Loading...
HomeMy WebLinkAbout06-0315 Heidi Janna MacNamara, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW : NO. Dr., - 3(S : IN DIVORCE CIVIL TERM Edwin J. MacNamara, III, Defendant 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 will proceed without you and a decree of divorce or annulment may be entered against you for any claim or rel ief 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 of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S, Bedford Street Carlisle, P A 17013 (717) 249-3166 or (800) 990-9108 Heidi Janna MacNamara, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Edwin J. MacNamara, III, Defendant : NO. OG3 /"'~ : IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT I. Plaintiff is Heidi Janna MacNamara, an adult individual currently residing at 226 West Ridge Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Edwin J. MacNamara, III, an adult individual, 53 N. Bedford Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4, Plaintiff and Defendant were married on August 26, 2000, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6, Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling, 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10, Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S, Section 3301 (c) of the Domestic Relations Code. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. Respectfully submitted, GRIFFIE & ASSOCIATES Date: ,!n/oh I ' By: , // . Griffie, Esquire ~ Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904, relating to unsworn falsifications to authorities. ;--1 /'" ~~'/~~~ HEIDI JA MACNAMARA, Plaintiff ~ / .' I /),..-" DATE: f/J ~.!J \-_0 >ll. ~,) '-:.:> ~ ;) " :~-! r-d '.f~ c c-:' ,-- ,~ ',J Heidi Janna MacNamara, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; NO. U, ,- ~/j- : IN DIVORCE CIVIL TERM Edwin J. MacNamara, III, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Heidi Janna MacNamara to proceed informa pauperis. I, Bradley L. Griffie, Esquire, 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. Respectfully submitted, GRIFFIE & ASSOCIATES Date: -lJ 10 I 0 10 ffie, Esquire o X #34349 Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 -. c.) u:. , Heidi Janna MacNamara, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Edwin J. MacNamara, III, Defendant : NO. 0(;, -JJS' : IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE AND NOW, this <6 if,. day of February, 2006, comes Bradley L. Griffie, Esquire, counsel of record for Plaintiff, and states that a true and attested copy of a Complaint In Divorce was sent to Defendant, Edwin J, MacNamara, III, at his address of 53 N. Bedford Street, Carlisle, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on January 13,2006. . Griffie, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PAl 70 13 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this Y d:, day of ,2006 NOTARIAL SEAl ROBIN J. GOSHORN, NOTARY PUBLIC CARLISlE BORO., CUMBERLAND COUNlY MY COMMISSION EXPIRES APRIL 17 2007 ,,' ~ Heidi Janna MacNamara, Plaintiff v, Edwin 1. MacNamara, III, Defendant SENDER: COMPLETE 'HIS SECTION. . 'Complete ~ems 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse t ;~"so,thatwe can return the card to you. . Attach this card to the back of the mailpiece. or on the front if space permits. 1. Article Addressed to: E:tilOl n0. rfldt.!t/tll1llfd../lI{: oj N. I6tlft;rl. straf ta%U6/e. PA /1P/:3 2. Article Number (Transfer from service label) PS Form 3811 , August 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE CIVIL TERM . . *~t'/h~ fe, AlIV by (Prlntsd Name) cf~i .. D, Is delivery fd&resS'. Item 11 lIVES, rerr;'!Il\id~ be, ,w:, r I It lei , ' , ' " ,_\~~r~,. ,/, '~J CJ Agent o Addressee c. Date of Delivery . CJ Ves CJ ~o . 3. ~~::if~::~~;~~~' tf~preSs Mall o Registered (:(RetumRecelpt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 7002 0860 0001 5848 8027 102595..Q2-M-154Q Domestic Return ReceIpt l',.' , r, '..'.:) ,.~) ,-"., -1'1 ~, :=1 ;.": L " c) -.,:; r0 (.) CD HEIDI JANNA MACNAMARA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CNIL ACTION - LAW EDWIN J. MACNAMARA, III, Defendant : NO. 06-315 : IN DIVORCE CNIL TERM CORRECTED AFFIDAVIT OF SERVICE I, Bradley L. Griffie, Esquire, counsel of record for Plaintiff, this 11th day of May, 2006, state that a true and attested copy of a Complaint in Divorce was sent to Defendant, Edwin J. MacNamara, III, at his address of 53 North Bedford Street, Carlisle, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt was previously filed in this matter incorrectly stating that service was made on January 13,2006, when service was actually made on January 31, 2006. Sworn and subscribed to Before me this 11 th day of May, 2006. ,/~~ ,d~~ Notary Pub NOTARiAl SEAL ROBltU. GOSHORN, NOTARY PUBlIC CARliSLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 17 2007 .