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HomeMy WebLinkAbout06-3908 WAYNE F. SHADE Altorn~y at Law 53 West Pomfret Street Carlisle, Pennsylvania ]7013 NANCY J, WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. JEFFREY L. WHITE, Defendant : NO. 06- 3 c; 0 g CIVIL TERM : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been su~d in Court. If you wish to defend against the claims set forth in the following pages, you mm! 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 marriag(' counseling. A list of marriage counselors is available in the Office of the Prothonotary at 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 tV~~ Wayn . Shade, EsqUire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 170]3 NANCY J. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 06- 3 tlbY CIVIL TERM JEFFREY L. WHITE, Defendant : IN DIVORCE COMPLAINT 1. Plaintiff in this Action in Divorce is NANCY J. WHITE, an adult individual who resides at 905 Forge Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is JEFFREY L. WHITE, an adult individual and citizen of the United States of America whose last known address is 404 McIntosh Way, Chambersburg, Franklin County, Pennsylvania 17201. 3, Defendant has b'~en a bona fide resident of Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. Plaintiff and Defendant were lawfully joined in marriage on April 4, 1996, in Winchester, Virginia. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 2004. 5. The parties have been living separate and apart since on or about September 1, 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any 'Jther jurisdiction. concerns. America. 1996. 8. Both parties to this Action in Divorce are legally capable of managing their own 9. Defendant herein is not a member of the armed forces of the United States of 10, There was one child born to the parties, namely, Hunter Lynn White, born May 21, -2- WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 11. Plaintiff has no adequate means of support for the child. 12. 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 demands judgment dissolving the marriage between the parties. ~~c~ Wayne F, Shade, EsqUIre Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -3- . WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 I verify that the statements made in this pleading 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: July 7, 2006 .~~JW Nancy J. . G0~~ ~~~ ;r: ~- 0' ........... "6> ~ ~., c) .-::> -q c;., ...... .1: :.1 r"J c:..:: NANCY J. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v, : NO. 06-3908 CIVIL TERM JEFFREY L. WHITE, Defendant : IN DIVORCE PRAECIPE TO: Curtis R. Long, Prothonotary Please enter my acceptance of service of a true copy of the Complaint in the above-captioned matter. Date: July 25, 2006 JJi~ q :;;:; ~ , = C- c>" -l '?:: :po ::c." vt:C! c:: m- 1"llr;" '" hi ' . -06 ..."" N Xl ' ..~ .r::- 0;; ~;~ '- :::::!..,-. ~l:. -.:> Q::D -.0 . "', ~~~ :3: 6rn ~ ~ ~ <Jl -< WAYNE F, SHADE NANCY J. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO, 06-3908 CIVIL TERM JEFFREY L. WHITE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODE COMMONWEAL TH OF PENNSYL VANIA) ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under S3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on July 11,2006, and served on July 25, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and seryice 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 concern ing alimony, division of property, Attorney at Law S3 West Pornfret Street lawyer's fees or expenses if I do not claim them before a divorce is granted. Carlisle, Pennsylvania 170]3 _.~ WAYNE F, SHADE Attorney at Law 53 West Pomtret Street Carlisle, pennsylvania 17013 5. I understand that I will not be divorced umil 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 of my right to 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 that my spouse and I participate in counseling prior to a Divorce Decn::e's being handed down by the Court. 9. 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: November 14 , 2006 d~ "----" o 'i: ~ c;? cr'" o fT., c-; \ Cf" ~;:. ::2. c> -'{"I .-\ :1".-" pIe. _}?)ic,~ t~~, ~::.:~\ ~ ...-0 -- ~ - - (,)'\ .---- , " NANCY J. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 06-3908 CIVIL TERM JEFFREY L. WHITE, Defendant : IN DIVORCE AFFIDA VIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODE COMMONWEAL TH OF PENNSYLVANIA ) ) SS: COUNTY OF FRANKLIN ) 1. A Complaint in Divorce under ~3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on July 11,2006, and served on July 25, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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! 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 of my right to 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 maJTiage 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 that my spouse and I participate in counseling prior to a Divorce Decree's being handed down by the Court. 9. 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. 94904 relating to unsworn falsification to authorities. Date: November ~ C) ,2006 _(J// f~ Jef~te r-.:I = = """' CJ rq ('") I en o ." :'?Il lil --' r-- ;~~ -0 -....",.. ....to. ~):: (--) s:.2 r ;"'1 :n -< w. WAYNE F, SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 NANCY J. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO, 06-3908 CIVIL TERM JEFFREY L. WHITE, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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) of the Divorce Code. 2. The date and manner of service ofthe Complaint were July 25, 2006, by acceptance of service. 3. Date of execution of the Affidavit of Consent and Waiver of Notice ofIntention to Request Entry of a Divorce Decree under ~330 1 (c) of the Divorce Code by Plaintiff was November 14,2006, and by Defendant was November 20,2006. 4. Related claims pending: None. Date: December 4, 2006 waf,f~d~ Attorney for Plaintiff -----------. ~ ~ <:::r' o r"\"" c.., , Ci' -0 -:> ~ ..-\ :r.-n rnr': _~ h"" :0~; ~f(~ ~, ,n .~ -,~.. ~ - -- 0'\ ----------~ ~---- ~'liftifti;li:li:li:li:li :Ii :f.:Ii :Ii T. :Ii :Ii 'Ii T. T. T. 'f. 'f. T. 'f. :Ii :Ii :Ii :Ii T. T. T. T. :Ii :Ii 'f. :Ii T. :Ii :Ii :Ii 'f. 'f. fti ftiftifti:li fti :lifti:li:liT.T. :Ii 'f.:Ii :f. if. if.if. 'f. if. :Ii if.if.if. if. :Ii:li :Ii;li;li!li T.;liif.l+; fti if. if. if. if. ;Ii if. if. if. if. if. if. ;Ii if. if. if. if. if. ;Ii T. if. if. if. T. 'f. if. 'f. :Ii if. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. STATE OF NANCY J. WHITE, No. 06-3908 Civil Term Plaintiff VERSUS JEFFREY L. WHITE, Defendant DECREE IN DIVORCE AND NOW, ~/r or 0).'3 ~,M · , ~, IT IS ORDERED AND NANCY J. WHITE , PLAI NTI FF, DECREED THAT JEFFREY L. WHITE , DEFENDANT, AND 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 ATTES(:~ PROTHONOTARY 'f.!Ii:li;li;li;li;liif.:liif.;Ii :Ii:li:li :Ii:liT.'f.T.:Ii if. 'f. fti;li 'f.if.if. if.if.'f.if.'f.'f. J, _*;?~~ 4t?,}I-el ~ p f? ~ ,/"w -/'9 1fl' J;/- (:1 , " .. ,.."',....~.. , II ,"