2005 IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE . . YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT . . +. . . . . . . . . . . +. . Nnnp 'f W7JS ------- . . By THE C . . . . . . . +. . . . +. :t';"+'+':t'+'+' +.+.+.+. .. . +.~+. +.~ "'+. +.+. +. +. "'+.+.+. ~+. +. :+:+. Of. +. Of' +. Of. +. +. +. '+ +. +. +. +. ~ +. +. ~:+: +. +. ROTHONOTARY +. . . . +. . . . . +. . . . . . . . . +. . . . . . . . . . . . . . . . . . . . +. +. . . . +. . . . . . . . +. . +. . . . . +. . . . +. . . . . +. . . . . . . . +. . +. . +. . +. . +. . +. . . +. . . . . . +. . +. . . +. +. '" +. +:"" J. .~ :::r p-?:1'I# ?~~:t.? 7/0 ~?P ft,,? .~ /JrPtu'. ~/ /W ~q/ rIJ/e/ . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA \)o.\J ld J. ilia MS Plaintiff File NcDS- 4'-1 os IN DIVORCE Vs JlJJ1'C ~O(V\S Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, I or . X after the entry of a Final Decree in Divorce dated m I <I ~,S- hereby elects to resume the prior surname of JWI ( ).iane lJJzj~, and gives this written notice avowing his / her intention purs to the provisions y-;;. P .S. 704. . Date:-.1JJ q ) ;;'OQ[P . " . Signature COMMO~T?OI;;PEl)JNSYLVANIA ) COUNTYOF~ . On the R day of ~Jl.l n e- . , 2001e.... before me, the Prothonotary or the notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and aclmowledged that he / she executed the foregoing for the purpose therein contained. sealIn Witness whereoo. h.ave hereunto set my hand he~reunt "S~tm hand. and official ~ >J 'M".lI~WtAU H Qt PENNSYLVANIA D NOTA '=?Ul~ SEAL ARCIE A f' Not. ~ 8oro Of. c.....arl '...~mber~~~l~b"C Prothonotary or otary Pu~ ~ Com~I?S;.., 1~u:es.No\l..24,- ~~~ty9 - ~ ~ -- 5:Q:I ('"') '<00 C C"> a :> 3: o :::0 3:' 3~("') c ~. C') ;:;; :z ~Ql 2~ _. ::!. :> 0 r>", o -.' ~ :::l!a....,~r- ",_Cll --:to -I ~ ~:::o:r: ::;. ~r); 0 ~32r-"Tj :zg~~ -0 O::!.Ql:>/'TJ :c: Ql ... r- :z :::J '< :z NQ. en _.:a. C"> ~ -< NOtr r- 05::: ~ ~qO ~ :> T( -'9. r-:l 0 = = -n CT' ~ '- ::r!-n s; f11p () ~:;':- ,-" .' "" - ~ () \..0 C< g :;,:".. -I.., -.. C~, r CS i-n CJ CO ~ ~