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HomeMy WebLinkAbout06-3329 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA David Henry Price, v. Danielle Marie Price, Defendant CIVIL ACTION - LAW NO. 06 - 3 3 ~ 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 action within twenty (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 claim.ed 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. 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. 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 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. David Henry Price, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Danielle Marie Price, Defendant CIVIL ACTION - LAW NO. 06 - 33~ CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c..l OF THE DIVORCE CODE 1. Plaintiff is David Henry Price, an adult individual, who resides at 523 151 Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Danielle Marie Price, an adult individual, address unknown, employed at Wal-Mart Super Center 60 Noble Blvd, Carlisle, Cumberland County, Pennsylvania 17013. 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 October 11, 2004 in Cumberland County, Carlisle, 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. Respectfully submitted, ROMINGER & WHARE Date: ~/2-!o6 / I lie A. To eo, Esquire 155 South anover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court J.D. # 200198 Attorney for Plaintiff David Henry Price, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Danielle Marie Price, Defendant CIVIL ACTION - LAW NO. 06 - 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. ~4904, relating to unsworn falsification to authorities. Date: <:.. Cj . ~c::.~b b~ H~ .p~ David Henry Price, laintiff David Henry Price, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Danielle Marie Price, Defendant CIVIL ACTION.. LAW NO. 06 - CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff, do hereby certify that I this day mailed a copy of the Divorce Complaint upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: DanielIe Marie Price WaI-Mart Super Center 60 Noble Blvd. Carlisle, Pa 17013 Date: t fl./" I / Leslie A. Tome , Esquire 155 South Han ver Street Carlisle, PAl 70 13 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff 0 S~ ~ ~ ~ "- 'It ~ --t) c::> "- ...... ..j ~ ~ ..0 ,~ c::> " " ~ ~ '!'- , ...... - ~ 0 ) ~ f'\ " C>J e. .f' 1- ~ .. " r' '" "-~ ~ '-- ~-=. o ." ~'Tl m- r- :n8 ..; L -:CJ ''''j j,"'ri .~~O Orn '~ ~ -< N ..", _."", '''' w J AFFIDAVIT OF SERVICE ~- ~\it ~~'I& Commonwealth of Pennsylvania County of Cumberland Common Pleas Court Case Number: 06-3329 CIVIL TERM Plaintiff: David Henry Price vs. Defendant: Danielle Marie Price For: Leslie Tomeo Rominger & Whare Received by Pennsylvania Professional Process Svc. to be served on Danielle Marie PriceJ PLACE OF EMPLOYMENT: Walmart Super Center, 60 Noble Blvd., Carlisle PA 17013. 1./U./:tUAA1 A. A6e~~~ being duly sworn. depose and say that on the J q day of -:-rIJ Ai e , 20Q.(eat R:.3aPn.. executed service by delivering a true copy of the Notice; Complaint Under Section 3301(c) of the Divorce Code in accordance with state statutes in the manner marked below: ~DIVIDUAL SERVICE: Served the within-named person. k) SUBSTITUTE SERVICE: By serving as ( ) NON SERVICE: For the reason detailed in the Comments below. Military Status: ( ) Yes or ( ) No If yes, what branch? Marital Status: ( ) Married or ( ) Single Name of Spouse COMMENTS: Pf)~.Jl'yJl 'J:)~CR/Pr;AJJ.' +G-v\4-/~) ~J..l-rc.... J ,5': ~ ",J JdtJ cds &bt-1Al HIA~"R. I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. ~ and SWorn to before me on the tfikaay JI\..1 . dI!.ip. by the affi nt who is pers nally nown to me. (1/!!~~fu<~ Appointed in accordance with State Statutes COMMONWEAl.. TH OF PENNSYLVANIA Notarial Seal Tammie L. Peters, Notary Public South Middleton Twp., Cumberland County My Commission Expires Sept. 9, 2007 Member. PerlOsV"'1l 11'" . Pennsylvania Professional Process Svc. 48 W. High St. P.O. Box 1148 Carlisle, PA 17013 (800) 863.2341 Our Job Serial Number: 2006000185 . S, Inc. - Process Server's Toolbox V5.5i o ~ .:.c_ (_., C ."