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HomeMy WebLinkAbout01-5356 AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 01 - -S'.2Sb Ctull~~ GEORGE P. ANDERSON Defendant CIVIL ACTION -- LAW 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 MAYBE 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 A V AILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE YORK COUNTY COURTHOUSE, 28 EAST MARKET STREET, YORK, PA 17401. 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. Court Administrator Cumberland County Courthouse 3 S. Hanover Street Carlisle, P A 17013 Telephone: (717) 697-0371 AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 0 l ~ Q%~ CCJtL~) GEORGE P. ANDERSON Defendant CIVIL ACTION -- LAW COMPLAINT IN DIVORCE COUNT I I. The plaintiff is Amy D. Anderson, who currently resides at 6 Holly Road, MarysvilIe, Pennsylvania since July 2001. 2. The defendant is George P. Anderson who currently resides at 6028 Hummingbird Drive, Mechanicsburg, Pennsylvania since April 1996. 3. There are two minor children of the parties: George P. Anderson, Jr., dob 8/18/96 and Devin W. Anderson, dob 9/12/97. 4. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married February 14, 1998 at Mechanicsburg, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. The parties have not entered into a written agreement as to alimony, counsel fees, costs, and property division. 9. 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. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. The cause of action and section of the Divorce Code under which Plaintiff is proceeding is S3301(c). The marriage of the parties is irretrievably broken. II. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the Court enter an Order dissolving the marriage between the Plaintiff and Defendant. Dated: 9 /1' lo( ( Respe:5[uIly submitted, /a(~ _ Timothy J. Colg, 're WILEY, LENOX, COLGAN & MARZZACCO, P.C. I South Baltimore Street Dillsburg, P A 17019 (717) 432-9666 LD. #77944 VERIFICA TION I, AMY D. ANDERSON, verifY that the statements made in this docwnent are true and correct to the best of my knowledge, information, and belief. 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: 9--005 -()/ (~~J4kdj)1rf'& .~ /~i:y WANDERS . Plaintiff 0, - ~ N 7i ~ ~ 0 a C) 8 frJ c "n ~ . S u') ~ -0 C) ,,., ':"Xl 8 lr) [I1n: "'"U in '- 2::11 ~ \) ZC' :~~'r ~ (f) ;_~ (..; , C) i ---....-r.,. ~ , r"r- ""'!J \'- -'-" ~- ::J;: (':5 (), VJ ::E:c~, ...(: fP g:~! -'in r;;> CJ ~ Pi.. -,.-.r ~ ).0" r :D ...- -< '>- r!;, ",- ~..:..:, N >- 1-- ---;:- ~:i~ r:::\~ (/) ;;;; .1LLi -1~ 0_ ~~ G :-~r: u- ;") C' ~ !.....' V~ .~:-) " 0.. g 0'1 ;Z :::J~cn_\O o 1 e ~ 0;' cG-O_N C '< E ~ ~ >- Vl';: p..j _ u.J >- '";; ~ r--- ....J l.I.llXj e!l- ~ ~..c;::l C ;>~_.D" g ~ C u.l CI):-:::;O ~ <<: 1;l '" a:: o ""', AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 01-5356 CIVIL TERM GEORGE P. ANDERSON Defendant DIVORCEICUSTODY AFFIDAVIT OF SERVICE I, Michele A. Reneker, being duly sworn, deposes and says that she is an adult and that she served the within Complaint on the Defendant, at the Defendant's last known address as follows: 6028 Humingbird Drive, Mechanicsburg, PA 17055, by certified mail, restricted delivery, return receipt requested on the 1st day of October, 2001. The A copy of the PS form 381 II are attached hereto, marked Exhibit "A" and made a part hereof by reference thereto. Date: October 4, 2001 WILEY, LENOX, COLGAN & MARZZACCO, P.C. By: ~mti hiff (1.. ;PM! g J)iA Michele A. Reneker, Secretary to Timothy J. Colgan, Esquire COMMONWEALTH OF PENNSYLV ANlA : UvJt_ : SS COUNTY OF d - On this, the 4th day of October, 200 I, before me, a notary public, personally appeared Michele A. Reneker, known to me or satisfactorily