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Home My WebLink About06-3148 ABRAHAM LAW OFFICES 2157 Market Street Cam Hill PA 170 1 (717) 763-1700 v. : IN THE COURT OF OMMON PLEAS : CUMBERLAND CO TY, PENNSYLVANIA ev.L T ~""l JAMES T. JONES, II Plaintiff AMY R. JONES Defendant : CIVIL ACTION - : DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish t set forth in the following pages, you must take prompt action. You do so, the case may proceed without you and a decree in divorce or against you by the Court. A judgment may also be entered against yo relief requested in these papers by the Plaintiff. You may lose money important to you, including custody or visitation of your children. defend against the claims warned that if you fail to ulment may be entered for any other claim or r property or other rights When the ground for the divorce is indignities or irretri vable breakdown of the marriage, you may request marriage counseling. A list of marriage co lors is available in the Office of Court Administrator, 4th Floor, Cumberland County Courtho se, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, IVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVO CE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY 0 THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LA YER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 0 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU AN GET LEGAL HELP: Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (71 7) 240-6200 JAMES T. JONES, II Plaintiff v. : IN THE COURT OF OMMON PLEAS : CUMBERLAND CO TY, PENNSYLVANIA : NO, 010-.31 P C;C>IL '-rE:R.J; : CIVIL ACTION - L W : DIVORCE AMY R. JONES Defendant COMPLAINT AND NOW, comes Plaintiff, James T, Jones, II, by an through his attorney, James W. Abraham, Esquire, Abraham Law Offices, Camp Hill, Penn ylvania, 17011, and files the following: COUNT I - DIVORCE (Pursuant to 23 Pa.C.S.A. Section 3301(c)) I, Plaintiff, James T, Jones, II, is an adult individual who c ntly resides at 99 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant, Amy R. Jones, is an adult individual who curre tly resides at 3570 Ruffed Grouse Drive, Dover, Pennsylvania, 17315. 3. Plaintiff and Defendant have been bona fide residents ofth Commonwealth of 4, Plaintiff and Defendant were married on July 4, 1997 in N rt, Pennsylvania. Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 5. There have been no prior actions of divorce or for annulme t between the parties, 6. The maniage is i1Tetrievably broken. 7, Plaintiff has been advised that counseling is available and at Plaintiff may have the right to request that the Court require the parties to participate in coun eling. 8, Plaintiff and Defendant are not members of the Armed Fo es of the United States. WHEREFORE, Plaintiff requests Your Honorable Co to enter a decree in divorce dissolving the maniage. COUNT II - DIVORCE (Pursuant to 23 Pa.C.SA Section 3301(d) 9, Paragraphs I through 8 are incorporated herein by referenc . 10, Plaintiff and Defendant have continued to live separate an apart for a period of at least two (2) years as the parties separated on or before May 31, 2004. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter a decree in divorce dissolving the maniage. James W. Abraham, Esq, Abraham Law Offices 2157 Market St. Camp Hill, P A 170 II (717) 763-1700 Attorney for Plaintiff, James T, Jones, II DATE: 6/2/06 I JA-UlIZS , VERIFICATION T JDJ1tS. ..II . verify and confIrm that the foregoing document and the statements , e undersigned, hereby e therein are true and correct to the best of my knowledge, information and belief. I furthe understand that any false statements made herein are subject to the penalties ofl8 Pa.C.S.A. S tion 4904 relating to unsworn falsification to authorities. DATE: ~-;;(4 - ()~ ~ l' I CERTIFICATE OF SERVICE I, James W, Abraham, Esquire, the undersigned, hereb certify that I have served a true and correct copy of the foregoing document, by certified mail, pon the following person at the following address on the date stated herein: Amy R. Jones 3570 Ruffed Grouse Drive Dover, PA 17315 DATE: 612/06 James W. Ab , Esquire ~ (::) ~ (") ';?5 Q, ~ c co ..