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Home My WebLink About06-1074 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES M. LEE, Plaintiff CIVIL ACTION -LAW vs. NO. 06-1074 CIVIL TERM AMBER L. LEE, 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 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, First Floor, 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: Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013-3302 Telephone number: (717) 249-3166 Toll Free (in PA) 1-800-990-9108 , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES M. LEE, Plaintiff CIVIL ACTION -LAW VS. NO. 06 -It) 71CIVIL TERM AMBER L. LEE, Defendant . . IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE PENNSYL VANIA DIVORCE CODE 1. Plaintiff is Charles M. Lee, who currently resides at 3294C Wakefield Road, Harrisburg, Dauphin County, Pennsylvania 17109 since May 2001. 2. Defendant is Amber 1. Lee, who currently resides at 1002 Howland Square, Arbutus, Baltimore County, Maryland 21227 since July, 2004. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on September 2, 1989 at Woodland, Baltimore County, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 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 require the parties to participate in counseling. 8. Plaintiff requests 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. S 4904, relating to unsworn falsification to authorities' . Date: February 2-- L-;L006 ? / ~ ..,/ .' . /.....' _~;1';' -, "J'..., ,'_ ..." ~ Charles M:Le~, ~laintifr ,-1' ./'" L_< L V C:')~~~ David Patrick Perkins, Esquire Attorney for Plaintiff Attorney ro. No. 34342 4 James Circle Shippensburg, PA 17257-2165 Telephone: (717) 532-6629 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHARLES M. LEE, Plaintiff CIVIL ACTION -LAW VS. NO. 06 - 10'4 CIVIL TERM AMBER L. LEE, Defendant IN DIVORCE VENUE AGREEMENT elJRSUANT TO Pa.R.C.P. No.) 920.?(a)L?) I. Plaintiff is Charles M. Lee, who currently resides at 3294C Wakefield Road, Harrisburg, Dauphin County, Pennsylvania 17109. 2. Defendant is Amber 1" Lee, who currently resides at 1002 Howland Square, Arbutus, Baltimore County, Maryland 21227. 3. Plaintiff and Defendant desire to obtain a no-fault divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code to be filed in the Court of Common Pleas of Cumberland County, Pennsylvania. 4. There are no outstandwg custody, support, or equitable distribution matters between the parties to be resolved by this Court. 5. The parties agree that venue shall lie in Cumberland County, Pennsylvania and that the divorce action may be brought in Cumberland County, Pennsylvania. I verify that the statements made in this Venue Agreement are true and correct. I understand that falsc statements her<lin are made subject to the oenalties of i 8 Pa.C.S. S 4904. relati::lg to unsworn falsification to authorities . Date:~--L J- "L.. ,2006 / J:/ ---:;;::".//~' ',' ,"-, - / #'t. Charles Kf. Lee, Plaintiff' t../., ....~ {.-' I verify that the statements made in this Venue Agreement 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: _E~~E-UP.R.'i.'i., 2006 (I. . .' . _,,-.t h-.i..~ti{.. A~~r 1" Lee, Defendant ~ (:::) 4- - "- \'". "-. "'f ~.. ~ " --- 'G (). <;;'- IS'- ~ ~ ~ ( ~ A, ,~' V\ ':~ 'il ~'1'~ :~ o. J ',l' r...,) -- r (, :'1 '-'; " , .,.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES M. LEE, Plaintiff CIVIL ACTION -LAW vs. NO. 06 - 1074 CIVIL TERM AMBER L. LEE, Defendant IN DIVORCE PROOF OF SERVICE 1 certify that on February 24, 20061 served a true and attested copy of the Complaint in Divorce, Notice to Defend and Claim Rights, and Venue Agreement upon the Defendant in the above captioned matter by depositing the same in the United States Postal Service, certified mail, restricted delivery, addressed as follows: Amber L. Lee 1002 Howland Square Arbutus, MD 21227 USPS Domestic Return Receipt evidencing delivery on March 4, 2006 is attached hereto. I verify that the statements made in this Proof of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Q 4904 relating to unsworn falsification to authorities. Date: June 16, 2006 Q~ (J. c7~ David P. Perkins, Esquire Attorney for Plaintiff ,. ,,. U'1 M r:::J ...0 IT' IT' U'1 I"- ", r:::J r:::J r:::J r:::J r:::J U'1 r:::J ", r:::J 0 ~ ll>HtAjn:~:~..