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HomeMy WebLinkAbout02-2473TAMMY M. ADAMS, Plaintiff VS. DALE E. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. tOo) 'o~7_~ Civil Term ACTION 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 by the Court. A judgrnent 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, D1VISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 TAMMY M. ADAMS, Plaintiff VS. DALE E. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : N°'c)~- o~q'-?.~ CivilTerm : : ACTION IN DIVORCE ; COMPLAINT IN DIVORCE 1. Plaintiff is Tammy M. Adams, a competent adult individual, who has resided at 1 Park Street, Mount Holly Springs, Cumberland County, Pennsylvania, since 1991. 2. Defendant is Dale E. Adams, a competent adult individual, who has resided at 48 Seavers Road, Newville, Cumberland County, Pennsylvania, since February 2002. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiffand the Defendant were married on July 13, 1987 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divoree or for annulment between the parties. 6. Plalntiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. 7. Plainfiffand Defendant have two children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plalntiffor Defendant are a member of the Armed Forces of the United States of any of its allies. '10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to enter a decree in 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. §4904 relating to unswom falsification to authorities. dams, Plaintiff Respectfully submitted, 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF TAMMY M. ADAMS, .Plaintiff VS. DALE E. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 02 - 2473 Civil Temi : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT AND NOW, this May 30, 2002, I, Jane Adams, Esquire, hereby certify that on May 25, 2002, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Dale E. Adams 48 Seavers Road Newville, Pa. 17241 DEFENDANT Respectfully Submitted: 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF TAMMY M. ADAMS, Plaintiff VS. DALE E. ADAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O~ ' ~ ~"73 Civil Term : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 18, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 true and correct, i also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. Date: ~--I~ale E. Adams, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER .q3301(c) OF THE DIVORCE CODE 1. I consent to 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 unsworn falsification to authorities. Date: ................... · ams, Defendant TAMMY M. ADAMS, Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 0 ~ ~ ~'~ ~) Civil Term DALE E. ADAMS, Defendant ACTION IN DIVORCE 2002. AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on March 18, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: Tammy M Adams, "' WAIVER OF NOTICE OF INTENTION TO RE~I_I~_-_qT ENTRY OF A DIVORCE DECREE UNDER _~3301 (c) OF THE DIVORCE CODE 1. I consent to 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 unsworn falsification to authorities. Date: ?~/~ ~/~ Tammy M. A~ams, Plaintiff TAMMY M. ADAMS V. DALE E. ADAMS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2~5473 CIVIL TERM ORDER OF COURT AND NOW, this 2ND day of OCTOBER, 2002, it appearing that the Affidavit of Consent signed by defendant is undated, the request for the entry of a final decree in divorce is denied without prejudice. Edward E. Guido, J. Jane Adams, Esquire For the Defendant :sld TAMMY M. ADAMS, Plaintiff VS. DALE E. ADAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 2473 Civil Term ACTION IN DIVORCE AMENDED AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 18, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.$. 4904, relating to unsworn falsification to authorities. Date: /O~-'~"-~..~ ,_.~'~ ~~~ Dale E. Adams, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that t may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do net 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 unsworn falsification to authorities. Dale E. Adams, Defendant IN The COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of PENNA. tammy M. Adams, Plaintiff O~, No. j~l - 2473 Civil Term NO. VERSUS Dale E. Adams, Defendant DECREE IN AND NOw, DECREED THAT DIVORCE Tammy M. Adams ,~1~ , it iS orDereD aND , PLAINTIFF, AND Dale E. Adams , 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. BY ATTEST: O J' THONOTAR~