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Home My WebLink About02-1105In the Court of Common Pleas of Cumberland County, Pennsylvania JULEEN O'BRIEN, Plaintiff, VS. JOHN T. O'BRIEN, Defendant. No. 200 - CIVIL TERM 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 orother 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: Office of the Prothonotary Cumberland County Courthouse 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania JULEEN O'BRIEN, Plaintiff, VS. JOHN T. O'BRIEN, Defendant. ) ) ) No. 2002 - ) ) CIVIL TERM ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in 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 and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9509 In the Court of Common Pleas of Cumberland County, Pennsylvania JULEEN O'BRIEN, ) Plaintiff, ) vs. ) No. 2002- //O~ ) JOHN T. O'BRIEN, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by her attomey Michael S. Travis, respectfully represents: 1. Plaintiff is Juleen O'Brien, who resides at 923 C Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043, since August 2001. 2. Defendant is John T. O'Brien, who resides at 1423 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050, since February 2000. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 26, 2000, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. 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. 9. Neither Plaintiff nor Defendant are in the Military Service in the United States Armed Serviced. Neither Plaintiffnor Defendant are within the provisions of the Soldiers' and Sailors' Relief Act of Congress of 1940 and its amendments. 10. Plaintiffrequests the court to enter a decree of divorce. I verify that the statements made in this Complaint 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. J~'en O Brien,'-Pl~intiff Michael S. Travis Attorney for Plaintiff I.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 In the Court of Common Pleas of Cumberland County, Pennsylvania JULEEN O'BRIEN, VS. JOHN T. O'BRIEN, 5,2002. ) Plaintiff, ) ) No. 2002 - 1105 ) CIVIL TERM Defendant. ~ IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 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 ora 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 falsification to authorities. DATED: ~- · ~ulee 'Brlen, Plai~~ In the Court of Common Pleas of Cumberland County, Pennsylvania JULEEN O'BRIEN, ) Plaintiff, ) vs. ) No. 2002 - 1105 ) JOHN T. O'BRIEN, ) CML TERM Defendant. ) IN DIVORCE tms A DIVORCE DEC~~ ~an~t_, ,-, ....... TRY OF oo~ c ~r t~ DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose fights conceming alimony, division of property, lawyer's fees or expenses ifI 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: ~ --/cO ---~2 In the Court of Common Pleas of Cumberland County, Pennsylvania /ULEEN O'BRIF~N, ) Plaintiff, V$o ) ) No. 2002 - 1105 JOHN T. O'BRIEN, ~ CML TERM Defendant. ) IN DIVORCE ~AFFIDAVIT OF CONSENT 5,2002. A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 2. The marriage of Plaintiffand 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 ora 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 falsification to authorities. DATED: Jpn Thomas 0 Bi'ien, Defendant-- - In the Court of Common Pleas of Cumberland County, Pennsylvania JULEEN O'BRIEN, ) Plaintiff, ) No. 2002 - 1105 JOHN T. O'BRII~N, ~ CML TERM Defendant. ) IN DIVORCE ~~O~T~I~C~E,O..F.._I_N_TENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 3301 e OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, la er's fe wy es or expenses ifI 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: John Thomas O'Bri'en, l~efendant JULEEN O'BR1EM, VS. JOHN T. O'BRIEN, In the Court of Common Pleas of Cumberland County, Pennsylvania ) Plaintiff, ) ) No. 2002 - 1105 ) ) CIVIL TERM Defendant. ) IN DIVORCE _AFFIDAVIT OF SERVICE I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. 7000 1530 0001 0192 6737, return receipt requested, by depositing the same in the United States mail on March 5, 2002, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was received by the Defendant on March 7, 2002. I verifi~ that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. · Complete Items 1, 2, and 3. Also coml:~te · nero 4 if Restricted De~;v~y is desired. Print your name and address off the reverse s° that we can return the card to you. · Attach .this card to the back of the mallpiece, Johh T; O' ' Brien 1423 T&mber Brooke Drive MEchan~csburg, PA 17050 ~0 0001 0192 6737 PS Form 3811, July 1999 Domestic Return Receipt Suite 209 oat~ o* t~,v. 7011 ..... Y '"'~ dlfferect froth item 17 I-lyes 0 ~ [] Return Rec~m for Mecmandi~e [] C.O.D. 4. Pal~'ttiot~;I D~h/eo~ ('~911 ~) ~ 102595-00-M.0952 Michael S. Travis ID No. 77399 4076 Market Sa'eet, Suite 209 Camp b/ill, PA 17011 (7 ! 7) 73 !-9502 Plaintiff, VS. JOHN T. O'BRIEN, Defendant. In the Court of Common Pleas of Cumberland County, JULEEN O'BRIEN, Pennsylvania ) No. 2002 -1105 CIVIL TERM 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: Code. 1. Ground for divorce: irretrievable breakdown under § 3301(c)(I) of the Divorce 2. Date and manner of service of the complaint: Complaint was mailed March 5, 2002, via United States certified mail, restricted delivery, return receipt requested to Defendant, which was received by Defendant on March 7, 2002, Affidavit of service attached hereto. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on June 13, 2002; by Defendant on June 13, 2002. 4. Related claims pending: No economic claims were raised. 5. Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: ~ -,"~-,~Z~ Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the prothonotary: -~/,~.o~. ~ ravis Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF JULV~N 0 ' BP~IRN, Plaintiffr VERSUS Defendant. PENNA. NO. 2002-1105 DECREE IN DIVORCE AND NOW, DECREED THat Jtlleen Of~rien AND John T. Of}3rien ARE DIVORCED FROM THE BONDS OF MATRIMONY. , , it IS ORDERED AND , PLAINTIFF, / , DEFENDANT, THE COURT RETAINS JURISDrCTiON OF THE FOLLOWING CLArMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A F~NAL ORDER HAS NOT YET BEEN ENTERED; None. ATTEST: PROTHONOTARY