Loading...
HomeMy WebLinkAbout06-3747 . ... In the Court of Common Pleas of Cumberland County, Pennsylvania MICHAEL A. MURPHY, ) Plaintiff, ) (/(p~ 3/~7 "- vs. ) No. Cu.ri0 ) LAURIE L. MURPHY, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE TO DEFEND AND CLAIM 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 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: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 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 LA WYER 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. Lawyer Referral Service Cumberland County Bar Association :1 LiBYI't?: ^"'lR'l'l ~2- 5. Brdton1 5/. Carlisle, P A 17013 (717) 249-3166 . In the Court of Common Pleas of Cumberland County, Pennsylvania MICHAEL A. MURPHY, ) Plaintiff, ) Of,- 37'17 ~-r,,--- vs. ) No. ) LAURIE L. MURPHY, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days ofthe date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. . Michael S. Travis Attorney at Law ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9509 In the Court of Common Pleas of Cumberland County, Pennsylvania MICHAEL A. MURPHY, ) Plaintiff, ) 0(,' 31'f7 ~ ""-.L-- vs. ) No. ) LAURIE L. MURPHY, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by his attorney, Michael S. Travis, respectfully represents: I. Plaintiff is Michael A. Murphy, who resides at 1323 English Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since May, 2006. 2. Defendant is Laurie 1. Murphy, who resides at 15 Wadsworth Drive, East Berlin, Adams County, Pennsylvania, 17316, since May, 2006. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 7, 1997, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 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. Neither party is in the Military Service in the United States. 10. Plaintiff requests the court to enter a decree of divorce. VERIFICATION 1 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. g 4904, relating to unsworn falsification to authorities. Date: b In I (}/,p , , H~a. H""~~ Michael A. Murphy, P tiff e . raV1S Attorney for Plaintiff LD. # 77399 3904 Trind1e Road Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 ~R~ ~ 'J ~ 01 \,,),.J ~ ~ ~ ~ () ~ C) -';1 (~_ '4 ( ~ ' f'j"lF (.) --:'-: ~~q o 7'.,., C) "" -.1 ]~.5~ In the Court of Common Pleas of Cumberland County, Pennsylvania MICHAEL A. MURPHY ) Plaintiff, ) vs. ) 06-3747 ) LAURIE L. MURPHY, ) CIVIL TERM Defendant. ) IN DIVORCE ACCEPTANCE OF SERVICE I accept service ofthe Complaint. Date: <oil lo~ ~c1.~ Laurie 1. Murphy address: \':J w~ t:vI &.M ~ .'P~ n'Sllp 0..) f'-.~ c In the Court of Common Pleas of Cumberland County, MICHAEL A. MURPHY, Plaintiff, ) ) ) ) ) ) No. 2006-3747 vs. LAURIE L. MURPHY, Defendant. CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant on July 10, 2006, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. ~- -/~s. Travis 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 falsification to authorities cr, J I-,O~ 1. ArtICllI AdeJI_l I.Ho: C(U.Lr,' eLm ~r phy lS wo.dswor-}h Dr\ ue. Eo-st 6er\;(l, fA 1,?;J{, 2. ArtIcle Number (TnInsfer from SBfVIce IebeI) PS Form 3811, February 2004 o c: <"" "'0 tD O)Lli ~t.~,"1 ~:)' ~ <<. ~,...C '. .