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Home My WebLink About06-5321 DARRYL M. McLAUGHLIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006- CIVIL TERM HEIDI J. McLAUGHLIN CIVIL ACTION-LAW Defendant 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 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 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 DARRYL M. McLAUGHLIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006- SYaJ CIVIL TERM HEIDI J. McLAUGHLIN CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT Plaintiff, Darryl M. McLaughlin, is an adult individual residing at 15 Meeting House Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, Heidi J. McLaughlin, is an adult individual residing at 209 N. College Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 7, 1996 in Las Vegas, Nevada. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he 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. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER & k/V Michael A. cherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff mas.dir/domestic/mclaughlin/complaint.pld VERIFICATION 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.A. § 4904, relating to unsworn falsification to authorities. Date: a " G 15:) aN S'? lJ r-? ? :- cl- r y. l --C DARRYL M. McLAUGHLIN, Plaintiff V. HEIDI J. McLAUGHLIN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- 6391 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this day of !?j , 2006, I, Heidi J. McLaughlin, j Defendant above, hereby accept service olf the Complaint fiied in the above case pursuant to Pa. R.C.P. 1930 (d) and acknowledge receipt of a true and attested copy of said Complaint. I idi J. McL hlin f.? ? `-=s cr_ ? ? a ? -r C" n1 ??, x r, .. ? ?..:f .?_i l_ y.y S? ,ai ., 4«?.'.? it DARRYL M. MCLAUGHLIN, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-5321 CIVIL TERM HEIDI J. McLAUGHLIN, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF- DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on September 12, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 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. 5. 1 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. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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 unsworn falsification to authorities. Date: / -6 A, , /) ( l Darryl M. aughlin I I ?- r c? ?'? --r- f' -- - ?.-.., S.""" i j -,fit iT' t' `? [.. +?.? ._.a ??. ....» ?3 ? i"1' ' ? - i. v,; _ ?? _ ??" ?, .? DARRYL M. McLAUGHLIN, Plaintiff V. HEIDI J. McLAUGHLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-5321 CIVIL TERM 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed an Acceptance of Service form on September 22, 2006 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on July 11, 2007; and Defendant on August 29, 2007. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARIC & SCHERER .4 Mi ha I A. erer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 ??,? ?? C„-,`! q ? ' ? "?. ,i?" + ' "r ? ? ' . "'C Sr--' , f ? ? n ? ? j / ., ??{ "j ""'a ?? .. .o'° '.f?a +? ? ? j ?Y?` ,,.?? / w ?,. .r+. , DARRYL M. McLAUGHLIN Plaintiff V. HEIDI J. McLAUGHLIN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-5321 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 12, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. § 4904, relating to unsworn falsification to authorities. Date: 2 a ?? Heidi J. McLaug?firDefendantrI, Q t . DARRYL M. McLAUGHLIN Plaintiff V. HEIDI J. McLAUGHLIN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-5321 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 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. §4904, relating to unworn falsification to authorities. Date: JO eid i J. McLau in, Defend ' -Tt Cl t? ? am :, fr? : 7 C 'D Plaintiff VERSUS HEIDI J.McLAUGHLIN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. DARRYL M. McLAUGHLIN, I I NO. 2006-5321 Civil Defendant PROTHONOTARY DECREE IN DIVORCE AND NOW IT IS ORDERED AND DECREED THAT DARRYL M. McLAUGHLIN , PLAINTIFF, AND HEIDI J. McLAUGHI;IN. 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. '-s Irvw ?? c-a. L_/ Lp- C/ b