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HomeMy WebLinkAbout06-0806 II KRISTIN D. SCOTT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JOHN F. SCOTT, Defendant NO. OL.- rc~ 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 foregoing 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 in 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 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: Office of the Prothonotary Cumberland County Court House 1 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 1 II KRISTIN D. SCOTT. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 0(..- :rOt- CIVIL TERM JOHN F. SCOTT, Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: 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. .A.!! 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. 2 11 KRISTIN D. SCOTT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO.Of.,.}'O<".. CIVIL TERM JOHN F. SCOTT, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, KRISTIN D. SCOTT, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is KRISTIN D. SCOTT, an adult individual who currently resides at 241 North 19th Street, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is JOHN F. SCOTT, an adult individual who currently resides at 7261 Capital Drive, Harrisburg, Dauphin County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 6 June 2003 in Las Vegas, Nevada. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The Plaintiff requests this Court to enter a Decree of Divorce. 3 . ' 11 ,i WHEREFORE. Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. ~-- . ' , ~('\--'\0 sa' el L. Ande ~ Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DA TE:4dC,lo 4 ~--"--". ~ --..J ..c::. ~ ~ c ~\/ , ~ ~,J ~ --.J ~ /t'~ w " - ~ \'., '-'" '" n ,: ,-:-.- \~ --- !"_,1 ~, t....} '::c> C' -'l~; .-, :-:.- Iii ;:] :., .N , \.D '.':? C" c vs, ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTIN D, SCOTT, PLAINTIFF CIVIL ACTION - LAW NO, 2006-806 CIVIL TERM JOHN F, SCOTT, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE 1, JOHN F, SCOTT, hereby accept service of the original Complaint in Divorce and acknowledge receipt of a copy of the Complaint. Date: 2.-17-00 JO~;~ :.1 ~. t r-,,; c ", 'I KRISTIN D. SCOTT, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) ) NO. 2006-806 CIVIL TERM JOHN F. SCOTT, ) Defendant ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 9 February 2006 and served on the Defendant on 17 February 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ec) OF THE DIVORCE CODE 1. 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 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. Section 4904 relating to unsworn falsification to authorities. F5/3/0U I . Dated: .~ i . ~J]l .. '/ .-.' ~'ND.SC- .. o ~ rl1 ij~ 2:' C.- -7;- ~"- " ~",(-- !::; "';' :'~; :;:.'" I~" :~ "" = = cro :x ~ -<: f (,11 o -n ..... ffi::n "OF.; S5,'Z ~;5 :~) .;:.,. (..J ~JZT-! '::0 ,< ~ 'Y C) c..:: II vs. ) ) ) ) ) ) ) ) ) IN DIVORCE AFFIDAVIT OF CONSENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTIN D. SCOTT, Plaintiff CIVIL ACTION - LAW NO. 2006-806 CIVIL TERM JOHN F. SCOTT, Defendant 1. A Complaint in Divorce under Section 3301 (e) of the Divorce Code was filed on 9 February 2006 and served on the Defendant on 17 February 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 Ie) OF THE DIVORCE CODE 1. 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 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. Section 4904 relating to unsworn falsification to authorities. ~_n-o& Dated: ~~~ J N F. SCOTT 2 ~:, ~r; Z'- -7 Tfy. :./ .' r;: "- %:~:~., '7 C., ~~;/ ';2 ~ "if. ?f. ~. I cfI --11 :;r.; r::'> .' C-' (.Yo o -fl ~, -;t;-<' P"E -c-r(. ~;-"Q r';1~ ~~ J-iS :4. 11 vs. ) ) ) ) ) ) ) ) ) IN DIVORCE PRAECIPE TO TRANSMIT RECORD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTIN D. SCOTT, Plaintiff CIVIL ACTION. LAW NO. 2006.806 CIVIL TERM JOHN F. SCOTT, Defendant TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceotance of Service filed bv Plaintiff's counsel indicating service on or about 17 Februarv 2006. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 3 Mav 2006 By Defendant: 22 Aoril 2006 (b) (1) Date of execution of the Affidavit required by Section 3301 (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 Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 3 Mav 2006 and filed contemooraneouslv herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 22 Aoril 2006 and filed contemooraneouslv herewith. Date: 3 May 2006 By ~~112~ Attorney for Plaintiff o ~ "'Oe:~ n\r' Z;;,' ::r~., ~~~ '- .'-~~.. ~:~ ','i>r"' :~,~ :< "'" = = .".. ::;r; J> -< 9n .-( :J:-n nlr, -ern -!JO C)h '~:f.; :~i:'5 ~:~ .rn o '--1 '~ :J" -< I (}1 -0 3 i)? CJ C'> . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY 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 . PROTHONOTARY . . . . By THE COURT: / . /7P- . . . . J. . . . . /.dJ ~ ~ 1(j' -9 . :tr 'r ~ 11.I,; . Y"Z7 '}tJ. -9 0/"!1 fr' f- "f/ .; r' , - .. ... '. .: ;. ... .~. "\. ~.~".~.. I , I vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTIN D. SCOIT Plaintiff CIVIL ACTION - LAW NO. 2006-806 CIVIL TERM JOHNF. SCOIT Defendant IN DIVORCE NOTICE TO RESUME PRIOR SURNAME NOTICE IS HEREBY GIVEN that KRISTIN D. SCOIT, Plaintiff in the above matter, having been granted a Final Decree in Divorce on the 19TH day of May, 2006, hereby elects to resume the prior surname of KRISTIN MARIE DAVIN, and gives this written notice pursuant to the provisions of 54 P .S. ~704. DATE:*lllP ,~ i e of Name R KRISTIN MARIE DAVIN COMMONWEALTII OF PENNSYLVANIA ) ( SS.: COUNTY OF CUMBERLAND ) On the 11t:hday of ,2006, before me, the undersigned officer, personally appeared KRISTIN D. SCOTI, known to me or satisfactorily proven) to be the person whose name is signed to the within Notice to Reswne Prior Surname and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~lm.~) Notary ic .-' .<~ ~ ;-...-, , ~ ~ c^) ..-,.. ~ 't ~ ~ " , '> ~ ~ f'- ~ ""-l ~~ rl ~vw.1O'~'~ ~~:::,~yY'