<-.C' );"c' Z ::2 . So 8IrvIcle ~ ~ CdIed MIll C ElcpnlIa MIIII C RegiIlIeIlKI C Return ReceIpt for MerchandllIe C Insured Mall C C.O.D. 4. FIeetItcted DeIlYery? (Extra Fee) IiJ-'fee 7005 1820 0007 7502 0651 00mIdc AIUn RecIIpt 102595-02-M-1540 f'.) <=> <:::::) C7' (.I) r1l -0 N ~ =E-n m- -oF;; Q6 ~:1J ,:,,:..JJ 'ott::o 6rn :-"-I ~ :J::llo :x a w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA LAURIE L. MURPHY, Defendant. ) ) ) ) ) ) No. 2006-3747 CIVIL TERM IN DIVORCE MICHAEL A. MURPHY, Plaintiff, VS. AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on June 30, 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. DATED: Cf//3/()~ f!teV t1. H1~V Michael A. Murphy, Plaintiff " o c: "'Os: mq: _;,[.1.. Z~-,.iL..' ,- -_I 0) ,'- ~"'-... :<,C. :b~ __ -'7' ( is:::'C; -~ c- ?i ,...., = <:::;) 0"\ C/) fT! -0 l'\,) ~ ~:o mr:n ~6 --i-r, T,., C)-- e5~ -I ~ "'< J;IIo ::x 9 w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURIE L. MURPHY, Defendant. ) ) ) ) ) ) No. 2006-3747 CIVIL TERM IN DIVORCE MICHAEL A. MURPHY, Plaintiff, vs. WAIVER OF NOTICE OF INTENTION TO REOUEST 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! 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: 11/ 3/ ()~ Mic.:.L~{t!lfrtItfy g ;g; -0 \J.~ 'l1,\ ':i. '.' ~~;: ~\-. 'Zc. ~-u YC: 3 ~ ~ ~ '"'0 "" - ~ ~:l1 --oh1 ~ot? b\o .:::.. ...., _J....-I> r')-- 'z~ 9 ~ ~ <2 e,..) - ~r~"r~n"'I"'':'l[OJ o r:(l:o-::i d,; :\'1:: 'J! 0 . L1.j.;)OI~fLJ~'. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURIE L. MURPHY, Defendant. ) ) ) ) ) ) No. 2006-3747 CIVIL TERM IN DIVORCE MICHAEL A. MURPHY, Plaintiff, VS. AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on June 30, 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. DATED: 9\\~lolo g -?" > -0 OJ rnt" '?"'j;.' '~r PJ:;;;' ~F-. t4-- ~%.t::, ':Pc -? 2 ~ ~ ~ '""P \ 'N ~ ~:Q .,.-o~ -:0 _ (.::),c :c=\'.; (~~ 9 v:> ~ ~ C5 ." - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MICHAEL A. MURPHY, Plaintiff, ) ) ) ) ) ) No. 2006-3747 CIVIL TERM IN DIVORCE vs. LAURIE L. MURPHY, Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST 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! 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:~ 1 \ <( 1 0'" () r--.;) <:::) ~ c: <:::) -eElS c:Y' (I) :i! SP ~~r; /'T1 n1~ -0 zr N :B6 cr) ), ~i':" 0., ;,.-- -., ::;:If. .1>,-. :J:>> 7):D Z'.: ::::l1: '? (') );c_, 6 om c Z .. -I ~ W ~ Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, P A 17011 (717) 731-9502 LAURIE L. MURPHY, Defendant. In the Court of Common Pleas of Cumberland County, Pennsylvania ) ) ) ) ) ) No. 2006-3747 MICHAEL A. MURPHY, Plaintiff, vs. 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. Ground for divorce: irretrievable breakdown under ~ 3301(c)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Complaint was mailed June 30, 2006, via United States Certified Mail, restricted delivery, return receipt requested to Defendant, which was received by Defendant on July 10, 2006, Affidavit of service attached hereto. An Acceptance of Service was filed on July 12,2006. Defendant signed the incorrect date on the Acceptance of Service. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff on September 13, 2006; by Defendant on September 18, 2006. 4. Related claims pending: No economic claims were raised. 5. Date Plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: September 21, 2006. .... e was filed with the Date Defendant's Waiver of Notice in ~ 3301(c) prothonotary: September 21, 2006. ,/ ~ ~ (/) ~ N a c. -"~ .0.;:..... -0 iJ.;. rn(~ -7 ,-, ~~~: 0.;;: r.:2.C %b 'J?C ~ ... - ~ ~::t1 hl :.By 0.6 ~~..,.., ~:u ,),...... ~~jO";:....4 6'" ~ ~ ~ '0 .' ~ - MICHAEL A. MURPHY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW LAURIE L. MURPHY, Defendant NO. 06-3747 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of October, 2006, upon consideration of the praecipe to transmit record filed on behalf of Plaintiff, and it appearing that the affidavits of consent were executed and filed less than 90 days after the filing and service of the complaint, a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiencies and file a new praecipe to transmit record. BY THE COURT, 1iJ~ J. esley Oler, ., :rc o C' ."1 ,.r , ,...' (, <I (,.'