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HomeMy WebLinkAbout06-5741 Jamie Re?'rs IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006 - S7?-f CIVIL TERM Dale (?egi? . , 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 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FORALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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, Pennsylvania 17013 (717) 249-3166 J COURT OF COMMON PLEAS COMPLAINT FOR DIVORCE COUNTY, PENNSYLVANIA In re: the marriage of ) c ) 0.- 5741 O ivi t 7 rm Plaintiff ) Docket No. and ) ) Defendant ) The Plaintiff, c respectfully declares the following: 1. Plaint' f's Resi ce: Pl ' tiff Insert Plaintiff's address and has commonwealth of Pennsylvania for residence in months and years]. 2: Def%ndant's_ Residence: Defendant resi des a resident of the .[-insert period of s [insert Defendant's address] and has been a resident of the commonwealth of Pennsylvania for [insert period of residence in months and years]. 3, marr.ag+e: on in (ci t ) , (state), the Plaintiff and Defendant married. An o fici 1 copy of the marriage license is attached to this COMPLAINT FOR DIVORCE. 4. Children : Plaintiff and Defendant have the following children born or adopted into their marriage: Name: Date of Birth: Name: Date of Birth: Name: Date of Birth: Name: Date of Birth: 5. Jurisdiction: This Court is that of proper jurisdiction to hear this cause. The Defendant has agreed to file an Affidavit of Consent in this cause. Neither the Plaintiff nor Defendant has been involved in any litigation or other proceeding a • involving the other party in this or any other jurisdiction with respect to their marriage or any other domestic matter. 6. Grounds for No-Fault : Plaintiff wishes a dissolution of marriage with Defendant. based rpn the following grounds: 7. Marital Settlement Agreement: Plaintiff ?rd Defendant have (copy attached) ??' have not entered into a Marital Settlement Agreement that formalizes an allocation of their prop?rtyand finances and matters relating to child custody and visitation. 8. Other Declarations: NOW, TaMREFORE, Plaintiff requests that the court order a DECREE OF DIVORCE and such further relief as Plaintiff may have requested herein. Verification [name of Petitioner], affirm unde nalty of perjury that I am the Petitioner in the foregoing COMPLAINT FOR DIVORCE and that all statements in this Petition are accurate to the best of my knowledge. I have filed this complaint in good faith and have not colluded with anyone J?ation to it. Peti er' ture Date Petitioner 5 Address, Line Petitioner's Address, Line 2 COMMONWEALTIA OF PENNSYLVANIA COUNTY OF ,,,,?? Su scri ed nd sworn to?before me on this "?W_ day of 20 ??.. Notary '\?r•ara. c..aq? Pobin L. Weigle, Notary Pu`tlic Carlisle Boro, Cumberland Courriy My Commission Expires March 6, 2007 Merntn. Pennsytvania Association Of Notaries :?-° cn T -n ` fin ( l? N Y a A J lJ AFFIDAVIT OF CONSENT PLEAS t!??? COUNTY, PENNSYLVANIA In re: the Marriage of ) Plaintiff ) and j S ) Defendant ) Docket NO. 1. A COMPLAINT FOR DIVORCE was filed between Plaintiff and Defendant on the day of 200(. 2. The marriage between Plaintiff and Defendant is irretrievably broken and efforts at reconciliation have failed. 3. I, , have received a copy.of the COMPLAINT FOR D ORCE, and I have read it thoroughly and understand it. I do not wish to contest this proceeding. I do not object to the declarations made in the COMPLAINT FOR DIVORCE. I do hereby consent to the relief requested in therein and to the entry of a DECREE OF DIVORCE dissolving and forever terminating the marriage between Plaintiff and Defendant. I consent that the court may hear this cause on any day convenient to the court without further notice to me. I further consent that the court may enter any order granting any and all the relief sought in the COMPLAINT FOR DIVORCE. 4. I waive any and all rights I may have to a motion for a new trial, a record testimony, findings of fact and conclusions of law, notice of trial, a notice of entry of a DECREE OF DIVORCE and my right to appeal. 5. I do not waive any future rights I may have to the modification of any judgment or decree in relation to this cause. 6. 1 affirm under penalty of perjury that all statements in this Affidavit of consent are accurate to the best of my knowledge. 7. 1 have filed this Affidavit of consent in good faith and have not colluded with anyone in relation to it, nor have I been subject to any force or duress in signing it. Signature Date Address, ine 1 Address. Line 2 COMMONWEAL OF ENNS LVAN A COUNTY OF Su Cri ed Ind sworn t -before me on this day of 20. Notary Notarial Seal Robin L Weigle Notary Public Carlisle Boro. Currit-r+and Courtly My Commission Expires March 6, 2007 Member, Pennsylvania Association Of Notaries ?? ? C?ri ? ?t i ^ t?"1" ,:_: E`J ; ; t`, ...- ° t^? t _, r r- =' :^,C . ?? ?,e S ??6D? gC)(% ' G7? Sxf U), c C- U e440n(e 0 -1 I Cru?p? 5e(o),e tit {he abase J ? Q "C1 ^e,.. t:3 ? .. .--•E --r-? ;,?• .`- N '' `', _ ? _, , W `'-a r 1 ? ? ? Jamie Regis, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE Dale Regis, Defendant NO. 2006-5741 CIVIL TERM NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER & 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in August, 2004 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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 falsification to authorities. Date: f ? r-a ??,', ? ? T -s ", -- - _ t ?.-- -? ` =' ?' f ? s? ± ` ?' ??;, ?^l . .. ? ..?a, .?rE?i ? ,- ? Ai A? ? :, .^... Ms. Jamie L. Regis, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Mr. Dale Regis, Defendant NO. 2006 - 5741 CIVIL TERM CERTIFICATE OF SERVICE I, Soyoung Chung, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Plaintiff s Affidavit and Counter affidavit on Dale Regis, residing at 1341 Grand View Court, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, first class, postage pre-paid. Soyoung Chung Certified Legal Intern Meg Riesmeyer d' Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 <- 7 Z7 G'1 1?`tz c-n Jamie Regis, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Dale Regis, a60 Defendant NO.2-007 - 5741 CIVIL TERM CERTIFICATE OF SERVICE I, Soyoung Chung, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Notice of Intention to Entry of § 3301(d) Divorce Decree and Counter-Affidavit on Dale Regis, residing at 1341 Grand View Court, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, first class, postage prepaid. Date: November 15, 2007 Soyoung Chung Certified Legal Intern " ?x ,, Z r I/Q. zje- nald-Fox Anne Pa__ Supervi Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 O 4 <- v cn Ca IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. No. 5741 2006 VERSUS DALE N. REGIS, DECREE IN DIVORCE AND NOW, 506cVv"'e .CIIV?, IT IS ORDERED AND DECREED THAT .TAMTR. T.. RRGTS , PLAINTIFF, AND DALE N. REGIS 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; PROTHONOTARY