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HomeMy WebLinkAbout02-2328 /N THE COURT OF COMMON PLEAS OF COMB A. JOSEPH SPENCER, PENNSYLVAN/A ERLAND COUNTy PhlntiE CAROL/NE p. SPENCER, ~NO. 2002 ~-~CML TERM _. : C/V/L ACT/oN. LAW Defendant : : /N D/VORcE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued/n court If you Pages, you rnus~ ' wish to take PrOmpt act/on. You are warned that ifyou fa//to do so, the case may Wi out you and a decreedefend against the ciaitns set in the fo//ow "~ c/a~I~ or re/jefro~uested oz~Vorce or ann.! .... '_ . ' Or other l~ht · '~t ~ct ~t2 tI~e .... -.~u~at ~v Do .... . m~P°nanttoyouincb,,~:__ -vYthepla/nt/ff. Yo'.-- - aga/nstyouforanv ~ C~°dy or ,~:--~- ' - u~y lose raolle-- ~ '~*maon ofyour ch/~dren, y or property When the ground for the divo--- · · . ~ay request mo,~__ *~c ~s hldJgnities or '~ ~,tage counse/Jno. A ,:~ . a'retrJevabie brealtn Protllonotary at the Frnnkli~' '~ ~ oI marr/a~e co- - ~aaown of the .... Pennsyh, nnia, 17201. -'~ unse/ors/s ava//am_ · .~ ,~mxtage, you Co#nly Conrthouse, 157 Lincoln o~: ~n the Office of the Way East, Cbambersb~rg, t~ES OR EXPE ~ NY D GRANTED, YOU MA .... NSES BEFORE - ~r LOSE ~ ~.~ ~ "~ ~GHT TO ~w~ ~H BELOW T ~.~E, GO TO OR T ~c~. ~ YOU DO NOT p~ ---, ~rT LEGAL H . _ ~ dar ~a~ ELP. *~ ~ S~t ~r~ PA 171~ Teleph~e: 1.~6~75 or Attorney for P/aintiff 701 E. King Street S&ipPensburg, PA 17257 IN THE COURT OF COMMON PLEAS OF COMBERLAND COUNTY PENNSYLVANIA A. JOSEPH SPENCER, Plaintiff CAROLINE P. SPENCER, Defendant NO. 2002 ~.f CIVIL TERM CIVIL ACTION - LAW 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 for any other claim or relief requested in these papers by the plaintiff.. You may lose money or property or other fights importam 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 Off]ce of the Prothonotary at the Franklin County Courthouse, 157 Lincoln Way East, Chambersburg, Pennsylvania, 17201. 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 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. Pennsylvania Bar Association Lawyer Referral Serviee 100 So~t~ Street PO Box 186 Harrisburg PA 17108 Telephone: 1-800.-692-7375 or (717) 238-671~ By: Attorney for Plaintiff 701 E. King Street Shippensburg, PA 17257 CAROLINE p. SPENCER, Defendant IN THE COURT OF COMMON PLEAS OF COMBERLAND COUNTy PENNSYLVANIA A. JOSEPH SPENCER, : NO. 2002 Plaintiff : ~--~P__CIVIL TERM civ ACTION. LAW ; : IN DIVORCE COMPLAINT IN DIVORCE COMEs NOW, the Pla/ntiff~ A. JOSEPH SPENCER, J. Winder, Esquire, and represents as follows: by and through his counsel, Sally address is, og Caoin Road, Newvil/e, Cumberh~ ,~_ *vno~c totaling 2002. '~"~" ~..ounty, Pennsylvania, since March 2, 2. Defendant is CAROLINE p. SPENCER, who currently resides at, and whose rna/1/ng ~ is, 125 Hershey Road Lot 12, · October 1, 2000. Shippensburg, Cumber/and County, Pennsylvania, s/rice 3. Both P/aintiffand Defendant have been bona fxle residents of the Commonweal~ of Pennsylvan/a for at/east sm months anmediate/y previous to the f~ing of this Corap/aint. 4. The P/aintiffand Defendant were married on August 25, 2002, at Newville, Cumberland County, Pennsylvan/a. 5. There have ' · . been no prior actmns ofdivoree or for annulment between the parties. 6. The marriage is irretrievably broken. 7. PlaintLffavers that he has been advised ofthe availability ofcoanseling sessions for both parties upon request of either party or by order of eom-t, and that a list of qualified professionals who provide such counseling service is available at the Domestic Relations Office upon request. By the filing of this Complaint, the Plaintiff acknowledges having been advised by his attorney of record of the avail~_b'flity of counseling sessiom and ora list of qualified professionals. Plaintiff further avers that she has been advised that the choice of a qualified professional sb. all be at the option of the Plaintiff and Defendant and need not he selected l~om the list available upon request and, further, that arrangements for and the payment of the services of the qualified professional shall be the responsibility of the parties and will not be included in the docket costs ofth/s proceeding. 