-;JIII ~:j -< f"-.) <=::) = CT' (/) PI -0 N ....J ~ =? - "'Ti Clip- --om :u9 (~~ (i; "L-n .c_) __ ''''M "51 :--\ ~ ;..<;: -0 :3]; w Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA David Henry Price, v. Danielle Marie Price, Defendant 8 g ~ <-. cr'" l:; tTi (/) -f Q . If r-rl :r: .." ~; ~:: u mr= .-,c:'l N "T1m g:!~ 0'1 ~g9 <' ~::i ,~: ~~ '~ -0 (5 :Il ;.-=:. r :Jl: "'7 (j 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was tn~ J~ 12~rn ~ w ~ N -< CIVIL ACTION - LA W NO. 06 - 3329 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 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. Date: 1 C SEfT o~ f::5~ HJ f~ David Henry Pri~laintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA David Henry Price, v. Danielle Marie Price, Defendant CIVIL ACTION - LAW NO. 06 - 3329 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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 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: ~ 0 S E.P i 0 b t5~ 1./ I p~ David Henry Price, P~iff g c::r ~ -0 2- -? ~~ -0(:..; c-r',n.. z.-e -/ /-. (j') =<.> (~\:e' >.--. ,.-"" ,,;.-'" ~- -/ ::3 --- N 0" -0 :z:;. ~ -' J:-n f1'~ -om 4:JY ';::),h ...~- ~:~ '-'-?'~ 0'" :=;..t ~ - v.) N Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA David Henry Price, v. Danielle Marie Price, Defendant CIVIL ACTION - LAW NO. 06 - 3329 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 12, 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. S 4904, relating to unsworn falsification to authorities. Date:j-c9l-0LQ J~e~!1Z~wdant () c -u~~ ~T~ r -~ -7' -:7 (r! = ~: r:' ~(~ -- C_ ):". c:: 3 -< ,....., = = C7' (/) \"<(1 -U N 0'\ o .." .-f :I:n f11, --om :"..PY ;:..~(!:> 6~ Zn1 9 'r> ~ -0 ::I': - .. W N Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA David Henry Price, v. Danielle Marie Price, Defendant CIVIL ACTION - LAW NO. 06 - 3329 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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 aftt:r it is filed with the Prothonotary. 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: (1- d I-O(g tU /!!~ , Danielle Marie Price, Defendant 2- ."" -s,.. -Q\:U ~~i~. .L ~ ;;;:. (~. ,.c..:: l' j--C -" .?, ::.2. ~ .g; (/) C6 rv Cj' -0 ::;It ~ :i--n Il'f':. --om -'0 t::? bh ~-.,. 7:~:0 ~7W. C5. .....\ ~ - .. vJ f') Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA David Henry Price, v. Danielle Marie Price, Defendant CIVIL ACTION - LAW NO. 06 - 3329 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 ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: June 12,2006, was served on Defendant by Affidavit of Service on June 19,2006 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by ~ 3301 (c) or The Divorce Code: by the Plaintiff, September 20, 2006; by the Defendant, September 21, 2006. 4. Related claims pending: None. 5. (b) Date Plaintiff's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: September 26, 2006 Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: September 26, 2006 Date: September 27,2006 Le i A. Tomeo, squire 155 South Hanove Street Carlisle, PAl 70 13 (717) 241-6070 Supreme Court ID No. 200198 N c::> = G:1" (/) r>\ -u N --I t_~, c: -;y ::-,4 -~ -n :i ~ :r-n rn f': -om ;1? C( '-), ( i _':-~.: :T:; (~o /- [-n S ij :...:::. - w ;+:T. "'''' '" '" if. '" '" '" "'''' "'''' '" '" Of if. "''''if. "'~"'Of "''''''''''Of~'''~ "'if. '" Of Of'" "'Of Of '" ~ '" '" '" ~'+O '" '" Of if. Of '" Of '" Of Of '" Of '" IN THE COURT OF COMMON PLEAS Of '" Of Of Of '" '" Of if. T. '" '" Of T. T. Of T. '" T. OF CUMBERLAND COUNTY PENNA. STATE OF David Henry Price Plaintiff No. 06-3329 VERSUS T. '" if. T. Danielle Marie Price Defendant DECREE IN DIVORCE AND NOW, O~7 ~/D.'''S,4~ · ~, IT IS ORDERED AND DECREED THAT David Henry Price , PLAI NTI FF, AND Danielle Marie Price , 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. - ,.j " PROTHONOTARY ATTEST: '" '" ~~~~~~~~~~~ ~~~~~~~~~~~~ ~~~ 'f."''f.'"'''if.Of''' "'''''''''' "'Of'" "'''''''''' '" "'''' "'''''''''''f. '" +. Of '" '" +. '" Of J. '" Of Of '" Of +. Of Of Of Of '" Of '" +. +. '" Of +. +. +. 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