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Home My WebLink About06-3597 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01.. -.3[;97 COlLe l~ : IN DIVORCE TERRI A. PARSON, Plaintiff JAMES D. PARSON, Defendant NOTICE To: .lames D. Parson 302 North 30th Street Harrisburg, P A 17111 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 BAR ASSOCIA nON 2 LIBERTY A VENUE CARLISLE, P A 17013 (717) 249-3166 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 AVENUE CARLISLE. PA 17013 (717) 249-3166 TERRI A. PARSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. ; NO. 01- - .3597 c,C,)~l [-~~ .lAMES D. PARSON, Defendant : IN DIVORCE COMPLAINT IN DIVORCE I. The Plaintiff is Terri A. Parson, an adult individual residing at 307 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is .lames D. Parson, an adult individual residing at 302 North 30th Street. Harrisburg. Dauphin County, Pennsylvania 17] ] ]. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 23. ] 987 in Camp Hill, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers and Sailors Act ofthe Congress of] 940 and its amendments. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. 9. There were no children born of the marriage. 10. The parties have lived separate and apart since November 2005. II. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant. NESTICO, DRUBY & HILDABRAND. LLP BY:~~~"?~#-~-'~. 0 ~rl R. Hildabrand, Esquire Attorney I.D. No. 30102 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 Attorney for Plaintiff Date: G. ~ 2-- \ laCe, ~ . ' , ' VERIFICATION I. Terri A. Parson. verify that the statements made in the foregoing document 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 of 18 Pa, C ,So *4904 relating to unsworn falsification to authorities, Date: ~II 0 Co ~a'-fJ~ Terri A. Parson p lQ. ~ - ~ ..0 \) . - \ '" 4- V'\ 0 -.0 .0 -0 Vl ~ ).) ?- -C: :e -r- . . n ('. r-.,) ~:,:~~ c,' \, C-_ c.~ r'''\ (.J.) () -n .-.:\ fh pi. C". C.- , - ~,.~ ; .-~) ~.-\ --..1, ~;' r<) t-,"~ g ~_:1 r , TERRI A. PARSON, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES D. PARSON, Defendant NO. 2006-03597 IN DIVORCE AFFIDAVIT OF SERVICE I, Karl R. Hildabrand, Esquire, counsel for Plaintiff, hereby certify that a true and correct copy of the Complaint in Divorce was served upon Defendant James D. Parson, at 302 North 30th Street, Harrisburg, Pennsylvania 17111, by Certified Mail Return Receipt Requested on July 5, 2006. Attached hereto, marked as Exhibit A and incorporated herein by reference is the original signed receipt card for said service. NESTICO, DRUBY & HILDABRAND, LLP ~~ Date: 21' I 0 ~ Karl R. Hildabrand, Esquire Attorney J.D. No. 30102 840 East Chocolate A venue Hershey, P A 17033 (717) 533-5406 Attorney for Plaintiff By: - .. ,,' ...... fLU ~ 0Ct/lX-J u P:i (SlY) cod.- IV 3f)+h S-t .,HQ(V1~bJ0 0\ 17/11 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desil'9d. · 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 mailpiece, or on the front if space permits. 1. Article AdcII888ed to: . t:.;,.~. , .., 3....~1Ype ':.kf CertIfIed Mall 0 Expr8sa Mall o Regiatered ~ ReceIpt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (ExtnJ Fee) 0 y" 2., ArtIcle N\ID1ber (T/'ansfer from 99fVice label) PS Form 3811, February 2004 7003 2260 0005 6584 9571 Domeatic ReUn ReceIpt 102595-02-M-1540 ! .. ... (....., .