8. Plaintitfrequests the Court to enter a decree of divorce. Date: Sally J. Winder, Esquire Attorney for Plaintiff, A. JOSEPH SPENCER 701 East King Street Shippensburg PA 17257 (717) 532 - 9476 In the Court of Common Pleas of Cumberland County, Pennsylvania No. OZ'- ,~'2'~ Civil. 19 To Prothonotary ey for Plaintiff No. Term, 19 ~ File) PRAECIPE 19 , Atty. VERIFICATION I verify that the statements made in this complaint are true and correct to the best of my personal knowledge and belief. I understand that fa~ statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. A. JOSEP~ SI~N~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA A. JOSEPH SPENCER Ye CAROLINE P. SPENCER : NO. 2002-2328 CML-TERM Plaintiff : : : CML ACTION- LAW : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of thc Divorce Code was filed on May 10, 2002. 2. Thc marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from thc date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of imcntion to request entry of thc decree. I verify that thc statements made in this affidavit are true and correct. I understand that false statements herein arc made subject to thc penalties of 18 Pa. C.S. section 4904 relating to unswom falsification to authorities. Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA A. JOSEPH SPENCER CAROLINE P. SPENCER : NO. 2002-2328 CIVIL-TERM Plaintiff : : : CIVIL ACTION- LAW : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 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 ifI 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. section 4904 relating to unswom falsification to authorities. Date: A. JOS]g~H S~E~R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA A. JOSEPH SPENCER Plaintiff V. CAROLINE P. SPENCER Defendant : NO. 2002-2328 CIVIL-TERM : CIVIL ACTION- LAW : : IN DIVORCE ACCEPTANCE OF SERVICE I, Caroline P. Spencer, do acknowledge that I have received a true and correct copy of the Complaint in Divorce and Notice to Defend in the above-captioned divorce and accept the service thereof on ~ ] af4~ ,2002. k/ I verify that the statements made in this Acceptance of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. CAI~.~INE P. SPENCER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA A. JOSEPH SPENCER CAROLINE P. SPENCER Plaintiff Defendant : NO. 2002-2328 CIVIL-TERM : CIVIL ACTION- LAW : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Section 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 ifl 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unswom falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA A. JOSEPH SPENCER Plaintiff V. CAROLINE P. SPENCER Defendant : NO. 2002-2328 CIVIL-TERM _- : CML ACTION- LAW : : 1N DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 10, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry ora 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. section 4904 relating to unswom falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA A. JOSEPHSPENCER CAROLINE P. SPENCER Plaintiff Defendant : NO. 2002-2328 CIVIL-TERM .. : CML ACTION- LAW : : 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 S3301(c)(1) of the Divorce Code. 2. Date and manner of service of the Complaint and Notice to Defend and Claim Rights: received by Defendant on August 14, 2002, as shown by her signature on the attached Acceptance of Service filed with the Court. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code: by Plaintiff August 26, 2002; by Defendant May 23, 2003. 4. Related claims pending: None. 5. Date of filing Waiver of the Notice of Intention to Request Entry of Divorce Decree Under Section 330~1(c) ~as filed with the Prothonotary: by Plaintiff September 6, 2002, by Defendant June It~ , 200.~. der, Esquire itcher Hwy., Shippensburg PA 17257 (717) 532 - 9476 Attorney for Plaintiff IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PENNA. PLEAS A. JOSEPH SPENCER Plaintiff VERSUS CAROLINE P. SPENCER Defendant NO. 2002-2328 DECREE IN DIVORCE AND NOW, ~':~' , 2003 , IT IS ORDERED AND DECREED THAT A. JOSEPH SPENCER AND CAROLINE P. SPENCER , PLAINTIFF, , 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 · hi 'L.