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Home My WebLink About05-5418 CHERYL S. GETTY, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE KEITH M. GETTY, Defendant :NO. :;JO<:n- 51f/1 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 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 ofthe Prothonotary at: Office of the Prothonotary Cumberland County Court House I Courthouse Square 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 CHERYL S. GETTY, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Defendant :CIVIL ACTION - LAW :IN DIVORCE . />.. --/,.._- :NO.05- yL;/r ~ ~ v. KEITH M. GETTY, COMPLAINT AND NOW comes the Plaintiff, Cheryl S. Getty, who, by and through her attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint, in which she avers that: I. Plaintiff, Cheryl S. Getty, is an adult individual residing at 2608 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Keith M. Getty, is an adult individual residing at New Insights 716 State Street, Lemonye, Cumberland County, Pennsylvania 17043. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on August 12, 1989. 5. There have been no prior actions in divorce or for annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs I through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiff's marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. 993301(c) or (d), Plaintiff, Cheryl S. Getty, respectfully requests the Court to enter a Decree of Divorce. DATED: tJ-j!f-cf')' Respectfully submitted, of Counsel /~ Aomas A. Beckley ------ . --~ BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 (717) 233-7691 2 CJ ,.......) 'tf'< c:', ("'- c::.~) ~ ~-.Fl 0 ----- ,'i 0 ~ ,~ . (~) ~ -, ~ C.::J ~. ~ ::-" -s, - --". <><:> --:E -v --.b ~ C.J - .- (,}": ~ n-- ~. @ C"J -n =-~ -;'1 ,',.! : :n .~ ~ .- Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CHERYL S. GETTY, v. : CIVIL ACTION - LAW : IN DIVORCE KEITH M. GETTY, Defendant : NO. 2005-05418 PRAECIPE To the Prothonotary: Please attach the enclosed verification, which was inadvertently omitted, to the Complaint filed on October 18, 2005, in the above-captioned matter. DATED: October 26, 2005 .1 Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 (717) 233-7691 / ////4 /~~l;--- -- If. . VERIFICATION I, Cheryl S. Getty, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: I g iG -/.. t4?O .j ~'-tI0~ '^"> " -II '-1 i-'-,') C ( CHERYL S. GETTY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. : CIVIL ACTION - LAW : IN DIVORCE KEITH M. GETTY, : NO. 05-5418 Defendant ACCEPTANCE OF SERVICE I, Keith M. Getty, hereby accept service of the Divorce Complaint filed in the above-captioned action. 1?0~ 1/A -&-1 . fA KeIth M. Getty DATED: L" ,-.':' '", CHERYL S. GETTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU1\TY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE KEITH M. GETTY, Defendant NO. 05-5418 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 18,2005. 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 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. 9 4904, relating to unsworn falsification to authorities. Dated: J) 9 Joy CHERYL S. GETTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE KEITH M. GETTY, Defendant NO. 05-5418 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on October 18,2005. 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 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. 9 4904, relating to unsworn falsification to authorities. Dated: ~r(6f1 ~;;.%? .$- Keith M. Getty CHERYL S. GETTY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE KEITH M. GETTY, Defendant NO. 05.5418 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. J/910~ Dated: " -_.~~- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL S. GETTY, v. CIVIL ACTION - LAW IN DIVORCE KEITH M. GETTY, Defendant NO. 05-5418 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorcto 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. 94904 relating to unsworn falsification to authorities. Dated: i~r /!;/ ~ Kith M. Gett -- -::::::> ------ CHERYL S. GETTY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE KEITH M. GETTY, Defendant : NO. 05-05418 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for the entry of a Decree of Divorce. 1. Ground for divorce: irretrievable breakdown of the marriage under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served by Keith M. Getty personally accepting service on October 23,2005. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on February 9, 2006; by defendant on February 9, 2006. 4. Related claims pending: No economic claims raised. 5. (a) March 9, 2006. Date plaintiff's Waiver of Notice February 9, 2006, and it filed on (b) Date defendant's Waiver of Notice February 9, 2006, and it was filed on March 9, 2006. DATED: S-~ Respectfully submitted, of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 (717)233-7691 (") ~ "'^,,- v[~, rTlfT:- "7- Z (fJ ~;~:-. :~.,~ -<.. '"'" c;::) = "" ::r.; .".. -< '" '" -v :::t: ~ ~:D l:n --C~-i -T)"\...r' j:~9 ;~~~~ 8m -'-\ ~ r:-? <..n '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF CHERYL s. GEITY, Plaintiff VERSUS KEITH M. GE'ITY, Defendant if. if. if. PENNA. No. 5""'1 I 'i' o 54:l:8" 2005 DECREE IN DIVORCE '" if. AND NOW,~\S 1.~ ~ dt.." . , IT IS ORDERED AND 0\ \'\ o.,\- ' 2006 '" DECREED THAT CHERYL s. GETl'Y , PLAINTIFF, if. if. AND KEITH M. GE'ITY '" , 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; NCl'm. BYTH~O~ lki \ ATTEST, ~ .~\\ J. ~~ I PROTHONOTARY if. '" if. '" if. '" '" if. '" if. '" '" '" if. '" if. if. '" if. if. if. if. if. '" if. '" if. if. if. '" if. '" if. if. '" if. '" if. if. '" if. if. if. if. if. if. if. if. if. if. if. if. if. .6~ ~=~ ~ fp :2 "r..~ ~ -.p7;J .~ - ' ~. . " . "..~ ~ 4' ~ ". '" .., , ..' .,.. 10. /j/ -J' ~(/. 1/ -.9