HomeMy WebLinkAbout05-4744
In the Court of Common Pleas of Cumberland County,
Pennsylvania
FRED WAYNE FRITTS, )
Plaintiff, )
vs. )
)
REGINA MARIE FRITTS, )
Defendant. )
No. 05" --- L/lcft.{
CIVIL TERM
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 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 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 Courthouse
Carlisle, Pennsylvania 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.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
In the Court of Common Pleas of Cumberland County,
Pennsylvania
FRED WAYNE FRITTS, )
Plaintiff, )
vs. )
)
REGINA MARIE FRITTS, )
Defendant. )
No. 05'. if 1'1 't
CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in 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) of the 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 of the date on which you receive this notice. Failure to do so will constitute a waiver
of your right to request counseling.
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Michael S. Travis
ID No. 77399
3904 Trindle Road
Camp Hill, P A 17011
(717) 731-9509
In the Court of Common Pleas of Cumberland County,
Pennsylvania
FRED WAYNE FRITTS, )
Plaintiff, )
vs. )
)
REGINA MARIE FRITTS, )
Defendant. )
No. 05- r1'fY
CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
Plaintiff, by his attorney, Michael S. Travis, respectfully represents:
1. Plaintiff is Fred W. Fritts, who resides at 2317 Page Street, Camp Hill,
Cumberland County, Pennsylvania, 17011, since August 31,2005.
2. Defendant is Regina M. Fritts, who resides at 306 Low Road, Cecil County,
Maryland, 21919 since July 2005.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on September 18, 2004, in New
Cumberland, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, Plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years.
8. Plaintiffhas 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.
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9. Neither party is in the Military Service in the United States.
10. 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 18 Pa. C.S. S 4904, relating to
unsworn falsification to authorities.
Date:
1/;3/0 5
ic ae . Travis
Attorney for Plaintiff
LD. # 77399
3904 Trindle Road
Camp Hill, P A 17011
(717) 731-9502
Fax 731-9511
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
FRED WAYNE FRITTS, )
Plaintiff, )
vs. )
)
REGINA MARIE FRITTS, )
Defendant. )
No. 2005 - 4744
CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint.
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Michael S, Travis
ID No. 77399
3904 Trindle Road
Camp Hill, PA 17011
(717)731-9502
FRED WAYNE FRITTS,
Plaintiff,
In the Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
)
No. 2005 - 4744
vs.
REGINA MARIE FRITTS,
Defendant.
CIVIL TERM
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:
I. Ground for divorce: irretrievable breakdown under S 330l(c)(l) of the Divorce
Code.
2. Date and manner of service of the complaint: Complaint was accepted by
Defendant on September 23, 2005, Acceptance of Service filed on October 4, 2005,
Code:
3, Date of exeton ofthe affidavit of consent required by S 3301(c) of the Divorce
by Plaintiff on I. 9 ' 2006; by Defendant on /2--/1,7 , 20af.'
4.
Related claims pending: No economic claims were raised,
5.
prothonotary:
Date Plaintiffs Waiver of.Notice in S 3301(c) Divorce was filed with the
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prothonotary:
D,;&:t;endant's ~~~;h.OfNotice in S 330.1 (c) D~~orc" was filed with the
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'Michael S, ravis -
Attorney for Plaintiff
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In tbe Court of Common Pleas of Cumberland County,
Pennsylvania
REGINA MARIE FRITTS,
Defendant.
)
)
)
)
)
)
No. 2005-4744
CIVIL TERM
IN DIVORCE
FRED WAYNE FRITTS,
Plaintiff,
vs.
AFFIDAVIT OF CONSENT
I. A complaint in divorce under S 3301(c) ofthe Divorce Code was filed on
September 13, 2005.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 verif'y 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 4904 relating to unsworn
falsification to authorities.
DATED:~~~(1)
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
REGINA MARIE FRITTS,
Defendant.
)
)
)
)
)
)
No. 2005-4744
CIVIL TERM
IN DIVORCE
FRED WAYNE FRITTS,
Plaintiff,
vs.
AFFIDAVIT OF CONSENT
I. A cornplaint in divorce under S 3301(c) of the Divorce Code was filed on
September 13,2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. r consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
r 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 4904 relating to unsworn
falsification to authorities.
DATED: J Ii'll 06
I I
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Fred W. Fritts, Plaintiff
--I
;.-;
In the Court of Common Pleas of Cumberland County,
Pennsylvania
FRED WAYNE FRITTS,
Plaintiff,
)
)
)
)
)
)
No. 2005-4744
CIVIL TERM
IN DIVORCE
vs.
REGINA MARIE FRITTS,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER S 3301(c) OF THE DIVORCE CODE
I, 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 affidavit are true and correct. I understand that
false staternents herein are made subject to the penalties of 18 Pa.C.S. 9 4904 relating to unsworn
falsification to authorities.
Date:lr-e)8})5"
~4;;;)/ll.
Re . a M. Fritts, Defendant
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
REGINA MARIE FRITTS,
Defendant.
)
)
)
)
)
)
No. 2005-4744
CIVIL TERM
IN DIVORCE
FRED WAYNE FRITTS,
Plaintiff,
vs.
WAIVER OF NOTICE OF INTENTION TO REOUEST 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 in 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 rne 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 4904 relating to unsworn
falsification to authorities.
Date:
1/7/06
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Fred W. Fritts, Plaintiff
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IN THE COURT OF COMMON
OFCUMBERLANDCOUNTY
FRED WAYIiIF: FRITI'S,
PEN NA.
STATE OF
Plaintiff,
No.
2005 - 4744
VERSUS
RF.GINA MARIES FRITI'S,
iBfendant.
DECREE IN
DIVORCE
PLEAS
AND NOW,_
l' ~t.O 1.(
c.:;r J:sri f.;1
dODb
DECREED THAT
Fred W. Fritts
AND
Regina M. Fritts
ARE D]VORCED FROM THE BONDS OF MATR]MONY.
.
]T ]S ORDERE:D AND
, PLA]NT]FF,
, DEFENDANT.
THE COURT RETA]NS JUR]SDICT]ON OF THE FOLLOW]NG CLA]MS WHICH HAVE
YET BEEN ENTERED;
BEEN RAISED OF RECORD ]N TH]S ACT]ON FOR WHICH A F]NAL ORDER HAS NOT
None.
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PROTHONOTARY
J.
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