() ~ cr- , -' ~ 0 'J_' 'e ';l:-r1 l~;~ \,; ;.&. K'i": C9 \ 3~Q 6"- N ~)t) 6"- -- >"}~, 6"- z . \~- -("; --< .r- D ~ ..;;:.. .,0 'b - c)rT' (j' (~~ - :-.;:-\ " ~ c:~ <:) 1- .-<. 0' ,: '~ ABRAHAM LAW OFFICES US7 Market St.Camo Hill. PA 17011 (717) 763-1700 JAMES T. JONES, II Plaintiff : IN THE COURT OF COM ON PLEAS : CUMBERLAND COUNT , PENNSYL VANIA : NO. O~-.3l'1; f./~LL<-r~ : CIVIL ACTION - LAW : DIVORCE AMY R. JONES Defendant NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affi vit, you must file a counteraffidavit, within twenty (20) days after this affidavit has been rved on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER S CTION 3301 d OF THE DIVORCE 0 E I. The parties to this action separated on or about May 31. 2 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, di sion of property, lawyer's 4. I verifY that the statements made in this affidavit are true d correct to the best of my ~ expenses if I do not claim them before a divorce is granted, knowledge, infonnation and belief. I understand that false statements erein are made subject to the penalties ofPaC.S.A. Section 4904 relating to unsworn falsificati to authorities. DATE: ~ - 1- 0 (P II ;f , " GPRTIFICATE OF ~~VICE I, James W. Abraham, Esquire, the undersigned, hereb certify that I have served a true and correct copy of the foregoing document, by certified mail, pan the following person at the following address on the date stated herein: Amy R. Jones 3570 Ruffed Grouse Drive Dover, PA 17315 DATE: 612106 o ,; L.' ,./ " . . r-.> = = Q.... <-- c:: -'I'" - ~ --< ::r.:-n r11F -om .1-JO (~), C~ '......,.-, -'1.:":-r'i S,~(') '.-m 9 ~ ~ 1 N ~,,.. :J;: C> 0:> JAMES T. JONES, II Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06 - 3148 CIVIL TERM AMY R. JONES Defendant : CIVIL ACTION - LA W : DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, as attorney for Plaintiff, James T. Jones, II, in the above-captioned action, hereby affirm that the Complaint in Divorce and Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code, both of which were filed herein on June 2, 2006, were served upon Defendant, Amy R. Jones, by certified mail on June 10, 2006, as verified by the green return receipt card from the US Post Office, which is attached below: SEND", "'-",, ,,,:,,, . 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 th to the back of the mallplece. or on t If space pennits. ~~<g~~ g~~ C. Date of Delivery " ReceMK:I,.!!l ( Printed Name) pr<.X.~ ~CtrO~\1'er'" D. Is delivery address d from If YES, enter del :eTYpe CertIfIecI Mall C RegIstered C Return ReceIpt for Merchandise o II1SUI'lld Mall C C.O.D. 4. RestrIcted Delivery? (Extra Fee) 0 Yes 'I 7006 0100 0003 4883 5007 PS Form 3811. Febru8ry 2004 DorMstIc "AMum ReceIpt 102Sl1&-02-M-1540 i DATE: 10/06/06 ~ James W. Abraham, Esquire I CT, (1) C) CD :< ", "~I'. ABRAHAM LAW OFFICES 2157 Market Street, Camp Hill, PA 17011 (717) 763-1700 JAMES T. JONES, III Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06 - 3148 CIVIL TERM AMY R. JONES Defendant : CIVIL ACTION - LA W : DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF SECTION 330Hd) DIVORCE DECREE You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after October 3,2006, the other party 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. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. 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 will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WI TH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 ("") c ~ c) g -n 0'" o c; -i 1 Cj\ -0 ::::: (:'5 :~5rn ':,:-\ '~t> ::0 ~ <:'? o .;;:- . "" JAMES T. JONES, III Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06 - 3148 CIVIL TERM AMY R. JONES Defendant : CIVIL ACTION - LA W : DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a 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 (2) 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 or property, lawyer's fees or expenses if! 