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HomeMy WebLinkAbout02-2483JAYNE M. DRAG, : Plaintiff : RICHARD J. DRAG, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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 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 the Cumberland County Courthouse, Carlisle, PA 17013. 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 LEC4~L HELP. Cumberland County Bar Association 2 Libert¥ Avenue Carlisle, PA 17013 TeleDhone: (717) 249-3166 fl\div\DRAG.DIVomp. WPD JAYNE M. DP~G, Plaintiff RICHARD J. DRAG, Defendant CUMBERLAND COUNTY, CIVIL ACTION - IN DIVORCE IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA LAW COMPLAINT 1. The Plaintiff in this action is Jayne M. Drag, an adult individual, who currently resides at 117 Round Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant in this action is Richard J. Drag, an adult individual, who currently resides at 117 Round Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on June 1, 1990, in New Cumberland, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is -1- irretrievably broken. 7. The Plaintiff avers that no children have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject P.C.S. §4904, relating to unsworn falsification to the penalties of 18 to authorities. Date: Jayne STONE LaF~V~R/~" T,E~SKI By~ E~'~be t~{ B./Stone /~.~ .rem~/Co/%t ID #60251 414 ~id~ Street, P.O. ~New//C/~ r 1 and, PA Attorneys for Plaintiff Box E 17070 717-774-7435 -2- JAYNE M. DRAG, Plaintiff Vo RICHARD J. DRAG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2483 CIVIL TERM : : CIVIL ACTION - LAW IN DIVORCE A~FIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, RICHARD J. DRAG, at 117 Round Ridge Road, Mechanicsburg, PA 17055, by United States Certified Mail, postage prepaid, restr.cted delivery, on May 23, 2002, as evidenced by the attached return receipts. SWORN TO AND SUBS~,~IBED bef.ore me this ~day of '--/)~-~,/ , 2002. No%a~ Publi~ ~ Eli~th B.//~J~ne fl\div\lconsentaffidavit JAYNE M. DRAG, Plaintiff Vo RICHARD J. DRAG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-2483 : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on May 20, 2002, and served May 23, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. 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 falsifica- tion to authorities. ~. Date JAYNE/~ [/~G ,~1~ nt i f f fl\div\lconsentaffidavit JAYNE M. DRAG, Plaintiff Vo RICHARD J. DRAG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2483 : : : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on May 20, 2002, and served May 23, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. 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 falsifica- tion to authorities. Date RICHARD J. De JAYNE M. DRAG, Plaintiff RICHARD J. DRAG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2483 : CIVIL ACTION - LAW IN DIVORCE WAI~ER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE notice. 2. I consent to the entry of a final decree of divorce without 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 falsifica- tion to authorities.o~ ~. ~oo~ ~~~..~, Date ' . fl\div\lwaivernotice JAYNE M. DRAG, Plaintiff RICHARD J. DRAG, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2483 : CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE notice. 2. I consent to the entry of a final decree of divorce without 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 falsifica- tion to authorities. Date fl\div\ltransmitpraecipe\7-97 JAYNE M. DRAG, Vo RICHARD J. DRAG, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 02-2483 : · ACTION 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 § (3301(c)) ~) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: May 23, 2002, £ertified Ms, I, Restricted Delivery, Return Receipt Requested, Postage Prepaid 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff Oct. 2:2002 ; by Defendant Oct..2, 2002 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: ; (2) A. Date of filing of Plaintiff's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: 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: (b) Date Plaintiff's ~aiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in § 330i(c) D~was filed with the Prothonotary: Attorn T ) S/~251 IN ThE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of JAYNE M. DRAGv Plaintiff VERSUS RICF~RD J. ERAG, Defes~ant PENNA. N O. 02-2483 DECREE IN DIVORCE DecReED THAT JAYNE M. DRAG , it iS ORDERED AND , PLAINTIFF, AND RICHARD J. ERAG ,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; By ThE COURT' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAYNE M. DRAG, Ye RICHARD J · ERAG, pi a~ntiff NO. 02-2483 CIVIL ACTION IN DI%K)RCE pefen~a~t : NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the //~'/~ day of ~~ _, ~97d~_~ hereby elects to retake and hereafter use her previous name of JAYNEMARIEKOPKO COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND (Si~d-fg~YNE M. KOPKO SS. On the ~ day of .~~ , ~, before, a Notary Public, personally appeared Jayne M. Drag , known to me to be the person whose name is subscribed to the within docu- ment, and acknowledged that she executed the foregoing for the pur- pose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. !--~ ' NOTARIAL SEAL_ ... KAYE R. LUCI~, Notan/ '! My C~nml~ion Exp~ ~ zr, · Not~rY