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Home My WebLink About05-4816 JASON WARDEN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW VS. MELINDA WARDEN Respondent . ) I ; NUMBER oS -4J 1'(:) : IN DIVORCE ciu~L~~\ 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 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 the "irretrievable breakdown" of the marriage, a No-FauIt Divorce, as in this case, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cwnberland County, Carlisle, P A. 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, PAS 17013 (800) 990-9108 JASON WARDEN Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. Of: - J-jPfb, C)I~'lL ~Ef~ CIVIL ACTION - LAW : IN DIVORCE MELINDA WARDEN DeCendant COMPLAINT UNDER SECTION 3301<9 OF THE DIVORCE CODE NO FAULT DIVORCE 1. Plaintiff is Jason Warden, an adult individual who presently resides at 5019 S. Dickinson School Road, Carlisle, PA 17013. 2. Respondent is Melinda Warden, an adult individual who resides at 25 N. Dickinson School Road, Carlisle, P A 17013. 3. Plaintiff and Respondent have been bona fide residents in the Commonwealth Cor at least six months immediately previous to the filing oC this complaint. 4. The Plaintiff and Respondent were married on May 30'''' 2003 in Carlisle, PA. (Cumberland County). 5. Plaintiff and Respondent separated on August 29th, 2005. 6. There have been no prior actions Cor divorce or annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff bas been advised of tbe availability of counseling and tbat plaintiff bas tbe right to request that tbe court require tbat tbe parties participate in counseling. Plaintiff waives bis rigbt to counseling. 9. Plaintiff requests tbe court to enter a decree of divorce. ->>2;2-005 ERT co 59 Central Boulevard Camp Hill, PA 17011 (717) 236-6491 I.D. # 07182 Counsel For Plaintiff VERIFICATION I verify that the statements made in this Complaint For a No Fault Divorce are true and correct to the best of my knowledge and related to me by my client, Jason Warden. 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. ERT GOLDSTEIN, ESQ Counsel For Jaso Warden, PlaintifflHusband DATE 00; P -4.. ^[ ,..., ~ ~ ~ ....... (") = ... ~ c ~ :i!:n ~ C> [Bel ~ m~ p' -0 -0 :1'.~' - "'T---. ~ l --. 6"- ~ "'::"'~.,. 6""- CJ:!:::: .:t1 ~ r-:CJ 'v K .." C, ~o ::E m Ii"'"- ~ 5>Q c.:> __, --0 C- .- ?'D ~ 0? ~ : '< (JI b +- ""'f-.. --...:::, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON WARDEN PlaintitTlHusband v. MELINDA WARDEN, RespondentfWife NO. 05-4816 CIVIL TERM DIVORCE AFFIDAVIT OF CONSENT TO DIVORCE 1. A Complaint in Divorce under 3301C of the Divorce Code was filed on the 15th day of September, 2005, in Cumberland County. 2. The marriage of PlaintitT and Respondent is irretrievably broken and more than (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. 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 P A 4904, relating to unsworn falsification to authorities. \./ Date AtdJ. - .2-60(0 ~.L-p~ JASON WARDEN, PlaintitTlHusband {'~) 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON WARDEN PlaintifflHusband v. MELINDA WARDEN, RespondentlWife NO. 05-4816 CIVIL TERM DIVORCE AFFIDAVIT OF CONSENT TO DIVORCE 1. A Complaint in Divorce under 3301C of the Divorce Code was filed on the 15'h day of September, 2005, in Cumberland County. 2. The marriage of Plaintiff and Respondent is irretrievably broken and more than (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. 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. 1 understand that faIse statements herein are made subject to the penalties of 18 P A 4904, relating to unsworn falsification to authorities. Date I~b(k\. \~ tOb , \. ~~. \ I \ ~ \~ \' .