HomeMy WebLinkAbout06-0916
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
CYNTHIA A. PRICE, )
Plaintiff, ) No. a-9lla C I oL't 'Cfl.YJ,-l
vs. )
)
JOHN L. PRICE IV, ) CIVIL TERM
Defendant. ) 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.
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, P A 17013
(717) 249-3166
In the Court of Common Pleas of Cumberland County,
Pennsylvania
CYNTHIA A. PRICE, ) CiuiL ~ E12-
Plaintiff, ) No. Ok,- q 1(..
vs. )
)
JOHN L. PRICE IV, ) CIVIL TERM
Defendant. ) 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.
I.
Michael S. Travis
ID No. 77399
3904 Trindle Road
Camp Hill, PA 17011
(717)731-9509
In the Court of Common Pleas of Cumberland County,
Pennsylvania
CYNTHIA A. PRICE, ) (!tOl{ 18L
Plaintiff, ) No. Dle. - q I to
vs. )
)
JOHN L. PRICE IV, ) CIVIL TERM
Defendant. ) IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
Plaintiff, by her attorney Michael S. Travis, respectfully represents:
1. Plaintiff is Cynthia A. Price, who resides at 316 Geary Avenue, First Floor, New
Cumberland, Cumberland County, Pennsylvania, 17070, since October, 2004.
2. Defendant is John L. Price IV, who resides at 412 Rear Geary Avenue, New
Cumberland, Cumberland County, Pennsylvania, 17070, since November 1, 2003.
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 November 13, 1993, at New
Cumberland, York 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 party is in the Military Service in the United States.
10. Plaintiff requests the court to enter a decree of divorce.
I verify that the statements made in this Complaint are true and correct. 1 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 - \ 1.1- oC~
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' ~{6h . TraVIS
Attorney for Plaintiff
1.0. # 77399
3904 Trindle Road
Camp Hill, PA 17011
(717) 731-9502
Fax 731-9511
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Michael S. Travis
ID No. 77399
3904 Trindle Road
Camp Hill, PA 17011
(717)731-9502
CYNTHIA A. PRICE,
Plaintiff,
In the Court of Common Pleas of Cum her land County,
Pennsylvania
)
)
)
)
)
)
No. 2006-916
vs.
JOHN L. PRICE IV,
Defendant.
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:
I. Ground for divorce: irretrievable breakdown under S 3301(c)(I) of the Divorce
Code.
2. Date and manner of service of the complaint: Complaint was mailed February 16,
2006, via United States Certified Mail, restricted delivery, return receipt requested to Defendant,
which was received by Defendant on February 28, 2006, Affidavit of service attached hereto.
3. Date of execution of the affidavit of consent required bI S 3301(c) of the Divorce
Code: by Plaintiff on June 2 , 2006; by Defendant on June , 2006.
4.
Related claims pending: No claims were raised.
5.
prothonotary:
Date Pl~tiffs Waiver of Notice in S 3301(c) Divorce was filed with the
ir, 1 ,2005.
prothonotary:
Date~endant's Waiver of Notice in S 3301. (c).I>i.":l?!:~ was filed with the
&, '1 ,2005. .//;;~//
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;//Michae .(' ravis
Attorney for Plaintiff
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In the Court of Common Pleas of Cumberland County,
CYNTHIA A. PRICE,
Plaintiff,
)
)
)
)
)
)
No. 2006-916
vs.
JOHN L. PRICE IV,
Defendant.
CIVIL TERM
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 on February 28, 2006, pursuant to Rule 1920.4 of the Amendments to the
Pennsylvania Rules of Civil Procedure relating to the Divorce Code.
I veritY 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.
relating to unsworn
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3904 Trindle Road
Camp Hill, PA 17011
(717) 731-9502
falsification to authorities.
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. Complete items 1, 2, and 3. Also complete
item 4 ~ Restricted Delivery is desired.
. Print your name and address on the reverse
so that we 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:
:::-01"\ L, PCI'c...<.. IV
LJI2 t<Po'-- CPL<N'f l\-vL.
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D. Is delivery address different from Item 1? 0 Yes
If YES, enter delivery address below: 0 No
3. Service Type
ISl Certified Mail D Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured MaU 0 C.O.D.
4. Restricted Delivery? (Extra Fee) ~ Yes
7005 1820 0007 7502 0552
2. Article Number
(Transfer from service label)
PS Form 3811, February 2004
Domestic Return Receipt
10259S-Q2-M-1540
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CYNTHIA A. PRICE,
Plaintiff,
)
)
)
)
)
)
No. 2006-916
CIVIL TERM
IN DIVORCE
VS.
JOHN L. PRICE IV,
Defendant.
AFFIDAVIT OF CONSENT
1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on
February 15, 2006.
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 of a final decree of divorce after service of notice of
intention to request entry of the decree.
I veritY 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. S 4904 relating to unsworn
falsification to authorities.
DATED:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CYNTHIA A. PRICE,
Plaintiff,
)
)
)
)
)
)
No. 2006-916
VS.
JOHN L. PRICE IV,
Defendant.
CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
L A complaint in divorce under S 3301(c) of the Divorce Code was filed on
February 15, 2006.
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 of a final decree of divorce after service of notice of
intention to request entry of the decree.
I veritY 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. S 4904 relating to unsworn
falsification to authorities.
DATED: /(T"':-d-.-Op
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CYNTHIA A. PRICE,
Plaintiff,
)
)
)
)
)
)
No. 2006-916
CIVIL TERM
IN DIVORCE
VS.
JOHN L. PRICE IV,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER & 3301(c) OF THE DIVORCE CODE
1. I consent to the 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 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 veritY 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 unsworn
falsification to authorities.
Date: t; d -tp
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CYNTHIA A. PRICE,
Plaintiff,
)
)
)
)
)
)
No. 2006-916
CIVIL TERM
IN DIVORCE
vs.
JOHN L. PRICE IV,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER S 3301(c) OF THE DIVORCE CODE
1. I consent to the 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 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 ofthe decree will be sent to me immediately after it is filed with the
prothonotary .
1 veritY 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. S 4904 relating to unsworn
falsification to authorities.
Date: 05+--do
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
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STATE OF
PENNA.
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CYNTHIA A. PRICE,
Plaintiff,
No. 2006-916
VERSUS
JOHN L. PRICE IV,
Defendant.
DECREE IN
DIVORCE
AND NOW,
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DECREED THAT
Cynthia A. Price
, PLAI NTI FF,
AN D John L. Price IV
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOYVING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None. No econanic claims were raised.
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