Loading...
HomeMy WebLinkAbout06-1134 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA Michael G. Henry, v. Defendant CIVIL ACTION - LAW NO. 06 - i 13l.j CIVIL TERM IN DIVORCE Beth Ann Henry, 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 LA WYER AT ONCE. IF YOU DO NOT HA VE 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 Michael G. Henry, v. Defendant CIVIL ACTION - LAW NO. 06 - /13,/ CIVIL TERM IN DIVORCE Beth Ann Henry, COMPLAINT UNDER SECTION 3301(c) OF THE I>IVORCE CODE 1. Plaintiff is Michael G. Henry, an adult individual, who resides at 137 Brookwood Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Beth Ann Henry, an adult individual, whose address is unavailable to Plaintiff at this time due to the fact that Defendant has lodged a PF A against Plaintiff and therefore Defendant's address is not accessible to Plaintiff. (Plaintiffs counsel will have complaint privately processed upon Defendant.) 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 23,2002 in Ocean City. Maryland. 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 require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: f:rf? Leslie A. Tome, Esquire 155 S. Hanov r Street Carlisle, P A 17013 (717) 241-6070 Supreme Court 1.0. # 200198 Attorney for Plaintiff VERIFICA TlON 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: rc"/) ;2 '/,00 , ~4.I c ~~V Michael G. Henry, Plaintiff .~ ~ ..... ~ ~ "'<:0, ~,) '" 0:/' h.~ , , ''1 ~ --"1 :-) I:' (:; -- ~ r..,) 1""" %.- , IF) -C:. () , " '+oJ '" ;~ ~ ~, \.-.- ~ 3 1\; .... -' Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Michael G. Henry, v. Defendant CIVIL ACTION - LAW NO. 06 - 1134 CIVIL TERM IN DIVORCE Beth Ann Henry, ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Beth Ann Henry, in the above-captioned action and I certify that I am authorized to do so. rI 0..ucjuo-t LL Date BY: ~d:h Clilil..~'fll"~ Beth Ann Henry, Defendan '* I Wd.nt --+he.. ~f'\~ e dfU',s ~ ~+ak -\.hcci -:r. \.O-i.C (lot . be- nf-LJ h:S~ibti -\hr ~ ~J1s \~ m,dlatls ,\'tanK ~Ur{~ C)..Jr \lYre.. h1 a ~ c. ()...t"\ 6 Uf -\D --th~ o.\, vort.c.. \ S ~\n -a..L . ~Q,~ ,...., = = --.I ..,., J"l'1 co N N -0 ::r; ~ ~:n hi ~6 "., "'T. ;r: :0 ~~C) om ;g ~ - .. N OJ Michael G. Henry, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. Defendant CIVIL ACTION - LA W NO. 06 -1134 CIVIL TERM IN DIVORCE Beth Ann Henry, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) ofthe Divorce Code was filed on February 27, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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, S 4904, relating to unsworn falsification to authorities. Date: F~LJ /0,,07 . ~J(J 1I~ Michael G. Henry, Plamtl o c: s:: -0 IT- ~~., (0~'~- ~(c, '~ .. )>c. be 'J> ...- :;z ~ r-..:> = = --' .." f'T1 co N o ~ ~:D -om ?3~ ::t-r', ~ g~ ?5 w ~ .s:- - .. Michael G. Henry, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Defendant CIVIL ACTION ~LAW NO. 06 - 1134 CIVIL TERM IN DIVORCE Beth Ann Henry, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I cons'='T)t to the entry of a final decree of divorce without notire. 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. S4904, relating to unsworn falsification to authorities. Date: F~b /~JO/ , 2 s:. "'0\.):1 mq~' :zf;: <P. . .../:'" ..<~~ ':2c "2.C".' ~() Y"C: 2:. 2 ~ ~~ -cto ~nO T~.b ::7. :!;\ -0 0-- ~ f5.~ - ::::.\ ~ ~ 1;' ~ ':3 """ ~ N c:> Michael G. Henry, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Defendant CIVIL ACTION - LAW NO. 06 - 1134 CIVIL TERM IN DIVORCE Beth Ann Henry, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 27, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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:_'1 ~. Q 'd t>1---- (") c <' "'tl ';'"':, [1'\ p-c ~"';'.... ....! ~ Zf" ~)':' ~~. .Lt: Pc' Z ~ r--> = = ....... .." rrt co N o o " ~:n -or.; :n 0, OJ., -leI :T. :H 0-- ,,,,,0 om -I ~ -0 :x c,.) .z:- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Michael G. Henry, v. Defendant CIVIL ACTION - LAW NO. 06 - 1134 CIVIL TERM IN DIVORCE Beth Ann Henry, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I COllSl:ut (0 the entry of a iinal 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. 94904, relating to unsworn falsification to authorities. Date: -"\ ~. \,,, 11 "I<s ~ ~.~cl,rtl<J Beth Ann Henry, Defendant (") c: ~~ -0 cc: ~J) r,~., ; ze' U} , ;:-: :,,:- ,.,. -', 'Z:C\ :PC: ~ ~ :::. ..." ~ f') o ~ ~~ :~$ c> .., ,.\~, "C-(1 '""0 96 ::c. "'- rn - ~ ?E c..:> ~ ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Michael G. Henry, v. Defendant CIVIL ACTION - LAW NO. 06. 1134 CIVIL TERM IN DIVORCE Beth Ann Henry, 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 ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: February 27, 2006, was served on Defendant by acceptance of service on August 17,2006 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by ~ 3301 (c) or The Divorce Code: by the Plaintiff, February 16,2007; by the Defendant, February 7, 2007. 4, Related claims pending: None, 5. (b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: February 20,2007. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: February 20,2007. Date: February 21, 2007 Les' , Tomeo, E 155 South Hanover Carlisle, P A 17013 (717) 241-6070 Supreme Court ID No. 200198 (') "'-3 ~ <:::::3 C = -~ -..I <~ ~:!i 'l}l':n .." t:p r~;; f'T1 oIl_ .,,_" co ;BS ?I:: '" ~]'" N 01 ,.....:, .-;0 ~~~ ::r-r. ~~~ -0 <5 ::n ::s: ~.,.o om ~ N ~ (X) -< ~,+; ,+;~ ,+; ,+; ,+; ,+; .. .. ,+; ,+; '+;'+;~;Ii ;Ii;li~ ~Of.0f. AS ;Ii ;Ii;li;li;li Of. .. ;Ii ;Ii..;Ii.. ;Ii ..;Ii;li;li;liOf...Of......... ....;Ii...... .......... ..;Ii.. IN THE COURT OF COMMON P OFCUMBERLANDCOUNTY STATE OF PENNA. Michael G. Henry No. 06-1134 Pl;:lint-iff VERSUS Beth Ann Henry Defendant DECREE IN DIVORCE AND NOW, f ~\H"\,)'~,\ ltJJ7, IT IS 0 1.1 DECREED THAT Michael G. Henry AND Beth Ann Henry DANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS HICH HAVE R HAS NOT BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL YET BEEN ENTERED; OR~ I i I i I i None. ONOTARY ....................~.. ~ ~ ~~~~~~~~~~~+~ ~~~++~+++~ +++++~~~~+ ~~+ +~+~+++++~~ ~ if... .... .. .. .. .. if. if. .. if. .. .. .. ;Ii .. .. .. ;Ii if. .. if. ,+; if. if. if. .. .. .. .. if. .. if. .. if. .. .. .. .. .. .. if. .. J. ~ ~ ~ ~ (0 1 I' ~Z~~',P9 LO. IJ..c .. '. . .... .