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 understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. DATE: AMY R. JONES .. . ..,. CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, upon the following person at the following address on the date stated herein: Amy R. Jones 3570 Ruffed Grouse Drive Dover,PA 17315 DATE: 9/13/06 James W. Abraham, Esquire C) (::0:- r-..) ~:.J ~ er- a CJ -, I c.... \J :J~= ~-:) C::, .t::- o .1 --f -, r11 ;:: F3 C'.; :ii ~;~ :---) - . ~D .< .. JAMES T. JONES, II Plaintiff v. AMY R. JONES Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06 - 3148 CIVIL TERM : CIVIL ACTION - LA W : DIVORCE AFFIDA VIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, as attorney for Plaintiff, James T. Jones, II, in the above-captioned action, hereby affirm that the Notice oflntention To Request Entry of Section 3301(d) Divorce Decree, was served upon Defendant, Amy R. Jones, by certified mail on September 14, 2006, as verified by the green return receipt card from the US Post Office, which is attached below: . Complete Items 1, 2, and 3. Also complete Item 4 if R~~ Delivery Is desired. . Prlntyournaro~ and address on the reverse so that we'canrefurn the card to you. . Attac/1 this card to the back of the mailplece, or onthe.front If space pennits. 1. ArtICle~ to: ..,(JuJfi K, J(;J1~.5 :5 S7~ rCvffi~ G-tt.dllJ€ lJ PlJv~ fA '7~/S D. (s delivery address different from item 17 If YEs, enter dellve/}' address below: , ~ 3. Service Type ~ Mall C Express Mall or 0 Registered C Retum Receipt for Merchandise C Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) [J Yes 7003 1680 0001 9300 3775 PS Fonn 3811. February 2004 00me8tic Return Aecelpt ....'~fl'<- ~ (I/O L~-M-l540 i DATE: 10/06/06 James W. Abraham, Esquire 0 ~ ~ C:'l (:.r'" ~4"\ rt~~; \,-"..-1 , ~ 'LV 't "%13 ::l yc:: <.J ~ C .".- ~ ABRAHAM LA W OFFICES 2157 Market Street, Camp Hill, P A 17011 (717) 763-1700 JAMES T. JONES, II Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06 - 3148 CIVIL TERM AMY R. JONES Defendant : CIVIL ACTION - LA W : DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section ( ) 3301(c) (x) 3301(d)(I) of the Divorce Code. 2. Date and manner of service of the Complaint: June 10.2006; see attached Affidavit of Service. 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 on ; and by Defendant on (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: June 2. 2006. (2) Date of filing and service of plaintiff's affidavit upon the Defendant June 10. 2006; see attached Affidavit of Service. 4. Related claims pending: None. 5. Complete either paragraph (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: 9/14/06 by certified mail; see attached Affidavit of Service. (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: DA TE: 10/6/06 James W. Abraham, Esquire Abraham Law Offices 2157 Market St. Camp Hill, PA 17011 (717) 763-1700 Attorney for Plaintiff, James T. Jones, II (") c::: ...;::. r--.:> c:...":) = c;r. a n --1 I 01 -\"J c.) o <:n o 11 -; :J;Tl n'f'" i!1 c:) '~T"l r::; rn [Ii [Ii [Ii [Ii ;t;[Ii;t; ;t;;t;;t;;f.;f.;f.;f.;t; Ol' "''''''''''''' "'''' "'''''''''''''''''''''' "''''''' "';t;"'''';t;", ;t; '" '" ;t; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. James T. Jones, II No. 06 - 3148 VERSUS Amy R. Jones DECREE IN DIVORCE AND NOW, O~\ c ~e,( 2006 ,IT IS ORDERED AND \~ DECREED THAT James T. Jones, II , PLAI NTI FF, AND Amy R. Jones , 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; By THE COURT: J. PROTHONOTARY '" "'''' "''''''''''Ol' Ol''''''''''''' "''''''';t; ;t;"''''''' "'''''''''''''''' "'''' ;t';t''''Of.[Ii "''''''''''''' "'Of. _~7~~ tW~6/-'(J./ ~ pPr"" 4 ~ ~t?61-o/ ~ ~ . ...... . ' , . - .' .