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HomeMy WebLinkAbout06-2513 JENNIFER L. OWEN, PlaintifI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 0 t, -:<.~ J 3 NO. CIVIL TERM IN DIVORCE WILLIAM F. OWEN, Defendant NOTICE TO DEFEND 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle, P A. 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 A venue Carlisle, PA 17013 Phone: (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. JENNIFER 1. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. CIVIL TERM 01....;( <{/3 IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Jennifer 1. Owen, who currently resides at 17 Spring Street, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Defendant is William F. Owen, who resides at 301 Morea Road, Frackville, Pennsylvania 93257. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 22, 1999 in Chambersburg, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiffrespectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & WHARE Date: s-h/o!. I I Leslie A. To eo, Esquire 155 South nover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court 10 # 200198 Attorney for Plaintiff JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE VERIFICATION I verify that the statements made in this 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: c J '--') ~ - Ov ~ JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Carlisle, Pennsylvania, addressed as follows: William F. Owen 301 Morea Road Frackville, Pa 17931 Date: April 28, 2006 Leslie A. Tom 0, Esquire Attorney for P aintiff ~-o ~ <;-. ;-~ ~ .~ . D -l;:. - -C _ (,J\. ....c::.. ~D-o ~ ~C>\ -; (b o ~. ~., " JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM IN DIVORCE NOTICE 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM IN DIVORCE AMENDED DIVORCE COMPLAINT TO ADD SECTION 330Hd) OF THE DIVORCE CODE 1. Plaintiff is Jennifer L. Owen, who currently resides at 17 Spring Street, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is William F. Owen, who currently resides at 301 Morea Road, Frackville, Pennsylvania 93257. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 22, 1999, in Chambersburg, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. By: Leshe A. Tomeo, Esquire Attorney for Plai tiff 155 South Hanover Street Carlisle, P A 17013 Supreme Court I.D. #200198 (717) 241-6070 JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM IN DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn Date: IO~\~ -=Oto falsification to authorities. JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Jennifer L. Owen, do hereby certify that I this day served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Carlisle, Pennsylvania, addressed as follows: William F. Owen 301 Morea Road Frackville, Pa 93257 Date: ~I~ 0", Leslie A. Tomeo, E quire 155 South Hanover treet Carlisle, Pa 17013 (717) 241-6070 Court Id. No. 200198 Attorney for Plaintiff ----:--1 () ~~: f'-.-) t:,-,;:J C,_':J C:f""\ r-, '. J ~1 G) -t" f') f"o..1 _-.0 ~.< ,... ", . .... JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or around April, 2000, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. S 4904 relating to unsworn i Date: 10 -I d - falsification to authorities. o c r-....:> c:.::) (~1 Cf-' C> ~~ . ~ ~fl G'l , ~ ~-' c;; JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LA W NO. 06-2513 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: William F. Owen, Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiffs affidavit. Therefore, on or after November 6,2006, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you wiUlose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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, P A 17013 (717) 249-3166 r--:> c::::> ,'''.J Q.... o C'j _i v' W OJ JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry ofa divorce decree. (b) I oppose the entry of a divorce decree because: Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g 4904 relating to unsworn falsification to authorities. Date: William F. Owen, Defendant c' <::":: 1--' = c;;.) er- a ::::~ !:") -'n :::-;1 ff'\ 0""\ -c~ (.,) en JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM IN DIVORCE PROOF OF SERVICE FOR A & B. . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: U,}I \ \\CLr\A O\JJLYl-zLSS")C{ Ja- mtlhc71j , 30' moveY-- ~d d troUt /JI/& (Pd /17,5/ SENDER: COMPLETE THIS SECTION 2. Article Number (Transfer from service label) PS Form 3811, February 2004 3. Service Type V!Certified Mail 0 Express Mail o Registered "la-Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restrlctecl Delivery? (Extra Fee) BYes 7005 2570 0000 3796 5527 Domestic Return Receipt 10259!Hl2-M-1540 g z,: Cc}l;~; >:8 -,.,.c 'z ~ ') -'~ r-' c::? ~~~ - ,."""- c~ ':::~;~ .--\ 1-= :r~ . .lr:: .:~.!..- ~ -0 --;..... -~ r'<) C~~} JENNIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM F. OWEN. Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TERM 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 9 3301(d) of the Divorce Code. 2. Date and manner of service of the Amended Complaint: October 13,2006, was served on Defendant by Certified Mail and the green card was signed on October 17. 2006 (attached hereto as Proof of Service A). 3. Related claims pending: 4. (1) Date of execution of the Plaintiff's Affidavit required by 93301 (d) of the Divorce Code: October 17,2006; (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: October 16, 2006. 5. Date and manner of service of the Notice ofIntention to file Praecipe to transmit record: Served on October 17,2006, by certified mail, green card. (Attached as Proof of Service I a& b) ~ Date: November 7, 2006 . Tome, Esquire 155 South Han ver Street Carlisle, P A 17013 (717) 241-6070 Supreme Court 10 No. 200198 c> (;. r-:> g 0" ~ 'i " \ --l ~ ~ '-- .-" ri1e :?;\:? ~i,~; -, ...-,.. ~ -D _,i'# ~~ 1" 0:) , JE~'NIFER L. OWEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. WILLIAM F. OWEN, Defendant CIVIL ACTION - LAW NO. 06-2513 CIVIL TER1\1 IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ~ I do not oppose the entry of a divorce decree. (b) I oppose the entry ofa divorce decree because: Check (i), (ii) or both): . The parties to this action have not lived separate and apart for a period of at least two years. @ The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. @ I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g 4904 relating to unsworn falsification to authorities. Date: n I, 166 I I -L~g~ William F. Owen, Defendant r--.) = = 0'"' -"':"" 23 ....c w ~ ::::1 ftl~.- ;-n ~t-l .u~ (':\0 :.! ~.-r ~ .-:. -T"' ._-~; ~-f; '~ ::0 ~ r;? Cl (;1 :Ii;!; :Ii :+i ;!; :Ii '" :Ii :+i'" :+i '" "'''':+i :+i :Ii:li;t;:+i;t;:+i:+i :+i:+i:+i:f.;t;:+i;!;;t; ;t;;t;;t;:+i;t;:+i IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF .lenn; f~r T. nW"~n Plaintiff VERSUS William F. Owen Defendant AND NOW, PENNA. No. 06-2513 DECREE IN DIVORCE ~.. 1'1 ,2fnJ(' ,IT IS ORDERED AND DECREED THAT Jennifer L. Owen , PLAI NTI FF, AND William F. Owen , 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; None. :+i:f.:f.:f. :+i :+i:f.:f.:f.:f.:f.:+i:f. :f. :+i:f.:f. :f. :f.:f.:f. PROTHONOTARY :f.,.,:+i:f.:f.:f.:f. :+i :f.:f.:f.:+i:f.:+i:+i:f.:+i:+i:+i:f.:+i:+i:+i:+i:+i:+i:f.:+i :f. J. -,W:l~~ ~yp-~~n c.',.... :.~ ?()* le')( 1j(J" Ie .)/