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Home My WebLink About05-5959 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE~SYLV ANIA CIVIL ACTION - LAW ---S1,,'D AJax,uJV Plaintiff : No.j 6S - SCfS? Civil Term CeCILI A v. y11, 4J" {?5o''\ , Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE 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, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OF 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 A venue Carlisle, P A 17013 (717) 249,3166 .----J ~. ~..:,u{C,X\,.:,i V .- . ",~N Plaintiff IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE C~CILI(.\. m. A",Jet2.S,I' Defendant No. NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a 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 ,md your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ~ . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL V A,'1IA v. No. 05-9tS'TCIv1L TERM Defendant IN DIVORCE COMPLAINT UNDER Q330 1 (c) or (d) OF THE DIVORCE CODE I. Plaintiff is -.:;:\,,, b, A"JeIZSo,J I V who currently resides at 1. tJed fl.J:wr:lob 'bt<.IVC G..ulsI.-r. PfI 170/ .~ f I Cumberland County, Pennsylvania. 2. Defendant is (;,,', 1"fA (1'\. AV\def2.5oV\ ,who currently resides at 3il"i tbJ.a l/cJle.v Q,)(J I ;r1L"pI~(L5Mt~H1,Jls P.Jlf7t53 I I 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on () '-I r;L... ,- ,Ly'2 'I , at 5. The marriage is irretrievably broken, and the parties separated on at{ rrI a~J 1- ~ 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his /her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address , given in Paragraph 2 above. . 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the/pa-rt'les participate in counseling. . I WHEREFORE, Plaintiff requests the Court tlJ:iJ Decree of Divorce. ., , .' 05JlJvt...IJcA/1 Date i i i . I Plainti~o Se i /; .--r; Lb. A.--dd"O,J I V , veriflthat the statements made in this Complaint I, are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. 94904. ()) Date: JCV(\I\~({:. \1 ro Se ed by: PENN LEGAL SERVICES o SE DIVORCE CLINIC (717) 243-9400 ~( ,~ u r-,~? <.~.; -:1 <..:') <':_1' :,J -n :.::J --' ~ f.q 1'<. .; . 't. At0bEf-SON I iJ ,- _>ot-l.-J Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA CEC{L.1A V riI, A,vbl5.eSOAJ ,Jt/k Defendant : NO. 05 -.s9~~ CIVIL TERM : DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, ~f.\ tJ ~ ,~t0!)e; ~s~..; I J, Plaintiff, to proceed in forma paupens. I, Valerie J. Faden, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. ;:: !/!U&:Jt€ ~ Valerie J. F<jlie Attorney for- aintiff 2807 Market Street Camp Hill, PA 17011 (717) 920-9461 r--',' ~3 '-.-'"' C1 ~,' :.:;J f',; <..,'-~-;. "j" -' ~- -' c., c:' - JOHN D. ANDERSON, IV, IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA PLAINTIFF, NO. 05-5959 vs. CECILIA M. ANDERSON, DEFENDANT IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 30th day of December, 2005, I, Valerie]" Faden, Esquire, attorney for plaintiff, hereby certify that a true and correct copy of the Notice to Defend and Claim Rights and Complaint in Divorce Under Section 3301(c) or (d) of the Divorce Code were served upon the defendant, Cecilia M. Anderson, by certified mail, return receipt requested, restricted delivery, at the following address: 3114 Heister Valley Road Mt. Pleasant Mills, PAl 7853 The signed return receipt is dated December 9, 2005 and is attached hereto. A TTORNE 0 P INTIFF VALERIE J. FADEN, ESQUIRE 2807 MARKET STREET CAMP HILL, PAl 70 I I (717) 920-9460 . . Complete ~ems 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. . Print your name and eddress on the nwerse so that we can return the card to you. . Attach this card to the back of the mall piece, or on the front ~ space parmits. 1. Article Addressed to: Ce~\ I,~. wl. A"de~scl'\ J 3; I 'f ~16k v(>..llq R" ty1{. p\~-f t11,/IJ1 PA ''1~.3 2. Article Number rrmnsfer from servfce IsbeQ PS Form 3811. August 2001 A Signature \ X j'.