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Home My WebLink About06-2467 vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA ~ NO. 2006- ~ 4G. 'l e~J' L ~~ : CIVIL ACTION - LAW : IN DIVORCE NANCY L. MOYER, Plaintiff RANDY L. MOYER, Defendant NOTICE TO PLEAD You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth .against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 32 South Bedford Street Carlisle, Pennsylvania 717-249-3166 NANCY L. MOYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.2006- ';<'4(/( u'L) I { '!s'LI RANDY L. MOYER, Defendant CIVIL ACTION - LAW : IN DIVORCE COMPLAINT Plaintiff, Nancy L. Moyer, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff is Nancy L. Moyer, an adult individual residing at 175 Fairview Street, Carlisle, Cumberland County, Pennsylvania. 2 Defendant is Randy L. Moyer, an adult individual residing at 105 Brookwood Drive, Carlisle, Cumberland County, Pennsylvania. 3 Plaintiff and Defendant were married on December 22, 1995 in the Commonwealth of Virginia. 4 Both Plaintiff and Defendant have resided continuously in the Commonwealth of Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of this action. 5 There have been no prior actions of divorce or for annnlment between the parties. 6 The marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing her from the Defendant. BROUJOS & GILROY, P.C. By VERIFICATION 1 verify that the statements in the foregoing pleading are true and correct. 1 nnderstand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to nnsworn falsification to authorities. :r----- ~ " , ~ ~ .~ -- N ~ ......'\ \h " '-' "-,._-," --- -- t'l :::) }..l .- f"- ~. \, W \J> -- -cJ '6 \\ (-'-.. 1= ~ ,- ------ , NANCY L. MOYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW RANDY L. MOYER, Defendant : NO. 2006-2467 : IN DIVORCE CIVIL ACKNOWLEDGEMENT OF SERVICE I, RANDY L. MOYER, hereby acknowledge service of the Complaint filed in the above matter along with the Notice to Plead on the 11th day of May, 2006. Date: ~- ;$[- O~ ik1,iER~ () C ~:,~'~0 ~--" ;0' ,- (/1 ~> (;. . ,.' " , ~-~ ~ ~ = = "" (/) ,..,.., -0 I C1' -0 ::z ~ :r!~ 1l1...:..l -aF;; ,:uc;:> JC c~~j Om ~ -< '& <.J1 <..J 3301 (c).OOI NANCY L. MOYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : CML ACTION - LAW RANDY L. MOYER, Defendant : NO. 2006-2467 : IN DIVORCE CML AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on May 3, 2006. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about May 11, 2006. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. S4904 relating to unsworn falsification to authorities. ....., = = 0' <n rrl ,) I ""' -0 :::s; o .." -l ::r:"l1 rl1F ....'1'11 :fJe ,'-')L, ::;,S--.. ;~5jJ ..<;?l,) Oi"n -I ?O '< '-2 <fl W . . 3301(c).not NANCY L. MOYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW RANDY L. MOYER, Defendant : NO. 2006-2467 : IN DIVORCE CML AFFIDAVIT OF CONSENT AND W AlYER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECI'ION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on May 3, 2006. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about May 11, 2006. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a fmal decree of divorce without notice. 5. 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. 6. 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 ProtIiODotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. ~904 relating to unsworn falsification to authorities. Date: ~ - :?, l "' 0 " ~otlDefen~=~~ / o c :C:=:. -0\:1) n....r; ~y r;;; g; (/) r'"\ --0 \ C1' '.'" ~~() ':i7c ~ ~ ~-n rf1.E .."rn en'=( .~C) -:.-c:;, (-') -:::~..:, ':,t:~ g ~ ...., ~ c.f? <J' c..:> v : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :241.1 NO. 200~ CIVIL NANCY L. MOYER, Plaintiff RANDY L. MOYER, 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 03301(c) (X)3301(d)(l) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: May 11, 2006 by First Class Certified Mail, Return Receipt Requested. 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: August 30,2006; by Defendant: August 31,2006. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 33010 of the Divorce Code: _2) Date of service of the Plaintiff's affidavit upon the Defendant: _ 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to fIle praecipe to transmit record, a copy of which is attached: August 31,2006 (b) Date Plaintiff's Waiver of Notice was fIled with the Prothonotary: (b) Date Defendant's Waiver of Notice was filed with the Prothonotary: Gilroy, Esquire Attorn for Plaintiff BroD os & Gilroy, PC 4 North Hanover Street Carlisle, P A 17013 717.243.4574 ( /: ":n :-::'> '; ;'j. 1"-' \ .', \'.) 'I''Ii<ti 'f.'f.'f. 'f. 'f. 'f. 'f. 'f. 'f. 'Ii 'f. ;Ii ;Ii ;Ii ;Ii ;Ii 'f. ;Ii 'f. 'f. ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii'f.'f.'f.'f.'f. 'f.'f.'f.<ti;li'f.'f.'f.'f.'f. 'f.;Ii 'f. 'f.'f.'f. 'f.'f.'f. 'f.'f.'f.'f.'f.;Ii 'f.'f.'f.;Ii 'f.;Ii;li;li'f. ;Ii;li;li'f.'f.;Ii'f.'f.;Ii'f.;Ii'f.'f.;Ii'f.;Ii;li'f.'f.;Ii;li~ 'f. IN THE COURT OF COMMON PLEAS ~ '" OFCUMBERLANDCOUNTY : 'f. 'f. STATE OF PENNA. Nancy L. Moyer Plaintiff No. ?OOfi-?4fi7 VERSUS Randy L. Moyer Defendant DECREE IN DIVORCE AND NOW, ~LS ~, IT IS ORDERED AND DECREED THAT Nancy L. Moyer , PLAI NTI FF, AND Randy L. Moyer , DEFEN DANT, 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; No Claims Pendin 'f.'f.'f.'f.'f.'l''f.'f.'f.;Ii'f.'f.'f. 'f. '" 'f. '" 'f. '" J. ,h/ ~7)t, ~(/Ie'~ ~p~~~n w.}e-/7 . ... ~ ' .. . .-' .' ..;.-, " .