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HomeMy WebLinkAbout02-2497HEATHER L. MYERS, Plaintiff VS. JEFFREY L. MYERS, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COLrNTY, PENNSYLVANIA : Civil Term : : ACTION 1N DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT~ 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. 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 al the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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 HEATHER L. MYERS, Plaintiff VS. JEFFREY L. MYERS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . : No. 002. -',2. t../c~ r-) Civil Term : : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Heather L. Myers, a competent adult individual, who has resided at 724 Allen Road, Carlisle, Cumberland County, Pennsylvania, since February 1, 2002. 2. Defendant is Jeffrey L. Myers, a competent adult individual, who resides at 201 West Ridge Road, Dillsburg, York County, Pennsylvania. 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. Thc Plaintiffand thc Defendant were married on July 1, 1995 in New Kingston, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between thc parties. 6. Plaintiffhas been advised that counseling is available and that'plair~tiffmay have:the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiffor Defendant arc a member of the Armed Forces of thc United States of any of its allies. 10. The Plaintiffavers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. §4904 relating to unsworn falsification to authorities. Heather L. Myers, Plainti~ Respectfully s~tt e/~ / J~lt~e Adams, Esquir[ Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF HEATHER L. MYERS, Plaintiff VS. JEFFREY L. MYERS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02 - 2497 Civil Term : 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: Jeffrey L. Myers 201 West Ridge Road Dillsburg, Pa. 17109 DEFENDANT Respectfully Submitted: Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF HEATHER L. MYERS, Plaintiff VS. JEFFREY L. MYERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 2497 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on May 21, 2l)02. 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: ~//~~..TM "//~'~/;~-- ?J~r~'l~. Myers, Deferfdant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6330t(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 th~ 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: ~/~;, 'fef~y L. Myers, D~fendant ~EATHER L. MYERS, Plaintiff VS. JEFFREY L. MYERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 2497 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on May 2t, 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 unsworn falsification to authorities. Date: /'c~ - ~ (~ ~ O ~ Heather L. Myers, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~33_n1(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: /c~-~~ O~,~ ~~/L~/C~ ~'~"~ ' Heather L. Myers, Plaintiff d HEATHER L. MYERS, Plaintiff VS. JEFFREY L. MYERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 2497 Civil Term 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. 2. Date and manner of the service of the Complaint: Delivered by certified mail~ restricted delivery, return receipt requested, delivered on:. ~'-- c~ ~ -- O ~., 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: By Defendant: Prothonotary: ?.--/~ -- O ~ Date Plaintiff's Waiver of Notice in Prothonotary: j ~. ____ ~ ~- 0 ~, Related claims pending: None._ Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Date: /~_~O-- O~,, §3301(c) Divorce was filed with the Respectfully Submitted: e Adams, Esquire No. 79465 · Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff INThe COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. Heather L. Myers, Plaintiff VERSUS Jeffrey L. Myers, Defendant No. No. 02 - 2497 Civil Term DECREE IN DIVORCE AND NOW, DECREED THAT Heather L. Myers ,~~, ~T IS ORDERED AND , PLAINTIFF, AND Jeffrey L. Myers ,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 T~E ATTEST: J' ~PROTHONOTARY