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Home My WebLink About06-4907 , . JOHN R. MORRISON, PLAINTIFF v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. Ci--"I907 Cr()~{~€IL~ SANDRA K. MORRISON, DEFENDANT : DIVORCE ACTION 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 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 (717) 240-6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 32 S, Bedford Street Carlisle, PA 17103 (717) 240-6195 , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Ol.. -1./'fP7 C!Lo~LJ~ : DIVORCE ACTION JOHN R. MORRISON, PLAINTIFF SANDRA K. MORRISON, DEFENDANT COMPLAINT UNDER SECTION 3301lcl OR SECTION 3301ldl OF THE DIVORCE CODE 1, Plaintiff, John R Morrison , is an adult individual who currently resides at 9 Trine Avenue, Mt. Holly Springs, PA 17065, 2. Defendant, Sandra K. Morrison, is an adult individual who currently resides at 129 Tower Circle, Carlise, PA 17013, 3, The Plaintiff's Social Security Number is 20848-7914, 4. The Defendant's Social Security Number is 178-50-3560, 5. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 6, The Plaintiff and Defendant were married on February 20, 1989, in Hagerstown, MD, 7. A prior divorce action was filed between the parties docketed to No. 99-6818, however, that action was terminated for inactivity. 8. The marriage is irretrievably broken. 9. 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, 10, Plaintiff requests the Court to enter a Decree of Divorce, WHEREFORE, Plaintiff, John R. Morrison, urges this Honorable Court to enter a Decree of Divorce, G1 - By: James G, Nealon, III, Esquire Attorney 1.0. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 . ~ VERIFICATION I, John R. Morrison, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,SA 4904 relating to unsworn falsification to authorities, -#:1- iL J?l ~ J N R. MORRISON Dated: 8 -'1 - fJ {;, 010... ~ 0 - ...., @ ~ .0 (') = ~ c <=> \) z CJ' .... -oef ;po- ffi:n rrr'- c: C;) r B ~;? ", "QtT1 W s_,. ..~ ""?,'! N ~UCJ - !rt u;~' ., c".;> ~;~ (~) "'Q i~-:, :c:1.\ - ~ -0 ()7) - C> 3 :2" -Q .......rn J;>-I'~- <;:-.) ,~ ".-- -.; ..c ~'7 ~ ~--t N - --F -< .. . , JOHN R. MORRISON, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. C)~ -4'(0( C'I(JLLYf:L~ : DIVORCE ACTION v. SANDRA K. MORRISON, DEFENDANT NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(dJ OF THE DIVORCE CODE AND AFFIDAVIT OF NON-MILITARY S!;RVICE 1, The parties to this action separated in November of 1994 and have continued to live separate and apart for a periOd of at least two years, 2, The marriage is irretrievably broken. 3. 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. 4, The Defendant is not presently in the active military service of the United States of America and is not a member of the United States Army, Navy, Marine Corps, Air Force or Coast Guard, nor is the Defendant an officer in the Public Health Service detailed by proper authority with any such service, nor is the Defendant engaged in any . . .' . active military service or duty with any unit covered by the Soldiers and Sailors Civil Relief Act of 1940, nor has the Defendant enlisted in any military service covered by the act. 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: ~ -7 -0'- ~ ;L (YL~ ohn R. Morrison (Plaintiff) (') c u~t~ n'n :.;it.,': l~;j-. ~ < ~>~.': )>(=: ~ . .. " . ,..., = = "" ".. c:: G"> N W ~ ::::; o -n s:! n1:I! r- -om ~UO ~) , '=. C) T.!'):Yi .2:0 Om ?,g -< <:'? N JOHN R. MORRISON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4907 Civil Term SANDRA K. MORRISON, DEFENDANT : DIVORCE ACTION AFFIDAVIT OF SERVICE 1. On August 30, 2006, I, James G. Nealon, III, Esquire, sent a letter and a certified copy of the Complaint and Affidavit pursuant to 93301 (d) of the Divorce Code to the Defendant, Sandra K, Morrison by certified mail, return receipt requested. A true and correct copy of the correspondence is attached hereto and incorporated herein by reference as Exhibit "A". 