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Home My WebLink About05-4998 SHIRLEY A. PERRY, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO, 05 -/.jq'?f Ci u;{~ l~ vs. JAY R. PERRY, 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 the: CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE PA 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 32 S. BEDFORD STREET CARLISLE PA 17013 (1-717-249-3166) vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO: oS -"f99f C!,;",LY~ SHIRLEY A. PERRY, Plaintiff JAY R. PERRY, Defendant COMPLAINT UNDER SECTION 3301 (c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Shirley A. Perry, who currently resides at 670 Old Shannon Road, Boiling Springs, Cumberland County, Pennsylvania, 17007, since 1994. 2. Defendant is Jay R. Perry, who currently resides at 48 Audubon Park, Dillsburg, Pennsylvania, 17019, since 2004. 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 May 6, 2003 on board the Nordic Empress, Hamilton, Bermuda. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The marriage is irretrievably broken. -1- 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 in Divorce. t~ .t.:::~ Es~ire Attorney for Plaintiff I.D. 42752 909 East Chocolate Avenue Hershey PA 17033 (717) 533-7130 -2- VERIFICATION I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 28 Pa.C.S. ~4904 relating to unsworn falsification to authorities. DATE: 81f}/~5 ~(Z Shirley A. pe ~t/ l1 ~ ~ -p - ~ ~ ..c if ~ r---' ~ -l:: CIl 0 c..^"" (C-::> ~ - () ?:~ "-'" :?--n ~ W (/) lk' i'"1 f11r=: ~ ~ -rJ , -0 -otQ ~ N :D 1:: ~ F N "'"J '::i ~T)' ~ ~,-"'n -0 lS~~ ~ ~-',:'. ~ '1? ':2\ <> 0} ~ 0'\ --"'- ...<.- SHIRLEY A. PERRY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -- DIVORCE .lA YR. PERRY, NO. 2005-4998 CIVIL TERM DEFENDANT IN DIVORCE AFFlDA VIT OF CONSENT 1. A Complaint in Divorce under 9330I(c) of the Divorce Code was tiled on September 22, 2005, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree in 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, 94904, relating to unsworn falsification to authorities, ;') )Ju'~' ) /) -u~ (,. I :J>v4y I ;J. /) '7 /OS- Shirley A. Perry Date C) c ~o ,"-' ,~ .:::-..:::) ',~.;'") o -,., :::f T11:JJ {- :-S!Fn ...1'--.., ',~i ,{,!:' ;J,S:;; =3.J -< t:::J P, r;, C) C. ..,-::' ~:> SHIRLEY A. PERRY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - DIVORCE JAY R. PERRY, NO. 2005-4998 CIVIL TERM DEFENDANT IN DIVORCE AFFJDA VIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on September 22, 2005. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ofa Final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are t~ue and correct. I I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsi~tion to authorities. .,,, I' " 'o"i.{.{ / ( lie A/W/' , . '/_ 'q", r- /..... .'" LU ) / Jay R. PerltY Date SIIIRLEY A. PERRY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE JAY R. PERRY, NO. 2005-4998 CIVIL TERM DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 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 thc Court and that a copy of the decree will be sent to me immediately after it is filed wi th 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 I 8 Pa.C.S.A. 94904 relating to unsworn falsifications to authorities. n /)tlG~C '-?J e, (l~Ld Shirley A. Perry 17. /"1 C) {)r- I Date ;.~; 0 c.":) -n .:.J' t:::J rT~ ..:-;. (...) o >',~J c:) ,D SHIRLEY A. PERRY. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION .- DIVORCE .IA YR. PERRY. NO. 2005-4998 CIVIL TERM DEFENDANT IN DIVORCE WAIVER OF NOTICE OF lNTENTION 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. S4904 relating to unsworn falsifications to authorities. j-'J /) I;;~ /' /2 -Ji of , . Jay R. Pe/ry Date (~ -t~ :":.Cl C') r':~ , , (....) c:.: C'":,' ,,0 SHIRLEY A. PERRY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE JAY R. PERRY, NO. 2005 -4998 CIVIL TERM DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, George W. Porter, Esquire, do swear that I served true and correct copy of the divorce complaint filed in this matter on Defendant Jay R. Perry, at his address of 48 Audubon Park, Dillsburg, PA 17019 by way of regular and certified mail, restricted delivery, return receipt requested. The return receipt evidencing the completion of service, signed by Defendant Jay R. Perry, is attached hereto and marked "Attachment A~'. This service was made in accordance with Pennsylvania Rule of Civil Procedure 1930.4 (c). Gf?,~",~g~ On the 29th day of December, 2005, before me, a Notary Public, personally appeared George W. Porter, who signed this document before me, for the purposes therein stated. Q.fJ<.hJ.