proven to be the whose name is subscribed to the within Affidavit and acknowledged that she executed the same for the purposes therein contained. WITNESS, my hand and notarial seal the day and year aforesaid. NotarIal Seal S. Dawn Gladfelter, Notary Public DlII8burg Boro, Yor1l COUnty My Commission Expires May 11.2005 Member. peoosyIvaniaAssOCiallOnolNolal18S ~dll{;i jll~/fhJ) NOTARYPU LIC My Commission Expires: . Complete ~em. 1, 2, and 3. Also complete ~am 4 II Restricted Oallvery is desired. . Print your name and address on the reverse so that we Can return the card to you. . Attach this caRl to the back 01 the mall piece, or on the front If space permits. ,. Arli<;IeAddl8SS8dto: , CJ Agent Add...... CJ Yes CJ No 3 /~lgeType r" t!l c.riliiOd~ CJ RoglstOl1ld o Insured Mail D Express Mall D Return Receipt for Merchandise CJ C.O.D. 4. Restricted Delivery? (Extra Fee) )C] Yes 2. Artk:le Number (Copy from service Iabef) 709q~~ ~/~ -r'~/ ~f'1 PSForm 11,Julyl988 '~AoIum~ 102585-OO-M-0952 .. .. .- C~, -~ ::.--) .-r-l I v "T) ~; Coj r~: L ~:r:~ ~' (~.~ "/ =;! ~:-: ~';) :Ji h) o " "1:1" g s~. ",;l>~ :::s ::::: 0 " ~" ~ ':::l~:;~;5 -cro I;;:lj ~ t'""" ~~ ~ ~ tyj ... :;::~. 0-<: v.> S ~ C'l ~~~~~ 0\-C/:l~8 0\ 1.0 ..... .... 0\ @v ~ l,?<>C7 0 "- c () - }:> ~-"" = +- -ae,n I" '" mrTl <i) -r 0> z::o ! '" t;;r;:;: -j- (' , rr :r- -0 !J ~ ~'.? ':! "J ,:Ji :;J -< 10 -< vJ .' <.11 ~ In The Court of Common Pleas of Cumberland County, Pennsylvania FileNo. 2001-05356 ANDERSON AMY D vs ANDERSON GEORGE P STATEMENT OF INTENTION TO PROCEED To the Court: Amy D. Anderson intends to procE'ed with the above captioned matter. Date: I{-r,,--oy , ~A~ Attorney for Plaintiff, Amy D. Anderson (') ~~ -..: ;Yf'~.. 0:. ,"::1." 2: ,~'- / . .:,-~' ( )>r-~:' :;";;' /- ~ r-> = = ...- U'l Cl.~1 -co --.l -0 I:Y N 0' 'S-', IY - 0 S ^---- AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. 01-5356 CIVIL TERM GEORGEP.ANDERSON Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in Divorce under 9330I(c) of the Divorce Code was filed on September 13,2001. 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 made herein are subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date g -" ~-- '~,\y~', ~~f~; ~_. ~<~~ ":" ...<. ~ ~ 'e ';;e- I c1> Q. ~:l;l "5};tt. ~~, O~' ."R- s <0 -'~ ...., -:;1: N " N - AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 01-5356 CIVIL TERM GEORGE P. ANDERSON Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under s3301(c) of the Divorce Code was filed on September 13,2001. 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 made herein are subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification to authorities. lp~~'o~ Date ,..., = = <.M E :.:.e o "T) :rJ"T) rnp ""Urn ;,,9 'J('- --I ~:J r::q .s?(~ .:jI'M ;.-1 :'0 .< ,l:'" -0 :1r: r:? N N AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 01-5356 CIVIL TERM GEORGE P. ANDERSON Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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 verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. [0- n8 -()<:. Date g, <g;, <-- <;jii .- ~ q, -:t.~ ".~ -0'<") ~l?"-'( 0(-) :?~;~0) ~':"/_~n ;.::\ -;;p ::L;, .." ::x:. r;:; ~ . . AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 01-5356 CIVIL TERM GEORGE P. ANDERSON Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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 Courtand 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 made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. 5~ /1- oS rt Date C'a-0 ~ -8 '~L Ofl.iq f 'JI l. Il-l-L, rr-Ovt~cl -j~'fL doc...l!i:c.L COfY. 1 0 ....., ~ = c: = c 1;;.1'1 -< I ,- -r I c: F1,:!] :;:;c: r- -0 iT'. I :nO a:> .~j I t. :~.~ c; -~- --t-, ,., :~,2~~ ~. ~~ cjrn ~ -,1 5'i N -< ~c../21h-c- ^ ,.... , AMY D. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 01-5356 CIVIL TERM GEORGEP.ANDERSON Defendant CIVIL ACTION - LAW 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. Grounds for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: The Defendant was served via certified mail. restricted delivery. return receipt reQuested on October 1. 2001, the PS form 38111 was filed with this Honorable Court on October 9, 2001. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: June 8. 2005 ; By Defendant: Mav 18,2005. (b) (I) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: NIA (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: N/A. 4. Related claims pending: No related claims are pendinl!: with this Honorable Court. ..~ . Date: 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce wasfiledwith the Prothonotary: June 14. 2005; Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 8. 2005. Respectfully Submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.c. (-;;lb -C(, Tim~ Supreme Court LD. #77944 130 West Church Street, Suite 100 Dillsburg, PA 17019 (717) 432-9666 (Attorney for Plaintiff) By: 0 "" 0 ~ C~: = """ o~ .." :.:;:l I"T1 ..:." OJ rl1f'~^ f:'J 1 'y' e} -1-- ~ ('::: ~2 I-n (,C> ~i] , G", .~ ---- ,+,'f :+:'+' Of . . . . . . + . . + . . . . . . . . + . + + + . . + + + . + + + + + + . + + + + + + + + + + + , + + + + + + + . + . + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + . + + + + + . :+. :+:'+':+: + + +. . .. . :+: :+::+::+: . . . :+::+: :+.:+:;+;:+::+: :+: :1':+::1':+::1':1' Of +Of + . . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF AMY D. ANDERSON, Plaintiff VERSUS GEORGE P. ANDERSON, Defendant PEN NA. ~ '3 .\-(p 01-~ CIVIL TERM No. DECREE IN DIVORCE AND NOW, F' E: ~~\,j~Q.,( ,'looe", IT IS ORDERED AND 7 DECREED THAT AMY D. ANDERSON , PLAINTIFF, AND GEORGE P. ANDERSON , 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; :+.:+::+.:+: :+: . + '+''+' '+' Of '+':+::+:'+':+::I' . + . . + + + + + + + . . + + + . . . . :+.~ ~:+:+:+::+'++~:+::+'++:+:Of :+::+: ? BY T~ C~CTW \ ATTEST,' ~ ~ PROTHONOTARY + '+':+: + . :+::+: +:+: + . . . . . . + . . . + . . + . + . + . + . . . . . + . . . . . + . . . . + . . . . . . . + . . . . . . + . . . . . . . + . . + . + + . + . J. /;.-c .2> 'r:' .;:h-J .1" /'fJ"V"1 ?~;t, "I.'/' ~,J!"'J {,q, '" /j!7q" /dp;)"" .,.; r;; If . ---"" _.--~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA iJ\YH~ Andey'.tm Plaintiff Vs ~Oy~p /;\nd~(SDa Defendant File No. 01- 5351.0 C v\ \ 1e-r 01 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, . [select one by marking ''x'1 _ prior to the entry of a Final Decree in Divorce, . . or X- after the entry of a Final Decree in Divorce dated t=e. b. 1'. 200 ~ hereby elects to resume the prio.r surname of ffi~ D .ll"){ 1 c\e r , and gives tbi~ written notice avowing his ~tion p~t to the pro~ons ~f 54 P .S. 704. Date: \- ~~-O 7 . Y\Y'^At1\\ ~'t<:\m .. CJ Slgnattrre COMM:ONWEALTH OF PENNSYLVANIA ) COUNTY OF ~kJ Ju-J.. ) On the J 3~ day of ~.LUJ. J, . 200.L before me, the Prothonotary or the I notary public, personally appeared the above affiant !mown to me to be the person whose name is subscribed to the within document and aclmowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. NOTARIAL SEAL PROTHONOTARY, NOTARY PUBUC CARLISLE CUMBERlAND COUNTY COURTHOUSE ! MY COMMISSION EXPIRES JANUARY 4, 2010 Prothonotary or Notary Public fC;c. ~. L. J 'f. 55'-1, 0 J 7 , ~ 'V ~ ~ "-f ~ \ ~ ~ t ~ . .......... .. ~--..-. ", ~"". . ~,- . ~ .., . nr !~. ";'1 'I:~40:' ':: ---: ~~" ~':~j.-,'n::) f'1;~" ',r,;~!t 1, :1~),1 Y9','::t,{,'\1 ~ "'r"r',:": N .. I'\.) \.0 ,...., c:;:;, C.:::;, -...., S ~'" 2: ~ :r!~ rn -'-! /- :-alTl ,!~y ::"-'1CJ ~~. .:5111 :.-/ ).:> :n -< I'\.) w :n ~:,..