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HomeMy WebLinkAbout06-4296 . , PAMELA PIERSON PERRAULT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW MICHEL PERRAULT, Defendant : NO. 01> - 4J..96 : IN DIVORCE Ciu;L '-r~ Nonr.F TO OFFFNn ANn r.T AIM RTr.HTS 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. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EUGmLE PERSONS AT A REDUCED FEE OR NO FEE. Cwnberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania (717)249-3166 /7/~ :r;/l'-~ , AnffiOhyi..-DeL~Esq~ 113 Front Street P,O. Box 358 Boiling Springs, P A 17007 . , PAMELA PIERSON PERRAULT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL Y ANIA YS. : CIVIL ACTION - LAW ; NO. at- - ^/;). 9/, C c.>L ~~ : IN DIVORCE MICHEL PERRAULT, Defendant COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is PAMELA PIERSON PERRAULT, who currently resides at 18 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania, since June 1,2005. 2. Defendant is MICHEL PERRAULT, who currently resides at 18 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania, since June 1,2005, 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 4, 2001 at Boiling Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties except None. . 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 of divorce. 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. ~&J~~~!Zt~IJOI~1h Pamela Pierson P ult, Plaintiff Date: * 1);iP a-4'~~ ~~9?~J6~ Anthony L. DeLu squire E. \ Attorney for Plaintiff Attorney's Number: 18067 113 Front Street P.O. Box 358 Boiling Springs, P A 17007 (717) 258-6844 ~ ~ AJ '- - ~ ..0 C) ~ . "- (j '\) - ~ ~ -u & p..: ~ ~ ,~,.' ~; ,-) . -~ 1 \"" u"\ ----4 ~~ ;~';~e~. ~ -";:) =, ::....: ,';.r1 _'.1 -- :......:.:: PAMELA PIERSON PERRAULT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CNIL ACTION - LAW MICHEL PERRAULT, Defendant : NO. 06-4296 Civil Term : IN DNORCE A FFIDA VTT OF M A IT JNG COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND Anthony L. DeLuca, attorney for Plaintiff, being duly sworn according to law, says that he mailed by certified mail, return receipt requested, a true and correct copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code to the Defendant at his residence and that Defendant did receive same, as evidenced by the signed receipt attached hereto as Exhibit "A". By: ~Yd~ ony L. D a, Esquire 113 Front Street P.O. Box 358 Boiling Springs, P A 17007 (717) 258-6844 Sworn to and subscribed before me this3f d:'day of~, 2006. 01u~~a'~R-X~ Notary PublIc ...... ... ~ADUCA MaIaIy NIle ~1WICtllllr ~cc::xHY __ ~~ lilT m....-.. 2007 \ 2. ArtIIIlIe__ mwtIIIeI'.... ~~,~ 7003 0500 0004 2325 5958 9P' ........, = = c;r.. o "11 .~ ftj:n I ,:gt-~l '~:: ~;:j z C) ~r;: ~ ~ 1_- _:'j ~5~ ~ ~r:J -< L"") ..c- -.l *"'R W""101>1 I. ')~I,JJO .. ~::i.t"'.' ..lilkfJ.CI..~}k~l .. ,;(~~ ~).JM~fflIOie . ,:; "oIOlt ~-1 'l\~):) 'fM PAMELA PIERSON PERRAULT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CNn.. ACTION - LA W MICHEL PERRAULT, Defendant : NO. 06-4296 Civil Term : IN DNORCE A FFmA VTT OF ~ONSRNT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 27,2006. 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. S 4904 relating to unsworn falsification to authorities. Date: JtJ/3()/t)~ ~~~ Pamela Pierson Perrault, Plaintiff r--..) = = 0"' -... (::; ~:.- ::P" :z o -n .-\ ::J:...,., n1r=: -rn:s :~~ ~~) :-;::M ;..~ :::::; ;F.o ~ <2 ..r -J PAMELA PIERSON PERRAULT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA YS. : CNIL ACTION - LAW MICHEL PERRAULT, Defendant : NO. 06-4296 Civil Term : IN DNORCE AFFIDA VTT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 27,2006. 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 ofthe 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. g 4904 relating to unsworn falsification to authorities. Date: 10/;$0/oC; I ~~~ IC eT errault, De ant ~ c:> i:;;;:> 0" :i~ c:;, ";:"'- \ - () 4"\ .-\ ::t:-n n'\ 'f" -~~~~\ ~~ ~">> ~ ~-:: ,'.:.,......-..;. ~~~A ':EO ~z ,:~ -1 PAMELA PIERSON PERRAULT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW MICHEL PERRAULT, Defendant : NO. 06-4296 Civil Term : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 9 3301(c) AND 9 3301(d) 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. S 4904 relating to unsworn falsification to authorities. Date: IO/.EO/Ow ()~-~ Pamela Pierson Perrault, Plaintiff Q 5.,;; ~. r~.;) ,...-, C3 0-" j~~~ ;s ~ CP PAMELA PIERSON PERRAULT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW MICHEL PERRAULT, Defendant : NO. 06-4296 Civil Term : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 3301(c) AND S 3301(d) 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. 9 4904 relating to unsworn falsification to authorities. Date: IcJ /~O /()~ , I { ~~ ~J1z - .- Michel Perrault, Defenaant 0 f'-,' ~ = c => ..:. ~V' ~:::.::r"'- Z :;:i c..~ i'Tlp2 < m t''': c:-\ , b1:21 _.~ C) ~ ;;;;;; rn 0 ' , ~O;;! -- ::0 CO '"'" fJ,If Iv:e>( d !fr'" f1 S'c:J A) Ie /It!' a c.> / of: I It d"AJ'f-r FF VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION 11 ( c ~ f'1 Ie ('{Hc.J (y NO. () b - f(;,p ~ 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) -63tl1 (d)(1) 6f the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: vufy J~ <tr>o' LlI4 C("'"r+rNr-rI /f all /f)'PY-<J/ltV Ift:ycL-l;?Y tlf=>g( I"'(C Y-r pp / t' UP"., 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 {) ~ Irt- r J 0 Z 0" , ; by defendant (Bet{ ~ ~ t'" /I :J 0 2 OJ de ( r (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: /VOIVIF' 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: /V ~ ()ejff~ reo" (/ 2(!)t!:) , Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: /VeVe-u6,-;r ;;, p(f'(!)O~ ~~)tCey~a;n~~~~ ~ ~ c;.:::l> ct"' :5~ ~ ~ ::?-n r;;~ '~ll!- -i\ L../ ;;-') !:-'; "::;1 ::.:t.: ':~; ~;\ ':::::..t ~ :..<. - ",;;? :r; -- - o o if. if. [Ii [Ii if. [Ii [Ii [Ii if. [Ii [Ii if.if. if. [Ii [liif. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. PAMELA PIERSON PERRAULT, Plaintiff No. 06-4296 Civil VERSUS MICHEL PERRAULT, Defendant AND NOW, DECREE IN DIVORCE ~ vveh 1 IT IS ORDERED AND 2006 , DECREED THAT PAMELA PIERSON PERRAULT, , PLAINTIFF, AND MICHEL PERRAULT , 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 PROTHONOTARY //,,- [Ii '" '" '" '" '" "''''''' '" "'''' "'''' "'''''''''''''''' '" "'''' "''''''''''''' "'''' "'''' "'''''''if. '" J. .~ ~ ~ ~ ?rl-1-j/ ~ fr#-~~/"O 5f2'- '7.// . .. . .. ". '.