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HomeMy WebLinkAbout06-0858 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Dwight B. Franks, v. Defendant CIVIL ACTION - LAW NO. 06 - 't)~ CIVIL TERM IN DIVORCE Loretta L. Franks, You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served. by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA Dwight B. Franks, v. Defendant CIVIL ACTION . LAW NO. 06 - i';'t CIVIL TERM IN DIVORCE Loretta L. Franks, COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Dwight 8. Franks, an adult individual, who resides at 31 E. Main Street, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Loretta L. Franks, an adult individual, whose address is 1627 South Glendale, Apt. 210, Wichita, Kansas 67218. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 14,2002 in Plant City, Florida. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court rcquire the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiffrespectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: t-l r;~ ~ Respectfully submitted, ROMINGER, BA VLEY & WHARE MLf-h&S 155 S. Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court LD. # 87663 Attorney for Plaintiff VERIFICA nON 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. 94904, relating to unsworn falsification to authorities. Date: J- 10 - 6 b /' "' . ., J/ .-l~-( ~' 71;t_~ ' ~ Dwight B,-t anks,'Plaintiff @) ~? ....' c::;> () r::fr '.: .~;,o .'"1'1 c:', "F -n -' ~. "-- -<" ~ pi ("':-iF) -c:.:; :'$!--- ,-"1 ':) W - "c\ -0. ')W .." --C " -" '>., --0 , ", '>-> -C ~ .:\ --0 :,.~~ (~) :j.J l.-l\ -< Dwight B. Franks, v. Loretta L. Franks, 2006. laintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA efendant CIVIL ACTION - LAW NO. 06 -858 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complain in Divorce under Section 3301(c) of the Divorce Code was filed on February 13, of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing e Complaint. 3. I consent to he entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the tatements made in this Affidavit are true and correct. I understand that false statements herein are m de subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: ~""T l.-OO 1I (") ~ -~ ~..,.~-- r~~-i ~-~. - .-;.>- ... I'-..) = = cr'" '- c.:: z o -11 ~ rn :!J r- -Om ;xJY ,--) ('. ;~ =+~ ~.~.; (') 01'1'1 .-1 ?:O -< I 0'\ -u _T# ~ w .. w o Dwight B. Franks, PI intiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. efendant CIVIL ACTION - LAW NO. 06 -858 CIVIL TERM IN DIVORCE Loretta L. Franks, WAIVER OF NOTICE OF INTENTION o REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to he entry of a final decree of divorce without notice. 2. I understan that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not cla m 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 wi I be sent to me immediately after it is filed with the Prothonotary. Date: 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 unsworn o :2 OOv o S ~-"", r--.> <= = C1"' C- c: -..".. ....-..- ~ -l :I:rn :D r- --0 iJJ - r) c.; (~~ (~) ~.i: :r~ c~?o ~m ':~l ~ ~ I 0' ""'0 --,,:.. s.:: w o Dwight B. Franks, Pia 'ntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. efendant CIVIL ACTION - LAW NO. 06 -858 CIVIL TERM IN DIVORCE Loretta L. Franks, AFFIDAVIT OF CONSENT 1. A Complain in Divorce under Section 3301(c) of the Divorce Code was filed on February 13, 2006. 2. The marriag of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing e Complaint. 3. I consent to e entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the tatements made in this Affidavit are true and correct. I understand that false statements herein are m de subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: .5 - (") ~~ r--.:> = = <::7' C- c: :J: o -n ~~ -0 !I1 :;JY ':.J -, :.:1 ~'T', (~E5 :.:s rn ~ ~ I C1'l :32 -- <-:? w o Dwight B. Franks, PI 'ntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 1. I consent to e entry of a final decree of divorce without notice. efendant CIVIL ACTION - LAW NO. 06 -858 CIVIL TERM IN DIVORCE Loretta L. Franks, WAIVER OF NOTICE OF INTENTION o REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not cIa m 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 wi I be sent to me immediately after it is filed with the Prothonotary. I verify that th statements made in this Affidavit are true and correct. I understand that false subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn statements herein are falsification to authoriti s. Date: to J);tI /3, t~ Dwigh~ranks, Plaintiff o S ,- I"...;) = = 0'" <- c:: -,.1'"" "'..... s;?, -l :r:,-r:! n~ 15cr '~~C) ;:~~ 6rn --j -,."" ~ I Cj\ -0 ...... ..,i;J.... Ci? w c::> Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Dwight B. Franks, v. Defendant CIVIL ACTION - LAW NO. 06 - 858 CIVIL TERM IN DIVORCE Loretta L. Franks, ACCEPTA1'lCE.Qf.~XBy-!q: I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Loretta L Franks, in the above-captioned action and I certify that I am authorized to do so. Od/;)'7/00 Date 1 (2 r-' c-:" -,-, () --\"1 .--' :,1 --- ~' ( , ,-- \ CO - -'~ ~" , . tn C;':: ~:.: :~ Dwight B. Franks, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Defendant CIVIL ACTION - LAW NO. 06 -858 CIVIL TERM IN DIVORCE Loretta L. Franks, 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. Grounds for divorce: irretrievable breakdown under S 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: February 27, 2006, Defendant signed Acceptance of Service. 3. Date of execution ofthe affidavit of consent required by S 3301(c) of The Divorce Code: by the Plaintiff, May 28, 2006; by the Defendant, May 30, 2006. 4. Related claims pending: 5. Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: June 6, 2006. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: June 6, 2006. Date: June 8, 2006 eo, Esquire 155 South anover Street Carlisle, PAl 7013 (717) 241-6070 Supreme Court ID No. 200198 (") ( CJ -n ---j .. i-\l I CO '-.' ::r (,) -~:- J. ;I; ;+; ;+; ;+; ;+; PROTHONOTARY ;I; ;+; ;I; ;+; ~ ~~;+; ~~~ ;+;~~~ ~ ? Ef. Ef. Ef. Ef. Ef.Ef. Ef. ~Ef.Ef. Ef. iIi Ef. iliEf.iIi Ef. iIi ;+;iIi iIi iIi iIi iIi IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. STATE OF Dwight R. Fr~nk~ Pl~;nt;f'f iIi VERSUS iIi Loretta L. Franks No. 2006 858 nAfAnnant DECREE IN DIVORCE AND NOW, ~\?~/1 ~, IT IS ORDERED AND DECREED THAT Dwight B. Franks , PLAINTIFF, AND Loretta L. Franks , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRI MONY. 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. iIiili iIi iIi ~ ~ ~ iIi Ef. iIi ~ ~ ;+; ;+; iIi ;+; ;+; ;+; ~? ~ ~ ')Cl. I/..~ ~~ /L~~'~ 1~.1/-t? , . , ';' ;:-.... - 1 " ~- '.,,-C; .'