~.~?::...h..:....J.::~..~.... . ., PO Box No. . . ~ ""2- .....................--. "",,&:,,_"'.._:..L............_.....~~\>Il.......N ~ oS 0::0. U 1\41.....- "'''T'.~'''''''''4 ....................... ~ . 9,,-~ LlS "" D ?-I ~ -;t.......-......., u ,. t-)t)'--,Ll: '",1 r co CER T IFIED rvlAIL RECEIPl I (Domestic M.-Jl! Only, No Insurance Coverage PrOVIded) , . , , HOHfiorfm lIe " A L , , USE 1 PooIogo . $0.39 ee.tlftedFeo $1.41) 0257 (Endo=,~ 05 $1.25 Postmark - R_lle!lvmYFeo n.70 (El.ck.......nent Required) -.Poetag...... $ $2.3. 02/2,12006 .. . .. . " Amber L. Lee F:l~ 1002 Howland Square Arbutus, MD 21227 ~ 2.__ m--_lIIIoO PS Fornt:IJ81',~ 211M 7003 . .........;..~' ~.. .... ~ . ....0 c-..o C:;) G' ~ l",) - .. f',) -.I _ c___ ''''II! ~ C............... nit Al.i_ 1._ ~=-'I? ~e'~ rr~ 0500 0003 75~~ b015 ~ l '--- 1~-M-1540 (::) "T1 =rt fj,;n ~gf9 'j[~ ~:.1'~ '__I;-:=:;:, ::::~:';j~ ~.l ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHARLES M. LEE, Plaintiff : CIVIL ACTION -LAW vs. : NO. 06-1074 CIVIL TERM AMBER L. LEE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on February 23, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) 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 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 unsworn falsification to authorities. Date: ~ R, 2IJb& t ~PL Charles M. Lee, Plaintiff ~ ! cr~ _0_ t:':' "':!. r-....1 ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHARLES M. LEE, Plaintiff CIVIL ACTION -LAW vs. NO. 06 - 1074 CIVIL TERM AMBER L. LEE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER g3301(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 if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decr~e 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 unsworn falsification to authorities. Date: -1J~ if ZhnJ Charles M. Lee, Plaintiff C') (3 f"\ ~>." IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHARLES M. LEE, Plaintiff : CIVIL ACTION -LAW VS. : NO. 06-1074 CIVIL TERM AMBER L. LEE, Defendant : IN DIVORCE 1",) (.,:; AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on February 23, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) 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 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 unsworn falsification to authorities. Date: U //? / () (p I I G"1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CHARLES M. LEE, Plaintiff CIVIL ACTION -LAW vs. NO. 06 - 1074 CIVIL TERM AMBER L. LEE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301(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 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 unsworn falsification to authorities. Date: U (/7 /(/~ Amber L. Lee, Defendant ;0-'-,,-' CO~\ C.::J f"'.._) CHARLES M. LEE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1074 CIVIL TERM AMBER L. LEE, Defendant : 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 service of the complaint: March 4, 2006, certified mail. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code: by Plaintiff on June 16,2006; by Defendant on June 17,2006. (b)(I) Date of execution of the affidavit required by ~3001(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 a copy of which is attached: Not applicable. (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: July 6, 2006 Date Defendant's Waiver of Notice was filed with the Prothonotary: July 6, 2006 Date: July 6, 2006 9~G~ David P. Perkins, Esquire Attorney for Plaintiff 4 James Circle Shippensburg, P A 17257 Telephone: (717) 532-6629 ,..~. 'I , (..., " , Cr""l r ."~l . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . STATE OF PENNA. CHARLES M. LEE: . Plaintiff No. 06-1074 CIVIL TERM . . . VERSUS AMBER L. LEE: . . Defendant . . . DECREE IN DIVORCE . . . . . . . 2006 IT IS ORDERED AND . . AND NOW, 1,.1. I CHARLES M. LEE , PLAI NTI FF, ~ II . DECREED THAT . . AMBER L. LEE AND , DEFENDANT, . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . 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 . . . . . . . ~/A-I~ R ~/~ ~ ,., ~ROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . \ . .p% ~~ 1il.eI.L ~ fJ" 1- /r/"" 1iP;.p1? ?il.eIL