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HomeMy WebLinkAbout01-5363Beverly J. Campbell, Plaintiff VS. William H. Campbell, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. O l- 530 3 CIVIL TERM : : CIVIL ACTION--LAW : : 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 in 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 at the Cumberland County Courthouse, High and Hanover 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Beverly J. Campbell, Plaintiff VS. William H. Campbell, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0[- ~-~g (t7~ CIVIL TERM : : CIVIL ACTION--LAW . . : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Beverly J. Campbell, who currently resides at 1113 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is William H. Campbell, who currently resides at 1113 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on September 22, 1984 at Carlisle, Pennsylvanlia. 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 require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Law Office of James K. Jones, Esquire Jatl~ K. Jones, ~l~ire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 I verify that the statements made in this Complaint are true and correct to the best of my knowledge 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. BEVERLY J. CAMPBELL, Plaintiff Vo WILLIAM H. CAMPBELL, Defendant : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 01-5363 CIVIL TERM : : CIVIL ACTION--LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on September 14, 2001. 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 in 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. WILLIAM H. CA PB~~ELL BEVERLY J. CAMPBELL, Plaintiff WILLIAM H. CAMPBELL, Defendant : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 01-5363 CIVIL TERM : : CIVIL ACTION--LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 83301 (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: //~,/~-'0 ~__ wI~BELL BEVERLY J. CAMPBELL, Plaintiff WILLIAM H. CAMPBELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 01-5363 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. Date: William H. Campbell~ BEVERLY J. CAMPBELL, Plaintiff WILLIAM H. CAMPBELL, Defendant IN THE COURT OF COMMONPLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 01-5363 CIVIL TERM CIVIL ACTION--LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECI~EE UNDER 83301 fo) OF ~ 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: VERLY J.~BELL~' BEVERLY J. CAMPBELL, Plaintiff WILLIAM H. CAMPBELL, Defendant : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : NO. 01-5363 CIVIL TERM : : CIVIL ACTION--LAW : : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301 (c) of the Divorce Code was filed on September 14, 2001. 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 VERIFY THAT THE STATEMENTS MADE IN THIS AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: · BEVER~ CAMPI~'E-LL ' BEVERLY J. CAMPBELL, Plaintiff VS. WILLI~ H. CAMPBELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 0-7--05363 CIVIL TERM 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 lc) (Strike out inapplicable section). 2. Date and manner of service of the complaint: .F±rst class ma±.1., postage pre [:~ with Acceptance of Service signed by Defendant. Complete either paragraph la) or lb). la) Date of execution of the affidavit of consent required by §3301 lc) of the Divorce Code: byplaintiff November 14, 2003 ; by defendant Novez~ber 13, 2002 lb) (1) Date of execution of the affidavit required by §3301 (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 la) or lb). la) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 lc) Divorce was filed with the Prothonotary: November 2~', 2003 Date defendant's Waiver of Notice in §3301 ,lc) Divorce was filed w th the Prothonotary:~ovember ].9, 2002 ,~/Attorney for.l~-~"tiff / I~P,,~E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BEVERLY J. CAMPBELL, Plaintiff VERSUS WTLLTA~ M. ~AMpB_ELL~ Defendant N O. 01-5363 CIVIL TERM DECREE IN DIVORCE AND N OW, ~___~_~ , 2~, IT IS ORDERED AND DECREED THAT BEVERLY J. CAMPBELL , PLAINTIFF, AND WILLIAM H. CAMPBELL , 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; "'" '"HE! c°,'77 /¢