2. I received the return receipt card indicating that Tammy A. Miller had signed for the letter on September 1,2006. A true and correct copy of the return receipt card is attached hereto and incorporated herein by reference a 3. Pursuant to Pa.R.C.P. 1930.4(c), s September 1, 2006. James G, Nealon, III, Esquire Attorney 1.0. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 AFFIDAVIT COMMONWEALTH OF PENN5YL VANIA ) ) 55: COUNTY OF DAUPHIN ) Before me the subscriber personally appeared James G, Nealon, III, Esquire, to me known, who being duly sworn according to law doth depose and say that the above Affidavit of Service to Sandra K. Morrison and further deponent sayeth not. Sworn to and subscribed before me thisJ:sth day of September, 2006. ~~o-A-~f)~ NO ARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal .Barbara j" Baker, Notary Public CltyofH:amsbllrg, Dauphin County My CommissIon Expin.1s Aug, 13,2007 Mtmbtt, Pltnn8;1Vlnl4I Association of Notaries p~'Jblt- A NEALON GOVER & PERRY NG&P MAlUNG ADDRESS: 2411 N. FRONT ST. IlAIuuSBURG, PA 17110 PH: 717.232.9900 FAX: 717.236.9119 40 E. PHILADELPHIA ST. YOU, PA 17401 PH: 717.852.7888 ;:II A lTORNEYS AT LAW James G. Nealon, III, Esquire j nealon@ngplawfirm.com August 30, 2006 VIA CERTIFIED MAIL Sandra K. Morrison 129 Tower Circle Carlisle, PA 17013 Re: Morrison v. Morrison - No. 06-4907 Civil Term Dear Ms, Morrison: The undersigned has been retained by your husband, John R. Morrison, to obtain a divorce. Enclosed please find a certified copy of the Complaint and a certified copy of the Affidavit Under Section 3301 (d) of the Divorce Code. These are being served upon you pursuant to the applicable Pennsylvania Rules of Civil Procedure. If you have any questions regarding this, please do not hesitate to contact me. However, I cannot provide you any legal advice. Thank you for your attention to this matter. U S postal Service ' CERTIFIED MAIL RECEIPT , (DomestIc Mail Only; No Insurance Coverage provIded) ~;;ee RestriClBd ry Fee (Endollllllll8l1l R 1btaI poetage & Feee $ . . James G. Nealon, III NEALON, GOVER & PERRY, P.C. Pa8I8g8 $ \l',ertllled Fee USE ~ ~ q. f. )(~l b (r \$ cr ">tl t . . Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. . Print your name and address on the reverse 80 that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space pennits. 1. Article Addressed to: . ~ Ii!fJPI.A rno ~~ f!ZJ;J / Jq T tJuf- e leaL&' (!,/I R LlsLI3j,tJYf / 7fJ/8 2. Mk:Ie Number (Jt&nsfer II'om service label) PS Form 3811, Februwy 2004 o Agent o Addreseee C. ~e of Delivery <a) ?-t~G. D. Is delivery address dlffer9nt from Item 1? 0 Yes If YES, enter delivery address below: 0 No 3. SelvIceType . Certified Mall C Express Mall o Reglstemd rtJ.Retum ReceIpt for Merchanc:IlN o Insured Mall b C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 7004 2890 0000 6575 3921 ~ Return Receipt 102S86-02-M-1540 ~ 't'"j () C-.::'1 t,;.:') '11 t;.;.~'-. -I (/"1 ~~ rC \ fft:n -0 I -om ~~ \.0 }~Y '::::~() :.:::0 'I t~-~:~ ~~'I) ~g ::;:. C"', 1') f') r'll ~ (,.