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Home My WebLink About02-0997JENNIFER L. THORSON, Plaintiff VS. ROBERT J. THORSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. ~)c~~ r-~ civil Term . : ACTION IN DIVORCE 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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, Pa. 17013 (717) 249-3166 JENNIFER L. THORSON, Plaintiff VS. ROBERT J. THORSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 08- ~ ~ Civil Term : ACTION IN DIVORCE . COMPLAINT IN DIVORCE 1. Plaintiff is Jennifer L. Thorson, a competent adult individual, who has resided at 34 Broad Street, Newville, Cumberland County, Pennsylvania, since November 2000. 2. Defendant is Robert J. Thorson, a competent adult individual, who has resided at 71 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania, since 1996. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on July 6, 1991 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulmem between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the fight to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together, namely, Ashley Nich¢!e Thorson, d.o.b. 5/6/91, and Maci Hannah Thorson, d.o.b. 4/25/99. 1.1~Lo~¢ 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are tree 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. J~hnife~t~. Thorson, Plaintiff Date: Respectfully submitted, ~Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF JENNIFER L. THORSON, Plaintiff VS. ROBERT J. THORSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 997 Civil Term 2002 : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND ANDCOMPLAINT AND NOW, this March 6, 2002, I, Jane Adams, Esquire, hereby certify that on March 4, 2002, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Robert Thorson 71 Peachy Ann Drive Newville, Pa. 17241 DEFENDANT 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF [ ~,[[ I [ I I q 36 SOUTH PITT STREET CARLI~;LE, Pa 1701:9 (717) 245-8508 JENNIFER L. THORSON, Plaintiff ATTOB, N-EY AT LAW IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 997 CiviITerm 2002 ROBERT J. THORSON, Defendant · ACTION IN DIVORCE WWW, ADAMSLAW. t ESQAOAM$~AOL. C FAX: (7 I 7) 245-E AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 1, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.$. 4904, relating to unsworn falsification to authorities. ~o~r~n. Def~end~an~,~- Date: ~'~-V~ C)~ ~- WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) OF THE DIVORCE CODE 1. I consent to 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 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.~.6~04 rela~ng to unsworn falsification to authorities. /,~,~ ~,~,._.._._..__~ Date: C..,-- y ~- O '~,,, ~;~obert J. Tho,~n, Defendant 36 SOUTH PITT STREET CARLISLE, PA 170! 3 (7!7) 245-8508 JENNIFER L. THORSON, Plaintiff VS. ROBERT J. THORSON, Defendant ATTORNEy AT LAW IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 997 Civil Term 2002 ACTION IN DIVORCE FAX: 717) AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 1, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: ~n" I~ orson, Plaintiff- WAIVER OF NOTICE OF INTENTIOn: TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) OF THE DIVORCE CODi- 1. I consent to entry of a final decree of divome 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. {}4904 relating to unswom falsification to authorities. Date: {~nifel: L~!k~'horson: Plai~ltiff 36 SOUTH PITT STREET JENNIFER L. THORSON, Plaintiff ATTOB2~-EY AT LAW IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WWW. A DAM ~,LAW. ESQAOAM$~AOL.( FAX; (71'7) 245- vs. No. 997 Civil Term 2002 ROBERT J. THORSON, Defendant ACTION IN DIVORCE 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 §3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery_, return receipt reouested delivered on: March 4, 2002. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: June 4, 2002. By Defendant: June 4, 2002. 4. Related claims pending: None, 5. Date Defendant's Waiver of Notice in {}3301(c) Divorce was filed with the Prothonotary: June 6, 2002. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 6, 2002. ~6. No. 79465 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff Jennifer L. Thorson~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ST/~TE OF .~. PENNA. VERSUS Robert J, Thor~on~ Defendant NO. 997 S 2002 DECREE IN DIVORCE AND NOW, DECREED THAT AND Jennifer L. Thorson Robert J. Thorson ARE DIVORCED FROM THE BONDS OF MaTriMONY. , IT 15 ORDERED AND __, PLAINTIFF, ~ DEFENDANT, 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; BY~OURT: / PROTHONOTARY