~, , "-~ ".. ",,"'~~A B, ReCeived Py (Printed Name) .V<-p.... D. Is delivery address different from Item 1? If YES, enter delivery address below: DAgen! o Addressee C. Date of Delivery _05 DYes DNa 3. SelVlce"Jype "illc.nmed Moll 0 Exp.... Moll 6 Registered 0 Return Receipt for Merchandise O. Insured Moll 0 C.O.D. 4. Restricted Delivery? /Extnl Fee) i!l'Ye. 7005 0390 0003 2641 4462 102595-02-M-1540 Domestic Return Receipt (j r_) "-;e' n ~;il I:~" c,_ :::-J :'~'<l" :";'1 :::c JOHN D. ANDERSON, IV, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA PLAINTIFF, NO. 05-5959 vs. CECILIA M. ANDERSON, DEFENDANT 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 loose rights concerning alimony, division of property, lawyers 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: t;J5/1~f - L (") c: -.,..:<;:: I..,J f"7'~l ~Etl ~ -<" ~f'";:;l ~ '~"_., !":-.. ~S -c:: ~ ......, <<::::I ~ o f'Tl ("") , ~ ~ m:D r- -o~j .:0 o -10 :t ::p O...J @5M ~ -0 :J: .r:- o Q') JOHN D. ANDERSON, IV, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, NO. 05-5959 vs. CECILIA M. ANDERSON, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECflON 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 loose rights concerning alimony, division of property, lawyers 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: (0\..0 I\JC)J~ y 7~ ~~ CE ILIA M. ANDERSON, Defendant <2 ?,;. -00::; rnr, \ t:s. r;(::~~ ~c -<(.../ 'Y'C: ~~ -<. ~ ~ ~ ('"'), , - ~ ~:rJ ~~ ...--\...,-; :C~ ~~ 5'" :::::-+. ~ ..." ::s:. s::- .- o 0'" 'J JOHN D. ANDERSON, IV, PLAINTIFF, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA NO. 05~5959 vs. CECILIA M. ANDERSON, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 17, 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. ~4904 relating to unsworn DATE: /)t, J1IJJ.rJ f DERSON, IV, Plaintiff falsification to authorities. f'.) C;:) = c:r-. o Pl C'"? I -.J o --n ::;:! ffi::D r- """'fTl jJy <::-)('-'j ~+i ~;.2 ('') iSrn ::;;! :.0 --< v :x N .. en N JOHN D. ANDERSON, IV, PLAINTIFF, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA NO. 05-5959 vs. CECILIA M. ANDERSON, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 17, 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. ~4904 relating to unsworn falsification to authorities. DATE: 0\0 Nov~xvf ~ CECILIA M. ANDERSON, Defendant (") c: ~~ ;=F! i,$~~ ~;: <,", "f').'" .,""" ',. ~~.~:~:.-: Z -i -<: r-..:l <:::::10 = c::r-. o ,.." CJ I -.J ~ :i! nl:!J r- "",m :170 C).t ::;J9 --;-1 .?c-, onl ::;;! ~:o -< -0 :.l:: N en N JOHN D. ANDERSON, IV, PENNSYLVANIA PLAINTIFF, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. 05-5959 vs. CECILIA M. ANDERSON, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. "" 2. Date and manner of service of Complaint: Certified mail, restricted delivery, article number 70050390000326414462, return receipt card executed by Defendant on December 9, 2005 and filed on January 4, 2006. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: March 24, 2006; by Defendant: November 24, 2006. 4. Related claims pending: there are no claims pending. 5. Date Plaintiff's and Defendant's Waivers of Notice were filed with the Prothonotary: December I ' 2006. DATE: / J. I "/lJ(P I I /. ~ f~ ~;' P'. ,'~ Valerie J.~ . -qwre I.D. # 87442 676 Villa Vista Avenue Lewisburg, P A 17837 (570) 523-2026 Attorney for Plaintiff ~.2 ,...." = = 0..... ~ ~,:n lIr -n fT. "1,)0 f"'o"l, '..'.c ~--r.j -'--' ~1 ~2 ('=S 7~ [11 ':::.\ 20 :< o rn c-? I -.j -v ::E ~ (..n (..) '" '" '" '" "''''''''''''' '" '" "''''''' '" '" '" '" '" "'''' '" "''''''' IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. John D. Anderson, IV Plaintiff No. 05-5959 Civil VERSUS Cecilia M. Anderson Defendant DECREE IN DIVORCE AND NOW, Ot..<.. e.V'4\ ~ tf' \ 1, 1()O~ , IT IS ORDERED AND '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" '" DECREED THAT John D. Anderson, IV , PLAI NTI FF, Cecilia M. Anderson AND , DEFEN DANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; '" '" '" There are no claims pending. BYTHE COUR~ ~ ~ ' Am?1~ PROTHONOTARY "'''' '" '" "'''''''''' '" "''''''' "'''' "''''''' '" "''''''' "'it: "''''''' '" "'''' '" '" "'''' "'''' "''''''' '" "''''if", '" '" '" '" if '" '" if '" '" '" '" if '" '" '" '" '" '" '" '" '" '" '" '" if '" '" '" '" '" if if if if '" '" '" '" '" '" '" '" '" if '" J. '" '" if '" if '" '" '" '" '" '" ",,,,Of; ~ '7 ~ ~~ 911- bf- c/ ~ fp.%~ ~ -f"P 1(j- ?;/-eI .. '..: . " ," ..' . ~