+"'J 50 c., , < . JOHN R. MORRISON, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-4907-Civil Term SANDRA K. MORRISON, DEFENDANT : DIVORCE ACTION NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: Sandra K. Morrison DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the ~ 3301(d) affidavit. Therefore, on or after November 16, 2006, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S, Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Ja JOHN R. MORRISON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4907- Civil Term SANDRA K. MORRISON, DEFENDANT : DIVORCE ACTION COUNTER-AFFIDAVIT UNDER i 3301(d) OF THE DIVORCE CODE 1, Check either (a) or (b): ) (a) I do not oppose the entry of a divorce decree, ) (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both: ( ) (i) The parties to this action have not lived separate and apart for a period of at least two years ) (ii) The marriage is not irretrievably broken. 2, Check either (a) or (b): ( ) (a) I do not wish to make any claims for economic relief, 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, ( ) (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary and serve them on the other party, If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me and I shall be unable to thereafter to file any economic claims, I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,SA 9 4904 relating to unsworn falsifications to authorities, SANDRA MORRISON NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. CERTIFICATE OF SERVICE AND NOW, this ..96 ~" day of October, 2006, I hereby certify that I have served the foregoing Notice on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Sandra Morrison 129 Tower Circle Carlisle, PA 17013 ,/ /1 L' /" ,.- L/ /.' / , ...-y / / ./ .. / .-</~;//t~' V' " /;A'&:./vr /,'~4' Jame~,<3. Nealon, III, Esquire " n ~:i f__. '- --'J .~.( ,...., = C;;:, cr' ~ :;i fll ::!J -oFn :;.)0 ;~~ (3fTl ::;-\ .'-'" ::0 -< C) ,,-) -j N -.J ,) ...". .....'~ N C. JOHN R. MORRISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA VS. NO. 06-4907 Civil Term SANDRA K. MORRISON, Defendant DIVORCE ACTION To the Prothonotary: PRAECIPE TO TRANSMIT Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S 3301 (d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified Mail return receipt September 1, 2006. 3. (Complete either paragraph (a) or (b). ) (a) Date of execution of the affidavit of consent required by S 3301 (c) of the Divorce Code: by plaintiff ; by defendant (b) (1) Date of execution of the affidavit required by S 3301 (d) of the Divorce Code: August 9,2006. (2) (a) Date of filing of Plaintiff's affidavit upon respondent: August 23, 2006. (b) September 1, 2006. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: None, no claims raised. 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: October 26, 2006. (b) Date plaintiff's Waiver of Notice in Divorce was filed with the Prothonotary: (c) Date defendant's Waiver of Notice in Divorce was filed with the Prothonotary: .J{u~fQ ( James G. Nealon, III, Esqui Attorney 1.0. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Attorney for Plaintiff () r--:> 0 = c = -n <:.-, ~~., 0 .-1 I" -..,- I"" rl1:D cJ t r:1 r~;J , C-.. --~ ~;i~ :;'~ ....Ii>- n'j CD ~~ 0:> N :.0 N .< ;Ii ;Ii ;Ii;li ;Ii;li ;Ii;li;li;li;li;li ;Ii;li;li;li;li;li;li;li;li;li;li ;Ii;li;li ;Ii;li ;Ii ;Ii;li ;Ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JOHN R. MORRISON No. 06-4907 PLAINTIFF VERSUS SANDRA K. MORRISON DEFENDANT DECREE IN DIVORCE AND NOW, DeL. l'1 , 2..606, IT IS ORDERED AND ;Ii '" ;Ii ;Ii DECREED THAT JOHN R. MORRISON '" ;Ii , PLAI NTI FF, AND SANDRA K. MORRISON '" '" '" '" '" , 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; A TTES J. PROTHONOTARY ft; ~ :+::f. :+: ~~~~~:+::+::+::+::+:~:+::+:~:+:~:+::+::+:~ :+: :+::+::+:~ ~:+::+::+: ~:+: :+::+:~:+::+:~~ "''''''';Ii''' 47...~'~ y~ ~ _ k 7 ~ r>7J!/t. 'W' re- 'CI ),fi :;. ~,/rJ,,, - P7 Ij(/' rc ~/ -.', ~."'" ... . ' . !f -.,; -.,t ~'""- ~