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HomeMy WebLinkAbout06-2336 , \ U" FRIEDMAN & KING, P.C. Richard S, Friedman, Esquire ID #07176 600 N. Second Street Penthouse Suite p, 0, Box 984 Harrisburg, PA 17108 Tel.: (717) 236-8000/Fax: (717) 236-8080 Attorney for Plaintiff v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO, c.;{, J33(, e~ MICHELLE R. POWERS, Plaintiff MICHAEL A, POWERS, Defendant COMPLAINT 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 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, Cumberland County Courthouse, I Courthouse Square, Carlisle PA, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER A T 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 By: Respectfully submitted, FRIED~ & KING, P.s:, "r //"'____ /' /' ,,/ Richard s..-Friedman, Esquire 600 N. Second St., 5th FIr. p, 0, Box 984 Harrisburg, PA 17108 (717) 236-8000 MICHELLE R, POWERS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 0(.- 235{.. (~T COMPLAINT IN DIVORCE MICHAEL A, POWERS, Defendant COMPLAINT UNDER SECTION 3301(c) AND SECTION 3301(d) OF THE DIVORCE CODE I, Plaintiff is Michelle R. Powers, who currently resides at 204 Birch Lane, Carlisle, Cumberland County, PA 17013. 2, Defendant is Michael A. Powers, who currently resides at 51 Springers Lane, New Cumberland, York County, P A 17070, 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on May 3, 1997, in New Cumberland, Pennsylvania, 5, Plaintiff avers that there is one child of the parties under the age of eighteen (18), namely, Nicole E, Powers, born August 30, 1996 6. There have been no prior actions of divorce or for annulment between the parties, 7. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the parties to participate in counseling, 8, The marriage is irretrievably broken, 9, Neither Plaintiff nor Defendant is in the military service of the United States, 10, The parties separated on June 18,2005, Date: RSF:ka WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce, Respectfully submitted, " 1 FRIEDMAN & KING, P,C, ~ h'(G 1:> , /~ Richard S, Friedman, Esquire 600 N. Second Street Penthouse Suite p, 0, Box 984 Harrisburg, PA 17108 (717) 236-8000 , VERIFICATION I, Michelle R. Powers, hereby acknowledge that I am the Plaintiff in the foregoing action; that 1 have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Dated: Y lit lob" ~~') 7~ ,'f'-.. , '~,',,', \.L.J ~ , , <:::,-, ~-" ..s::-,c.....i:.' ~ V\ ~, --..l --.} ~......,.. '\'J -!"--;-:' c' '" -, v -- "" -' '\:' ' v- <:r' ~'" \_"~/ r'_:~ v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-2336 CIVIL COMPLAINT IN DIVORCE MICHELLE R. POWERS, Plaintiff MICHAEL A. POWERS, Defendant ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, being duly authorized to do so, DATED: 5'('2-/l/t (") ...., ~ = ~ = "'"' -053 :x ~:!l n"1(r', ::>- -;-...,.., -< ~~ z( I (f),t -<:,' \D r:-r <:'"' ;Do I:il )0.." zt :x Qo "C 2m s;; E: '!? ~ z ~ ~ N N MICHELLE R. POWERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v, NO. 06-2336 CIVIL MICHAEL A. POWERS, Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 25, 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 verity 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. DATED: ; I] /0 ( 1 ' ,;//) '--,Jjf /};J J '\ /1 / /. Zit tlL D(l ( ~ O~('" "" 2-4-, Michelle R. Powers; lamtiff (") s ""- -au- mil --7 -.. "'-.. _-,r ; ~, r'-' ~ :);; ( S;{~ ~ -< r--> = = 0" "". c:: G> I \D ~ o -n ~"n rn;= -elm ~~~; r "';;'.1 \~ff; ~~ 55 "< - .. W \D MICHELLE R. POWERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-2336 CIVIL MICHAEL A. POWERS, Defendant COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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 Court, and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary . 4. 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 unswom falsification to authorities. Date: t Ii )0 6 ( I \. ~ = if' :p' c; G" I ..0 (") c ~ -1jO: r-t'111'. .~._c_ /- en ~::~ ~~~~ ~;/ 3- o "'f\ .-\ -:C--n f-n----' <;:;. _()l__~ -:-'-J:~' (;J,e) \"r~,:~S\ ~;~t\~ -v- ~ .",. :> -- -- 0) ..0 MICHELLE R. POWERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 06-2336 CIVIL MICHAEL A. POWERS, Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on April 25, 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. DATED: ?-q-oG ~~ Michael A, Powers, Defendant (") c ~ -ot~ S? ~_: 2: : Cf:>, . ~:~ ,~~ ~~ ~ r--> = = "" "'" c r.::;') o " ,.., I" [11;=_ -oeD ~T.!v' {:;~:(:) g~ ::;J :iJ -< I \D "'" :l~ W \D MICHELLE R. POWERS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-2336 CIVIL MICHAEL A. POWERS, Defendant COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(0) 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 conceming 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 . 4. 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: g- L/- 6" ftV~ L~ Michael A. Powers, Defendant o c: s: "Or;' "", ;;c::~. (7; \,~, ~ ....., = <g; ~ "'...., , ..p ,-- ...----'- ----_.~~._~ . V -F"- ~> - - o -n :Con n"1F -om ~DO _-._ L '._',{ ; ;'~~ 13 ,..;: 0) '" - MICHELLE R. POWERS, Plaintiff v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA NO, 06-2336 CIVIL COMPLAINT IN DIVORCE MICHAEL A, POWERS, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Code, 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of the complaint: accepted by counsel, being authorized to do so, on 5/2/06 3, Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff 8/3/06; by Defendant 8/4/06, 4, Related claims pending: There are no related claims pending, 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 Plaintiffs Waiver of Notice was filed with the Prothonotary: 8/9/06 Date Defendant's Waiver of Notice was filed with thJ1 othonotary: 8/ Richar S riedman, Esquire Attor ey for Plaintiff ) ~. -" ",. ..-0 OJ 0) C:~ .~ (';,\ '::.2.;-:: r::.,-" ~'"- ~~\~ "'_:7 :2 '2S ? :c c> \ ...0 q, .-\ :1:'-r:, rt\f-' -r:>'q 'Z;t S\ :~? ~ ~ ~~ -~ - - " (.0) ...0 ------ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PEN NA. STATE OF MICHELLE R, POWERS VERSUS MICHAEL A, POWERS . . . . AND NOW, . DECREED THAT Michael A. Powers . AND No. 06-2336 Civil DECREE IN DIVORCE ~il~ v Michelle -/~ . , Zddb , IT IS ORDERED AND R. Powers ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, 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 . . . J, PROTHONOTARY ~ b2~~~ 'V-u.~ ~-.. '?-H~ ~..;i~~-<,~ 'Jt?-I..J,,8 ..... . ,,..'~:;,,,... . ,..~ ',,\' ~\. .