+........~-,_......,-",."..,. !; .p\ ~ '\'" i T' ;..^ ~ -"" "S, ~i:;C -7Q' ~~',; !:2C ~E :;p. ~; ::z ,.." c::::t c::::t Cl'" :::It ;:poo -< ~ ~ rn:D hi ::0'0 .00 1 C.)CI ~;j -f :-:'- -n CJ-- ".,.C,,) Om -I ~ -J ;:po. :J: - .. -J HEIDI JANNA MACNAMARA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW EDWIN J. MACNAMARA, III, Defendant : NO. 06-315 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on January 17, 2006 and served on January 31, 2006. 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO TIIE PENALTIES OF 18 Pa.C.S. ~4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ~/ 10~ ~~~ t ~ ,'__.:;t d~ (- C:,: .'v'. r<' -- ~ .-\ ~'r: ~"\; (ne, <1;,t:~) ,-..... -. - ~," --:;;i ~: :,.() :.'i'-\\ "t,) ^~;:;;. ::2 t.:? - u:> HEIDI JANNA MACNAMARA, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW EDWIN J. MACNAMARA, III, Defendant : NO. 06-315 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 63301(~) OF THE DIVORCE CODE I. I consent to the entry of a final decree in 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 THE FOREGOING 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: ~~ 4~ //. - . MACNAMARA, III, Defendant --z "-' <: ~:: > ,~:.-J or> c._ ,',,:": r) ::"'q .~ -r' h"fJ IT: c. , ~,' ..,. N IJ ",::; :~~; .-~C) >c:-;rT'i ~~ -< c......1 I.D HEIDI JANNA MACNAMARA, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW EDWIN J. MACNAMARA, III, Defendant : NO. 06-315 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on January 17,2006 and served on January 31, 2006. 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: 7 / /3/0(f) . $~.a~~/~~~ HEIDI JA;!1NA MACNAMARA;Plaintiff ....... n c~ ~:?~ ..;::? 0...... -- s:."' C) -(\ 0' ...;:., HEIDI JANNA MACNAMARA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW EDWIN J. MACNAMARA, III, Defendant : NO. 06-315 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301W OF :.mE DIVORCE CODE I. I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND TIfAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. ~4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 7//3/0& 6~!~~f,^- HEIDI J A MACNAMARA, Plamtiff ~'" ~,"~' i" C) :::-: C.-:> C',:;:' c::-' -':':;;!-.... ("- 4::--- (-::~) en I,.::! Heidi Janna MacNamara, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Edwin J. MacNamara, III, Defendant : NO. O~. a/5 : IN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 9330I(c) 33g1(d~(I) eftke Diyeree Cede. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on January 31, 2006. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by 93301 (c) ofthe Divorce Code: by Plaintiff: 7/13/06 by Defendant: 7/13/06 (b) (I) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 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 of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: July 14, 2006 Date defendant's Waiver of Notice In 93301 (c) Divorce was filed with the Prothonotary: July 14, 2006 ;~\.) (>,': - c::> IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Heidi Janna MacNamara Plaintiff No. 06-315 . VERSUS Edwin J. MacNamara Defendant . . DECREE IN DIVORCE . . . . . . AND NOW, Jut, 2h :;Inn/; , IT IS ORDERED AND DECREED THAT Heidi Janna MacNamara , PLAI NTI FF, . . AND Edwin J. MacNamara , 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 . ATTEST: J. . . . ~- PROTHONOTARY ,#.z /f . ~,~ o/lL. 911- ,$-e - L '-"'P,F' ~ ~ 4#n -I"P ",,-~-L . - ,;;.' j . .. \ - . .., ... Heidi Janna MacNamara, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Edwin J. MacNamara, III, Defendant : NO. Oei, - "3/~ : IN DIVORCE CIVIL TERM NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter hereby elects to retake and hereafter use her previous name of HEIDI JANNA LAWTON. 1/tt(ddAAt.d-~{'~~ HEIDI J A MACNAMARA - :f;~~/J141A r7 au~. HEIDIJ A LAWTON COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cu..ovWa-vL : SS On this .1!i day of O~ ' 2006, before_me, the undersigned officer, personally appeared Heidi Janna MacNamara, now known as Heidi Janna Lawton, known to me (or satisfactory proven) to be the person whose name is subscribed to the within document and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. a,'41 Ii. Lt.J 8f~ - Notary PubliV ~ r~ 8 i ~ ;s:: > ;~ "U(J::1 c:: \,"':; " ;ff rnrr-, C') ~-r; ~ .0;......_. ZC ....... (f)~. ,f:'", ~ -<:< ~ r;:c -u ()~ ~.-.., :::r; Z Z''': (5 " .~o N )>c:: ;g ~ .. " N '< "0J (,.) ~ J;.~ ifj;1\~'iXrf.:.'~" fI'.!<!.'....~ , \ ", ~ '\" qo "'" ~ . ! ~"^"'~!\:f)~,'.;\,"I';,'l;; l.e! '~\'l i , YT'~'<:J ~~;t1):\I,:11";.", '''::'r'''';f::-'"~'\~' :;_",,1.'_ .'