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HomeMy WebLinkAbout06-4705 . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW F--r::. NO. Ot. -I.I/(O~ (!;UL"L /~....., IN DIVORCE DEENA K. DAVIS, Plaintiff JEFFREY L. DAVIS, Defendant NOTICE TO DEFEND 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 26 West High Street Carlisle,PA Carol J. Lindsay Es Attorney Id. 446 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY ............r5orAT.lAW SAIDIS, FLOWER & UNDSAY .......--.""""'.......' 26 West High Street Carlisle, PA II " DEENA K. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ~ NO. ot.- mos C;uLL I~ IN DIVORCE v. JEFFREY L. DAVIS, Defendant COMPLAINT IN DIVORCE UNDER SECTION 33011c\ or ld\ OF THE DIVORCE CODE 1. The Plaintiff is Deena K. Davis, an adult individual residing at 4165 Carlisle Road, Gardners, Cumberland County, Pennsylvania. 2. The Defendant is Jeffrey L. Davis, an adult individual residing at 4165 Carlisle Road, Gardners, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 26, 2000 in Gardners, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he/she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. SAIDlS, FLOWER &. UNDSAY ..,..----............... 26 West High Street Carlisle,PA WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with ~3301 of the Pennsylvania Divorce Code. Respectfully submitted, Date!!: 8 / /'-1 I (J)J Carol J. Linds Attorney Id. 26 West Hig treet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff "." SAIDIS, FLOWER &. UNDSAY AI ,,__. n">IAW 26 West High Street Ca.rlisle,PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~904, relating to unsworn falsifications to authorities. J~ l flcuW Deena K. Davis . Date: ?I-15 -of., ~\ - ~ )..) 'i' }.) ~~ ~ - ...0 \) . 8- ~ ~ -.:...... g .".. -00:' fD.f\ Z").' ;Z;C" (J) .,. ...;' ~.. < " r;:() ~~() ~__::- \.. J YC: ~ ~ c") ~ "fI ~ ~:n ;\\~ cp. 9- '" ~ c:P SAIDIS, FLOWER &. LINDSAY lU.u.o_.""""'.....w 26 West High Street Carlisle,PA II DEENA K. DAVIS. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4705 CIVIL TERM v. JEFFREY L. DAVIS, Defendant IN DIVORCE ACCEPTANCEOFSER~CE I, Jeffrey L. Davis, accept service of the Complaint in Divorce in the above-captioned matter. 8J!s!o(P Date r ~ 'S.., -on' f"nrr ';:';;>. . ~::' r;:. \.~ - '- 1="1~::.' .;;. c:: ~ ~ "'" """' ~ G') N ~ ~a; :BQ - b.b f:t~ ~ ~~ - 9 .;;. ~ c:J DEENA K. DAVIS, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-4705 CIVIL TERM JEFFREY L. DAVIS, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on August 16, 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 in 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 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.S. 4904 relating to unsworn falsification to authorities. /" Date:/J-c11-0I. j~l(.-( ,;/L~~ Deena K. Davis PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERI3301 eel 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.CoS. 4904 relating to unsworn/aISlf~cation to. authOritier; J Date: lie)' J - 0 (, ~dL;( ,Ji,/Jt/-6J Deena K. Davis r-.) c:'::'> = C0 -- 2:3. -;:.- \'.) ...,.., , . -".",- -,"'" c) N co SAIDIS, ROWER & LINDSAY A:rIOIlNEfSoAT.IAW 26 West High Street Carlisle, PA DEENA K. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4705 CIVIL TERM v. JEFFREY L. DAVIS, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed on August 16, 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 in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of18 Pa.C.S. 4904 relating to unsworn falsification to ~uthorities. ( Date: 4?k -Nt J ( ~)<-> I / r. . Davis DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER~ 3301 (cl 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the Dare: //1& penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorif J MOV ,., 2006 C) -'-n P,) -J ::2 0.) o SAIDIS, HOWER & LINDSAY AT\O\lNE'I'SoAHAW 26 West High Street Carlisle, P A DEENA K. DAVIS, Plaintiff v. JEFFREY L. DAVIS, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4705 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on August 18, 2006. An Acceptance of Service was filed with the Court on August 21, 2006. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: November 21, 2006 and filed with the Prothonotary on November 21, 2006. By Defendant: November 20, 2006 and filed with the Prothonotary on November 27, 2006. 4. Related claims pending: None. 5. signed: Date Waiver of Notice under Section 3301(c) of the Divorce Code was By Plaintiff: November 21, 2006 and filed with the Prothonotary on November 21, 2006. By Defendant: November 20, 2006 and filed with the Prothonotary on November 27,2006. Carol J. Lindsay E q Ie Supreme Court o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 f",) C,) Cl N ,.;'f. [l;[l; [l; [l; [l;[l; 'f. 'f. [l; 'f. 'f. 'f.'f. 'f. 'f.'f.'f.[l;'f. [l; [l; 'f. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 'f.'f.'f. [l;'f.[l; 'f.[l; [l;[l;[l;'f.[l;'f.[l;~ [l; [l; ;+; ;+; ;+; ;+; ;+; ;+; [l; DEENA K. DAVIS PENNA. STATE OF No. 06-4705 VERSUS JEFFREY L. DA VIS DECREE IN DIVORCE AND NOW, .AIo..-.., '- DEENAK. DAVIS oz.,' , ao'- , IT IS ORDERED AND DECREED THAT , PLAINTIFF, AND JEFFREY L DAVIS , DEFEN DANT, ARE DIVORCED FROM THE BONDS OF MATRI MONY. 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; The terms of the Separation and Property Settlement Agreement dated August 18, 2006 are incorporated, but not merged, into this Decree in Divorce. URd~ PROTHONOTARY [l; [l; [l;[l; [l; [l; [l;[l;[l; [l;[l;[l; [l; '10 ;+;'IO[l;'f.[l;[l;[l; [l;[l;[l;'f.[l;[l;[l;[l;'f.[l;[l; ;+; 'f. [l; 'f. 'f. [l; ;+; [l; [l; J. · h 1J ~~ 2'- 1-e/ ~ p;z ~-~-.P9 7t7. "J -Cj "l . . .' .. .' .t . ~ .