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HomeMy WebLinkAbout06-2325 f , D Renee M Bingham, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O(p - :J3~ (!~~ CIVIL ACTION - LAW IN DIVORCE v. Stuart A Bingham Sr, Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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, 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 --. James A. lIer, Esquire Attorney for Plaintiff ------ . ( Renee M Bingham, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. {)(,-.( 3.h'" CIVIL ACTION - LAW IN DIVORCE Stuart A Bingham Sr, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Renee M Bingham, who currently resides at 3588 Golfview Drive, Mechanicsburg, Cumberland County. PA 17050 2. Defendant is Stuart A Bingham Sr who presently resides at 3588 Golfview Drive, Mechanicsburg, Cumberland County. PA 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 18, 1999, in Ocean City, Worcester County, Maryland 5. parties. There have been no prior actions for divorce or annulment between the 6, The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 Ie) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. .. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree dissolving the marriage between Plaintiff and Defendant; Respectfully Submitted, Miller Lipsitt L,L(> / yY:..... //// c::U</"~- // James A Miller, squire / Attorney for Plai tiff / 2157MarketSt et Camp Hill, PA 7011 . (717) 737- 0 ",-------- ,. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Renee M Bingham, Plaintiff Stuart A Bingham Sr, Defendant CIVIL ACTION - LAW IN DIVORCE VERIFICATION I verify that the statements made in this Divorce 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: f( / () /ui(l /~ f/1UJ ~(7U .~~f~ CV/ Renee M"Bingham, Plaintiff L ~\?~~ ~_'T"- - ,'\t ~~ 0' ...s:::. ~-J --.., --"\ \"- '.\ '-.;} ('--' , ~,'. -~. r....,' ",' ~~ _.-1 , Renee M Bingham, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 Co 2.. 3 z, 5" Stuart A Bingham Sr, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT I, Stuart A Bingham Sr, Defendant in the above captioned matter do hereby on the date indicated below accept service of the divorce complaint filed by Plaintiff, Renee M Bingham, to the above term and docket. C/ (; 6/t1C ~~~~~ham s:~efendant Date: ~. $) i ~ ~ ~, ~~\ a-: ~ ~~. (J3 ~~ ~c, ~ %~ i~ ~ ~ ~ ~ ~ Renee M Bingham, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2325 CIVIL ACTION - LAW IN DIVORCE Stuart A Bingham Sr, Defendant AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 25 2006 and service was obtained upon the defendant on April 26 2006 by personally accepting the same thereof. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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.A. Section 4904, relating to unsworn falsification to authorities. Date: 7/85/ lid . / ~,~ 10, ~d"/1,~ Renee M Bingham ~ 2, ~ -001 t9C. ~::: %' (nP~.. ;';'0 \2(..' he ~() "'c 3. ~ ~ ~ <::> Q. ~t .- :?)t? -1 q.() ';::..,."'1'" 6~ 5~ ;::.; .- ~ :;:' ~ .- .- .. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06.2325 Renee M Bingham, Plaintiff Stuart A Bingham Sr, Defendant CIVIL ACTION. LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 eel 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. ~e/J ~, ~~ Renee Bingham // Date: 7/ :15/6& I ' o c: s: -ocr; rnr; z~,. ZS: tIl, , ;;:L, ;?;c' 4c...~ ;PC: :z; =< ..., = = "'" ".. c: en ~ ~f2 :gf!.3 b6 ::;1-r. --::0 ~o 0'" ~ "< -.J ~ - .. ~ Renee M Bingham. Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2325 Stuart A Bingham Sr. Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 25 2006 and service was obtained upon the defendant on April 26 2006 by personally accepting the same thereof. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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.A. Section 49"J;04 el~ain to unsworn falsification to authorities. '7 ~c OC~7~ Cl/'" I ')---V Date: ~ ~ , tuart A Bingham Sr (") ....... "" ~ c "" """ <r" -oED :x.- ~ rnp.' c:: ~~ zi:, <n :<: ~'~ ~e~ -.j ~59 ,~~ ;1:00 g' ",. _. -~ ~~~',; :x ~c ~ ,,..; .~ J:'" -< v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2325 Renee M Bingham, Plaintiff Stuart A Bingham Sr, Defendant CIVIL ACTION. LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: 7hC/ob ~~~~ -~-<< ( /Stuart A Bingham Sr () f; "'. -niT '""\11;;'::' Z::Je,:.' 3;~i~ ~C_ ~E )>c: ~ ...... = = 0'" ~ '" o -n ~:n ~~ al, "~-1-f. "- -n ( 0 -m ~ ~ -.J ". ::l!: .. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2325 Renee M Bingham, Plaintiff Stuart A Bingham Sr, 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. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner service of the Complaint: Defendant accepted personal service of a CERTIFIED COPY OF THE COMPLAINT IN DIVORCE on April 26 2006. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code: by Plaintiff: July 25 2006 by Defendant: July 26 2006 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code: by Plaintiff: contemporaneously with the filing of this Praecipe by Defendant: contemporaneously with the filing of this Praecipe 4. Related claims pending: There are no related claims pending. Respectfully Submitted, Miller Lipsitt LLC By: a c..: z:. -t)i.1:J t'"\"H'f'- -....,.,-f-' ~t;, rr.}..: ';:~c ~2~C: b;() yC; :? :2. ~ ~ ~ <r> q. ~~ -otr, __ ",'0 -" D. b ,,?-".n :'--:J;l 'Z~ 9, -- ~ s;' ~ -- -- ~~+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++~ + + + + + + + + + + + + + + + + + + + + <+ ". + + + + + + + + + + + + + + + + + + R 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; IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PEN NA. Renee M Bingham Plaintiff No. 06-2325 VERSUS Stuart A Bingham Sr Defendant DECREE IN DIVORCE + + + ,+ + + + /"'2(,l'~'" AND NOW, .z.v 2006 + + + + + + + + + + + DECREED THAT Renee M Bingham AND stuart A Bingham Sr ARE DIVORCED FROM THE BONDS OF MATRIMONY. + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + /Jo () ~ B'TH';":uL ATTES /1 K?ai!_ ~~ PLEAS + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, + + + + + + + + + + + + + + + + + + J. _~, t- ~ ~)" 'P-'O 'W"" ~ ?- ~ 4,; /"fJ 'JO H , - " - < ". "