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HomeMy WebLinkAbout06-3573 . v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW No. 06-.35 ";tJ CIVIL TERM IN DIVORCE SUSAN R. HENRY, Plaintiff WILLIAM S. HENRY, Defendant NOTICE TO DEFEND AND CLAIM OF 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 at: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 240-6195 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, FOURTH FLOOR CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 240-6200 . . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06- 3513 CIVIL TERM IN DIVORCE SUSAN R. HENRY, Plaintiff WILLIAM S. HENRY, Defendant COMPLAINT COUNT I - DIVORCE UNDER 3301(c) OF THE DIVORCE CODE AND NOW comes the Plaintiff and makes the following statement: 1. Plaintiff is SUSAN R. HENRY, who currently resides at 937 Forest Court, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is WILLIAM S. HENRY, who currently resides at 8 Hilltop Drive, Mt. Holly Springs, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 25, 1981 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 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. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, Divorcing Plaintiff and Defendant. .' v COUNT Il- DIVORCE UNDER 3301(d) OF THE DIVORCE CODE 8. The allegations in Paragraphs I through 7 are incorporated herein by reference and are made a part hereof. 9. Plaintiff and Defendant are now living separate and apart and have lived separate and apart since August 15,2003, a period which exceeds two (2) years. 10. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. 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. Dated: {p/~a )D~ 8d>>-Q TIFF , v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SUSAN R. HENRY, Plaintiff WILLIAM S. HENRY, Defendant No. 06- IN DIVORCE CIVIL TERM ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce as Defendant in the above-captioned matter and certify that I am authorized to do so. Date: n I'-'~ 0 c-:) (~-" c~'? ." Q.... c-::\ ~ '" , ,,\_-n ~ ~ ~ p1~ ",1 \.:~ \S N -. . t~ ~ -1:'1 - -.." - '" r.....1 ...s::, \ U1 --' ~ , . . ~ ~ ~ .. SUSAN R. HENRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERlAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW WILLIAM S. HENRY, Defendant No. 06- 3573 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT,W AIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE, AND WAIVER OF MARRIAGE COUNSEliNG 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. 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. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 7. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. .I' .. 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: lOJIOJDCe 82l>>-P' n f:: r-) C::-:-.J- c::::::') cj'...... o C'>, -'" o '- ;?, ,-0 '. .~. --, ~""-.1> C:;1 ~ 0\ 0J " SUSAN R. HENRY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW WILLIAM S. HENRY, Defendant No. 06- 3573 CML TERM IN DIVORCE AFFIDAVIT OF CONSENT,WANER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE, AND WANER OF MARRIAGE COUNSEUNG 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 22, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. 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. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 7. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. .. 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: Q:t , ci, 2rrh ~~~~ ;i~~i-------------------------1J----- o ~~~ ...~. - r--~ C=;;1 ~~~,} C)..... o ,~'), ___"-1 (.) -0 .-\ :r=.~ ~-ll, (.:::~ \~:-\ - o -.... ~) (_f\ V:' ~ . , SUSAN R. HENRY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA W WILLIAM S. HENRY, Defendant No. 06- IN DIVORCE CIVIL TERM ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce as Defendant in the above-captioned matter and certify that I am authorized to do so. Date: ~ /22 fOD ~~~ t--) c::;.1 ,---.. g~ :-1~ t~ I c.- '; -; G ~ ~...{J- . c"i 0.) Susan R. Henry, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION William S. Henry, Defendant NO. 06-3573 CIVIL TERM 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 93301 (c) 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: 6/22/06 by personal service 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff 10/10/06 ; by defendant 10/09/06 (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 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 of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: 10/10/06 Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: 10/10/06 ~'-A. o ~ r---:> = c..:~:) c.~ C) -n o r~-'" " " ........j o '2 C.) Q _.) ,..-! ~1'J -< '.~.~." ::.::.~~:. ':.::.::~::: >>>:~': )::+::( '. .::.:~::: )::.~{ )>>:~:': )::c.::: '::~::c.~: -:;.::.::.;:' ":.::+:.;> ::.::+:."" ..:+::.", ",;::C." :':.>>:-: '.::.::.' :-,.::+:.:: :,;::C." . ,.::.:.:'.,:~;::>::.-:.t":.::.~~'::'~::.::;'~:)::C~." :,,~::.:.;:,,~3~7,', ::-~::.::~;" ",.::.::!;::':~;~:e~~<:~~;~ ',,- '" ~ ~--- ~ y ~ -,."~ ~ I ~.~ ~..~ ~ ~.~ ~ ~.'" ~.~ ~ ;..~ ~ a ~.~ ~ .. ~,. ~ ~." ;.~ ~ >+, IN THE COURT OF COMMON PLEAS i~ ~ ~~~ ~ ,,+-,; ~ ~.~ ;.~ ~ ~.~ ~ ;.~ ~ ,.~ ~ ~~~ ~ ,.~ ~ ~.~ ~ ;.~ ~ ;.~ ~ ~.s * ~.~ ~ ',,+/ ,"~ ~ ~; i ~." ~.~ ~ ~ i ".~ ~ ~,.;:. ~ ~.~ ~.S ~ i ".~ ~ ~.~ a ~." ~ ~.~ ~ ... ~ ... ~ ".~ ~ '.' ~ '.' ~ '.' ~ '.' J. (~ I~ ~~ ~.~ ~ ~ ~.~ ~ ~ ~." ~.s ~ ~ ... OF CUMBERLAND COUNTY STATE OF PENNA. ~.~ ~ ~ ~ _ Prothonotary '.' I ~. .'. ~ 'f- ""'.___....,~ ~ ~ . ~.~ . ~~~~~~-~~,~-~~~~-)~ !:t.:( '::.>>:." >t>>:. '-.>>:. -.::.:....>>:.. -'.::.:-,,::.:.::.,,'.::.::.: ':.::.::.,:' '::':.::.:: -.::+::.'.::+~." - .::+::. _ - .::.::.,.~+::. .~+::. .:+::. .~+::. .:+::. ,.::.::. '-'.:.::. :.:.+::. .::+::.' ':.::+::.,".::.;. - .::.;. '.::"::." .::.::. _ -.::+::.' Susan R. Henry, N o. ,.....,~?~}~?~, ................. i ~.~ f.~' ,\ ~ ~.~ Plaintiff ~ ...~ i~ ~ Versus William S. Henry, Defendant ..t:: ~ ~l ~ ~i DECREE IN DIVORCE AND NOW, . . . . . Dk*.O.~~ . . . . .l.~7. . . . " l~!?~., it is ordered and I ~.~ ........ ) ~.~ ) ~ .,.. {.. ~.~ ~ i ~.jf ~.~ ~ decreed that.., .. ........ .S.u.s.a? ~'. !l.e?r.Y......................, plaintiff, and . . . . . . . . , . . . . . . . . . . . . . . . . . . ~~~~~~~. ~ ~ . I.I~~~:Y. . , . . . . . . . . . . ., 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; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , ~ir+~~7 . 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