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HomeMy WebLinkAbout02-1304JO ANN OLSON, PLAINTIFF Vo BRIAN DEAN OLSON, DEFENDANT IN THE COURT OF CO~ON PLEAS CU~PJ~%ND COUNTY, PENNSYLV]%NIA 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. 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, PA 17013 (717) 249-3166 1-800-990-9108 JO ANN OLSON, PLAINTIFF Vo BRIAN DEAN OLSON, DEFENDANT IN THE COURT OF CO~ON P?.~-%S ~ COUNTY, PENNSXLVANIA IN DIVORCE COMPLAINT UNDER SECTION 3301 (C) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Jo Ann Olson who resides at 33 Palmer Drive, Camp Hill, Cumberland County, Pennsylvania 17011. The Defendant is Brian Dean Olson who resides at 10 Drive, Mechanicsburg, Cumberland County, Pennsylvania juniper 17055. 3. The Plaintiff and Defendant have been a bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 14, 1994 in Dauphin County, Pennsylvania. 5. The parties have been living separate and apart since October 6, 2001. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. There was one child born of this marriage, Brian Dean Olson, II, DOB 09/10/96. 9. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 10. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION 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. 4904, relating to unsworn falsification to authorities. ~n JO ANN OLSON, Vo PLAINTIFF BRIAN DEAN OLSON, DEFENDANT IN THE COURT OF CO~40N P?~S CUMBEPJ~%ND COUNTY, PENNSYLVANIA NO. 02-1304 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 15, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. falsification to authorities. Section 4904 relating to unsworn om OLSON JO ANN OLSON, PLAINTIFF Vo BRIAN DEAN OLSON, DE~'~-~DANT IN THE COURT OF C~N PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1304 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT Section 3301(c) of the 1. A Complaint in Divorce under Divorce Code was filed on March 15, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. DATED: - to the penalties of 18 Pa. C.S. falsification to authorities. 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject Section 4904 relating to unsworn JOANN OLSON, PLAINTIFF BRIAN DEAN OLSON, DEFENDANT IN THE COURT OF CO~ON P?~S CUNBEPJ~%~D COUNTY, PENNSYL%rAN~A NO. 02-1304 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301¢c} OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 i~mediately 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: ~.~..~/~//~ JO ANN OLSON, PLAINTIFF Vo BRIAN DEAN OLSON, DEFENDANT IN THE COURT OF CO~ON PLEAS C%R~BEBLAND COUNTY, PENNSYLVANIA NO. 02-1304 CIVIL TEP/~ IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301{C) OF THE DIVORCE COD~ 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: BRIAN DEAN OLSON JO ANN OLSON, PLAINTIFF BRIAN DEAN OLSON, DEFENDANT IN THE COURT OF COI~ON PLEAS ~ COUNTY, PENNSYLVANIA NO. O~- 13~0'4 C_.I~'~'C 'T-~',e,,~ IN DIVORCE ACCEPTANCE OF SERVICE I, Brian Dean Olson, accept service of the Divorce Co~plaint in the above captioned matter. Dated:: Brian Dean Olson Il0 Juniper Drive Mechanicsburg, PA 17055 DEFENDANT JO ANN OLSON, PLAINTIFF BRIAN DEAN OLSON, DEFENDANT IN THE COURT OF CO~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1304 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail on March 15, 2002 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the signed Acceptance of Service attached hereto, the Complaint was received by the Defendant on March 17, 2002. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA (717) 731-1461 17011 JO ANN OLSON, : IN THE COURT OF CO~ON PLEAS PLAINTIFF : C%~4BERLAND COUNTY, PENNSYLVANIA v. : NO. 02-1304 CIVIL TERM : BRIAN DEAN OLSON, : IN DIVORCE DEFENDANT : PRAECIPE TO TRANSMIT RECORD To to 1. 3301 (c) 2. the Prothonotary: Transmit the record, together with the following information, the Court for the entry of a divorce decree: Ground for divorce: irretrievable breakdown under Section of the Divorce Code. Date and manner of service of the complaint: On March 17, 2002 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Defendant, June 24, 2002. 4. 5. By Plaintiff, June 30, 2002; Related claims pending: None Date Plaintiff's Waiver of Notice in ~ 3301(c) was filed with the Date was filed with Prothonotary on July 2, 2002. Defendant's Waiver of Notice in ~ 3301(c) the Prothonotary on July 2, 2002. Thomas D. Gould, Esquire Attorney For Plaintiff divorce divorce IN THE COURT Of COMMON PLEAS Of CUMBERLAND COUNTY STATE Of .~. PENNA. JO ANN OLSON, Plaintiff VERSUS BRIAN DEAN OLSON, Defendant N O. 02-1304 CIVIL DECREE IN DIVORCE AND NOW, Decreed That JO ANN OLSON /O' 2002 lt iS OrDErED AND , PLAINTIFF, AND BRIAN DEAN OLSON , 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 BY T h E/~{D U rt:~ ~// ~TARY