HomeMy WebLinkAbout02-2440 IN THE COURT OF COMMON PLEAS OF
THE 39th JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Lori Z. Parr, )
Plaintiff, )
)
)
Robert B. Parr, Jr., )
Defendant, )
Civil Action - Law
No. ~)~ -- o,gqqt~
In Divorce a v.m.
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 judgmant 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 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 of
the Cumberland County Court House, Carlisle, Pennsylvania.
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
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Pennsylvania Bar Association
Lawyer Referral Service
1-800-692-7375 (PA Only) or
(717) 238-6715
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
IN THE COURT OF COMMON PLEAS OF
THE 39th JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Lori Z. Parr,
VS.
Robert B. Parr, Jr.,
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 09.- .9t./4
In Divorce a v.m.
COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
1. Plaintiffis Lori Z. Parr, who currently resides at 24 Cumberland Avenue, Apartment #2,
Shippensburg, Franklin County, Pennsylvania 17257 since January, 2002.
2. Defendant is Robert B. Parr, Jr., who currently resides at 14 Partridge Trail, Cumberland
County, Pennsylvania 17257, since September, 1987.
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 December 15, 1984 in Shippensburg,
Cumberland County, Pennsylvania.
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 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 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.
Lol~'Z. Parr, ~nti~
BARLEY SNYDER
1078333
Lynh ~. MacBfi~., Esquire
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Lori Z. Parr,
VS.
Robert B. Parr, Jr.,
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-2440 Civil Term
In Divorce a v.m.
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF FRANKLIN )
Lynn Y. MacBride, Esquire, being duly sworn according to law, deposes and says that she
is the attorney for the Plaintiff, Lori Z. Parr, in the above-captioned matter; that she did serve a tree
and attested copy of the Divorce Complaint under Section 3301(c) or (d) of the Divorce Code by
mailing the same to Robert B. Parr, Jr., Defendant, by certified mail, restricted delivery, article
number 7106 4575 1294 2335 0901 on May 24, 2002, to his mailing address of 14 Partridge Trail,
Shippensburg, Pennsylvania 17257; that said certified mail article was delivered to Defendant,
Robert B. Parr, Jr., on May 28, 2002, all as appears from the receipt for certified mail and the return
receipt attached hereto.
WALKER & MACBRIDE Office
of Barley, Snyder, Senft & Cohen, LLC
By:
Sworn and subscribed to before me
this ~ day of ._-~_. ,2002.
Notar~
1082636
Chaml:~e~ Bom, F~J'tkrm C -x~_~f~Y
L~nla Y. MacBfi~e, Esquire
Attorney for Plaintiff
TO-' Robert B. Parr, Jr.
14 Partridge Trail
Shippensburg, PA 17257
~ENDER:
REFERENCE:
Lynn Y. MacBride, Esq.
Lori Z. Parr
PS r-ofl'n 3800~ June 2000
RETURN Postage .234
RECEIPT Certified Fee I
~NICE Return Receipt Fee I Z.jL .3U1U
3
Restricted Delivery
Total Postage & Fees
US Postal Service i 3~'~'MARK OR~
Receipt for (:
Certified Mail ~
DO NO{ Use for Intematfonal Mail -
3. ~e~viceType cERTIFIED MAIL
4. Reltricted Delivery? (Extra Fee) X~ Yes
1. A~lcle Atl,.l~c.,,;¢d to:
Robert B. ?art', Jr.
14 Partridge Trail
Shippensburg, PA 17257
O. Signature
a~drea~ different from Ifom 17
EYES, en~r d~lvery address below:.
[DYe,
"E2No
RESTRICTED
DELIVERY
..:~.,
I~:Lori Z. Parr SENDER: Lynn Y. MacBride, Esq.
i i~ Feint 3~11, June 2000
Loft Z. Parr,
VS.
Robert B. Parr, Jr.,
IN THE COURT OF COMMON PLEAS OF
THE 39TM JUDICIAL~DISTRICT OF PEN.~SYLVANIA
F~IN COUNTY BRANCH
) Civil Action - Law
Plaintiff, )
)
) No. 02-2440 Civil Term
)
)
Defendant, ) In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on May 17, 2002.
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 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.
Date:
Robert B. Parr, Jr., Defendant
I II IIII ! .I ~
Loft Z. Parr,
VS.
Robert B. Parr, Jr.,
IN THE COURT OF COMMON PLJEAS OF
THE 39TM JUDICIA.,.L,,DISTRICT OF PENNSYLVANIA
FRA]g,KLIN COUNTY BRANCH
) Civil Action - Law
Plaintiff, )
)
) No. 02-2440 Civil Term
)
)
Defendant, ) In Divorce a v.m.
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 fights 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 bc divorced until a divorce decree is entered by thc Court and
that a copy of thc decree will bc sent to me immediately after it is filed with thc Prothonotary.
I verify that the statements made in this Waiver 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.
Date:
1144095
Robert B. Parr, Jr., Defendant
Loft Z. Parr,
VS.
Robert B. Parr, Jr.,
IN THE COURT OF COMMON PLEAS OF
THE 39TM JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-2440 Civil Term
In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) or 33(}1 (d) of the Divorce Code was filed
on May 17, 2002.
2. The marriage of Plaimiff 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 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.
LoffZ. Parr, l~aintiff
I
Robert B. Parr, Jr.,
VS.
Robert B. Parr, Jr.,
IN THE COURT OF COMMON PLEAS OF
THE 39T~ JUDICIAL DISTRICT OF PENNSYLVANIA
~ COUNTY BRANCH
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-2440 Civil Term
In Divorce: a v.m.
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 conceming 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 il: is filed with the Prothonotary.
I verify that the statements made in this Waiver 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.
Date:
1144095
~L~ri z. Parr, ~intiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Loft Z. Parr,
VS.
Robe~ B. Pa~,Jr.
) Civil Action -Law
Plaintiff, )
) No. 02-2440 Civil Term
Defendant, ) In Divorce a v.m.
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: signed for on May 28, 2002 - (certified mail,
restricted delivery, Article # 7106 4575 1294 2335 0901);
3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code:
by Plaintiff, February 3, 2003; by Defendant, February 3, 2003;
4. Related claims pending: Resolved through private Agreement;
5. (a) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: February 12, 2003;
(b) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: February 12, 2003.
BARLEY, SNYDER, SENFT & COHEN, LLC
50326
By:
LA,
~ V. Ma.~.[clJride, Esquire
Attorney for Plaintiff
INTHE COURT OF COMMON PLEAS
OF CUMBERLAND courqTY
STaTE OF ~.~.~~..~ ~ PeNNA.
Lori Z. Parr,
VERSUS
Robert B. Parr, Jr.
NO. 02-2440 civil Term
AND NOW,
DECREED ThAT
DECRee iN
DIVORCE ~ ~: 2jOp/~
Lori Z. Parr _, PLAINTIFF,
AND Robert B. Parr, Jr. , 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
ByT u T