.; (] II IJO soaz 3111 :10 j:);)~'=:--{Bl!:l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MICHAEL A. MURPHY, Plaintiff, ) ) ) ) ) ) No. 2006-3747 CIVIL TERM IN DIVORCE VS. LAURIE L. MURPHY, Defendant. AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 330l(c) of the Divorce Code was filed on June 30, 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. DATED: III 12~ /t'v I . 'w;l,/ a Michael A. Murphy, Plainti re'Mtill (") C ? ~iV: ....< '" = = 0-- a n o -Tl :.? ~,., m;= 1'1lTi :tJy :=:1c) ___.....1 --rl ,:~ ;~. :ri :,,;, c) ;"'~,rn >==1 ~ -< -1 (..) " N C) \.0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MICHAEL A. MURPHY, Plaintiff, ) ) ) ) ) ) No. 2006-3747 CIVIL TERM IN DIVORCE vs. LAURIE L. MURPHY, Defendant. AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on June 30, 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. DATED: \o\~olo~ ~~ ;to ~ Laurie L. Murphy, Defend t o ~ ,...." = = 0'" <:::) C) -I ,'::) "T1 :::J R1:D TJ Fn '!lC' ;:":":\T..J ~~ --~ ..,.~ :n -< w -0 _'~;l". -:,... ~ C) u:> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MICHAEL A. MURPHY, Plaintiff, ) ) ) ) ) ) No. 2006-3747 vs. LAURIE L. MURPHY, Defendant. CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST 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: 10/20/ of; , I MiChaeaeelad<<+ 1~[ID r--:> = = Cl"> a ("') --I W o -n ::;:I" rTIr= ua:! =::<y "~~ .~~ ?O -< -0 :2;: N o \J) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA MICHAEL A. MURPHY, Plaintiff, ) ) ) ) ) ) No. 2006-3747 CIVIL TERM IN DIVORCE VS. LAURIE L. MURPHY, Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST 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! 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:~ ':'? a 1,0 "-.> <:::::> c:-;:; c:r. a C";;l -, o -n 5:! rf1 ::n r-- -'-1 f'11 ;!iy ::1C) 'r~ ....j'.; ;~~l~' :~ ::r", c ::.r:J "'"" w ~ Michael S. Travis ID No. 77399 3904 Toodle Road Camp Hill, PA 17011 (717) 731-9502 MICHAEL A. MURPHY, Plaintiff, In the Court of Common Pleas of Cumberland County, Pennsylvania ) ) ) ) ) ) No. 2006-3747 vs. LAURIE L. MURPHY, Defendant. 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: Code. 1. Ground for divorce: irretrievable breakdown under ~ 3301(c)(1) of the Divorce 2. Date and manner of service of the complaint: Complaint was mailed June 30, 2006, via United States Certified Mail, restricted delivery, return receipt requested to Defendant, which was received by Defendant on July 10, 2006, Affidavit of service attached hereto. An Acceptance of Service was filed on July 12,2006. Defendant signed the incorrect date on the Acceptance of Service. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff on October 20, 2006; by Defendant on October 30, 2006. 4. Related claims pending: No economic claims were raised. 5. Date Plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: October 31, 2006. Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: October 31, 2006. "-' = = c:.__ o n --l W o .,.., ~ m;:2 -ryft1 ~~ i'5n;1 $ :::0 -< - v ::!: N C) W ;4i;+; ;4i ;4i ;4i ;4i ;4i <t; ;4i ;4i;4i <t;;4i;4i <t; ;4i ;4i;4i ;4i IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF MICHAEL A. MURPHY, Plaintiff, VERSUS LAURIE L. MURPHY, Defendant . PENNA. No. 2006-3747 DECREE IN DIVORCE AND NOW, (\j 0 v C--v1la t' ) ~ 2.006 IT IS ORDERED AND DECREED THAT Michael A. Murphy AND Laurie L. Murphy , PLAI NTI FF, :+; :+; :+; :+; :+; :+; :+; ;to :+; :+; :+; :+; J. , 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. ;4i;4i~~;4i:+;~:+; ;4i ;4i !f. :+; !f.;4i!f.!f.;+;;4i ;+; Td9J PROTHONOTARY !f.:+;!f. ;+;!f.!f. !f.~!f. ~ !f. !f.;4i:+;!f.!f.~!f.!f.;4i;4i!f.!f.:+;;4i:+;:+;;4i;4i;4i;4i<t;:+;!f.!f. -~2~7~ ?r7-1-;; ~ ~ fl ~46"" -/'P <?tl. 1-// ~, t_'II' ";. .. 1.'-'