- .. ... :.:"~ ~ " ::::J j .; ~-J v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-03597 TERRI A. PARSON, Plaintiff JAMES D. PARSON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 23, 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 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. J 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//;).'5" loro ( , ~a.'~~ Terri A. Parson, Plaintiff o ~:;c ..-...:l = = 0:;;;"' o f1\ CJ ~ ~1-n n- \, ~D rr~ .~t.1C.... ~:1~ ~.~~~ ~~ JE =< w -n -,.,. _:';~ N .. TERRI A. PARSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-03597 JAMES D. PARSON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6 3301(e) OF THE DIVORCE CODE I. 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: J 'I d. '5 / (j &, ~a'f~~ Terri A. Parson, Plaintiff ~ ~ c;r" <:? - <P ~ ,;? --0 f\"\ ~, ~%~~) ?:?.. ~~ ~~~\'\ . "';:"A ;0. '.:4 ~ - - TERRI A. PARSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-03597 JAMES D. PARSON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301 ( c) of the Divorce Code was filed on June 23, 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 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:3&/W06 , ~ c:::> c.r" C) jfl CJ ~ .-1 :k-n rnF -'::11-;1 "'~JC( ; ',~.. ~,.J\~i .-t-t.- _ 9" ~ ~ N .' - TERRI A. PARSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-03597 JAMES D. PARSON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6 3301(c) OF THE DIVORCE CODE I. 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: 3tJ4p~ fi~ndant- ,......:l c::::> c::;:::> Cl"" c:J r.'j c-' v) ~ ~ :r:.-n rnp:: -T10J. :~~.~, ;;~;~ \..- <~ -rJ :;,~,~ t') ., - ..... TERRI A. PARSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-03597 JAMES D. PARSON, Defendant 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 *3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified Mail, Return Receipt Requested on July 5, 2006. Affidavit of Service was filed July 11, 2006. 3. Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code: By Plaintiff November 25, 2006; by Defendant November 30.2006. 4. Related Claims pending: None. 5. Date Plaintiff's Waiver of Notice In ~330](c) Divorce was filed with the Prothonotary: Contemporaneously with the filing of this Praecipe. .... Date Defendant's Waiver of Notice in ~330](c) Divorce was filed with the Prothonotary: Contemporaneously with the filing of this Praecipe. Respectfully submitted, NESTICO, DRUBY & HILDABRAND, LLP By: l ~ / <:----,,/ d' r;-/'AA 6 ~ ~~~ C?<:4- ~'F Karl R. Hildabrand, Esquire Attorney J.D. No. 30102 840 East Chocolate Avenue Hershey, Pennsylvania 17003 (717) 533-5406 (717) 533-5717 Date: (:;z -/ ! -o~ ,.-..) r-::;?- ~-~ ::) cr~ '. Q r:J c-; o "Tl -\ ~IJ \-il~ . ~-~ C__i co -.J r:~? CJ ,"0 ..:.\ t-r --...... :"'jJ ~ ;t;'" ~ ~ ~ ~~~~ ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ ~ ~ TERRI A. PARSON PENNA. STATE OF No. 2006-03597 ~ ~ VERSUS JAMES D. PARSON DECREE IN DIVORCE \, t) t.t. ~ W\ ~ t.f' , leO", IT IS ORDERED AND AND NOW, DECREED THAT Terri A. Parson , PLAI NTI FF, ;!; ~ ~ ;!; AND James D. Parson , DEFENDANT, ;!; ;!; ~ ~ ;!; ;Ii 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; ;!; ~ ;Ii ~ ;Ii ~ ;!; ;Ii ;!; ~ PROTHONOTARY ;Ii ~ ~ ~ ~ ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;!; ;!; ;!; ;f. ;f. ;f. ;f. ;f. By THE COURT: ~~;f. ;f. ~~ ~;f. ;!; ;+; ~;f. ~ ~ ;+;~;!; ;+; ~ ot'", ~ ~ ;f. ~ ~ ~ ~ ~ ;!; ~ ;f. ;f. ;f. ;f. ;f. ~ ;f. ;f. ;f. ;+; ;f. ;f. ;f. ;+; ;f. J. ;+; ;f. ;f. ;+; ;+; ;f. :f.'f; .~~ ~~Jh 1//'/e'e; ~ jz:v ,2~.y~ ~ 'JrJ./c-el " '-~" v. ..""..