-" L (~1SI1f/lA- NOTARY PUBLIC ~ Notarial Seal Carol L. Espenshade. Notary Public Derry Twp., Dauphin County My Commission Expires Aug. 31. 2006 Member, Pennsylvania Association otNotaries . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is 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 mailpiece, or on the front jf space permits. t JAY R. ?cj:.~'i. LJ r- A l) l> ,Ie (}41 ~ Ie. j)111s.8u~" i~ o Agent o Addressee c. ..Qat~ o.Wefjxp-- (f\J.J L) DYes o No 1. Article Aadressed to: 3.~rvice Type Certified Mail \). egistered B Insured Ma.il o Express Mail o Return Receipt for Merchandise o C.O.D. 2. Article Number (Transfer from service 1[, () I C; 4. Restricted Delivery? (Extra Fee) 7003 1680 0004 6487 9726 es PS Form 3811 , February 2004 Domestic Return Receipt 102S9S-02-M-1540 : ...D ru P- IT" U,S. Postal Service,. CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage provided) . '.: P- I } '" ;;r- ...D Postage $ .$7 ;;r- Certirled Fee ~. ~6 D D Return RecieptFee D (EndOlsemem'Required) D Restricted DelivetyFee 3 "5>0 '" (Endorsement Required) ...D t.. I 7 r'f Total Postage & Fees $ rn D D P- I /~~ f,~J~~ /,~.,:" Here :;i", 11 ~ ATTACHMENT A SHIRLEY A. PERRY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - DIVORCE JAY R. PERRY, NO. 2005 -4998 CIVIL TERM DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infonnation, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under S (3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: September 29, 2005, Certified mail, restricted to addressee only, returned receipt received, in accordance with PA.R.C.P. 1930.4 (c). 3. Date of execution of the affidavit of consent required by 9330] (c) of the Divorce Code: by plaintiff December 29,2005; by defendant December 29, 2005. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice was filed with the prothonotary: December 30,2005, Date Defendant's Waiver of Notice was filed with the prothonotary: December 30, 2005, . /"-1- 1.7/-(I"~^ 0/ I~~/i~ Attorney fo .' laintiff George W. Porter 909 East Chocolate Avenue Hershey, PA ]7033 1.0. #42752 .__f r--> c',:::':' C:.-;,. C;--'l S:2 " C.::J ~.'..:: . , :.::1 rh :!J " D~ ~-,-' I ~--~'! C,) C) () ;-n c:::; \/:) -"", :< r--..) c::) C~ (~,rl o f'>'; " C) -n :::1 f':"'1:D ,- -:jrn ,-_.,,-...., ~ 'r' "-;~J c',".; C C} :.f~~ ""J \;? ~~ ~~~~~~~~~++~++~~~~+~+~+~ ~~+~~~+++~+~~~+~++~~+~+++++~++++~~+~++++++~~ . . . . . . . . . . . . . . . . . , . . . . . . , . . . , , , . , . . . . . . . . , , , , . , , . , , . . . . . . . . . . . . . . . . . . , . . . . . . , . . . , . , , , . , , . . . . . , . . . . . . . , . ~ +~~ +~+~+++++++++++++++++++? ++ ~ + + + + + + , , . . . . . . . . . , . . . . . . . . . . , . . . . . . . , , . . . , , , , . . . . . . . . . . . . . , , . . , , . . . , . , , , . . . . . . . . . . . . . . . , . . . , . . . . . . , . , , . , , , , , , ~+++~++++++++++++++++~++ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. STATE OF Shirley A. Perry No. 2005 4998 Plaintiff VERSUS Jay R. Perry Defendant DECREE IN DIVORCE AND NOW~.JJ.e~ IT IS ORDERED AND - ~, -:to DECREED THAT Shirley A. , PLAINTIFF, Perry AND Jay R. , DEFENDANT, Perry 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; ()~~ \/ j' p PROTHONOTARY ++++++++++++++++++++++ J. . t-)~<:.L ~ ~ H~"'" ~ 11"'0 ,JfIcL "i- rl'~w I.JO() 1" 'J'f""D ., 0 I '" II .. .:t ~ . . 4. .'.. r. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Shirley A. Perry Plaintiff Vs FileNo. 2005-4998 IN DIVORCE Jay R. Perry 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, or ~ after the entry ofa Final Decree in Divorce dated 12/31/05, hereby elects to resume the prior surname of Bartlett ,and gives this written notice avowing his @ntentionpursuant to thIYprovisions of 54 P.S, Date: 1!3I!o{,p ". . Sign f,. /)7 #1t/uJe~ I.h0v tJ (~ l Signature' fname being resumed COMMONWJ;I\L TH OF PE~SYL VANIA ) COUNTY OF (jJ fA./g.p (!O.JI::QJl On the ~ day of Jt11lUCU 0 ,20013 before me, the Prothonotary or the notary public, personally appeared the above 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. In Witness Whereof, I have hereunto set my seaL l j TARlAl SEAl.. :fkkH,t Notary PubIc . ('..-"_"0""'.......... 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