\~ ,\,{ l;\.I( i l'- MELINDA WARDEN, RespondentlWife 1 '.) .':' JASON WARDEN, PlaintifffHusband VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05=4816 MELINDA WARDEN RespondentlWife CIVIL TERM IN DIVORCE - NO F AUL T WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE 1. I consent to the entry of a final decree of divorce without further 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. ,- Date1'h )2. .2Lc(:'j, / ~it/~~ -., ., 1"_' r_,." JASON WARDEN, Plaintiff/Husband IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05=4816 MELINDA WARDEN RespondentlWife CIVIL TERM IN DIVORCE - NO FAULT WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE 1. I consent to the entry of a final decree of divorce without further Notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses iff 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. /I' ~o ]:'t r)~v.. .. Date-\- j , - Jt(,\'1 \~. ~ \ ) \}~ ~ ,~k ' \~Jf-\1-'"'- MelissaWarden, RespondentlWife '. , ."tl ::-J "',) i~, ':.,"\ C';) JASON WARDEN Plaintiff/Husband IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-4816 MELINDA WARDEN Respondent/Wife CIVIL TERM DIVORCE AFFIDAVIT OF SERVICE I, Herbert Corky Goldstein, Esquire, hereby affirm that I served the above docketed DIVORCE COMPLAINT on September 20th, 2005, by Certified Mail on the above named Respondent. Return receipt is attached. ':Ejr~ 2 Date~{Y /5- ~ (}O& /'/7~ GtflLdt 0 iLL HERBERT CO GO~STEIN, ESQ. Counsel for Plaintiff/Husband ~..~ SENDER; COMPLETE THIS SECTION . Complete items I, 2, and 3. Also complete ~em 4 ~ Restricted Dellvary 1$ desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. ,.~~~~ .~~ :Jl r{ A<A';'~;l GM) ro.- 110/3 3. Service Type 1&. CertIfIed Mall fi'Reglstered D Insured Mall D Exp.... Mall D Return Receipt fcf Merchandloe DC.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (7"""- from service label) PS Form 3811, February 2004 7004 0750 0002 7281 5978 Domestic Return Receipt 102595-02-M-1540 ~t;i :2 -, ....-; -'" ":-..>"l...J Om -; 53 -< W u.l OJ I \h[ r n"".b ~"",;ff Vs. IN THE COURT OF COMMON PLEAS - . )! COUNTY, PENNSYLVANIA CL'MC>ERLA"{.) No. nL~~ Ni \,ctc:R. Defendant CIVil., ACTION- (; [) - /1-3 1(: PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Co?r entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section ( v) 3301 C ( ) 3301 D of the Divorce Code. (Check applicable code) 2. Datevand manner of service of the complaint ./~~\:G acto ;)...CJc\ C, 3. (Complete either paragraph (A) or (B) .) (A) Date of execution of the affidavit of consent required by Section 3301 (C) of the divorce code: By plaintiff h,J~ .;l...'l.. ,-d:~ C D'.b ; by defendant p. -.2- .~, ,2 7- l' /.. n81 (1lJ.~~ lYJaJc (B) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (D) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent 4. Related claims pending: ^;:, ~ I V (JILle. . 5. (Complete either (a) or (b).) (A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (B) Date plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: fi);-;} '304/ ,200(" I f Date defendant's Wavier of Notice in S 3301 (c) Divorce was filed with the Prothonotary: !i,t-;Zr<? ,~oOb ~(~,p A ey, ore ~tiff OJ/&;) \ ) Defendant ,~3G -"*7/) Prothon. -4 9 ! ;."" ~ (::' ;f.'" Of:+: +. . . +,Of'+.:+; . :+. :+: :f.:+::+: . .. :f.:+: :f:f +' :+::+: +' 'f:f. :+::+:'" +.:+::+. :+.:+: Of' Of':+, Of' Of' +'f' . . . . . . . . . .. . IN THE COURT OF COMMON PLEAS . . . . . . . . . . . . . . . . . . . . . . . . . OF CUMBERLAND COUNTY JASON WARDEN PENNA. STATE OF No. 05-4816 plaintiff/Husband VERSUS MELINDA WARDEN . . . . . . . . . Defendant/Wife DECREE IN . . . . . , " . DIVORCE 1..%11\ F' eo \lNI!>.~'( 2006 --, IT IS ORDERED AND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AND NOW, JASON WARDEN , PLAINTIFF, DECREED THAT AND MELINDA WARDEN , 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 THE COURT: Am~~ ~~ " ~--~~'OCHO'O'^"~ . . . . . . . . . . . . . . . . Of':+:'t''tO+.0f:+:0f' . :+: :f.:f. '+ :+ + '" 't' Of Of. Of. 't. Of' + Of' Of 'f + + :+: :+::+: Of' Of. Of:f. 'f:+: 'f .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + 'to:+: + ++ -*-r. $/ -f! ?"::f;r"'-W ~~ 7 ...... . . I'.'/r.~) ;/ "Ie? , ! f