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HomeMy WebLinkAbout06-5581 . . , Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA MARCELLUS MOORE, vs. NO.Ol. - SSP! CNIL TERM Defendant CNIL ACTION - LAW : IN DNORCE/CUSTODY CAMELLIA MOORE, 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, Cumberland County, 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. 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 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 Telephone: (717) 249-3166 By: ~,-. - v""""," Date: September 1 3 , 2006 onica E.. Baturin, Esquire ( ttomey I.D. No. 73356) 2604 North Second Street Harrisburg, P A 17110 (717) 234-2427 . ' Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO.O(,p - S $/>( CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY MARCELLUS MOORE, Plaintiff vs. CAMELLIA MOORE, COUNT I COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is MARCELLUS MOORE, an adult individual, sui juris, whose social security number is 184-48-9223, and who currently resides at 527 South 15th Street, Harrisburg, Dauphin County, Pennsylvania 17110, and has resided there since August of2006. 2. The Defendant is CAMELLIA MOORE, an adult individual, sui juris, whose social security number is 205-54-0679, and who currently resides at 301 Shepherd Lane, Shippensburg, Cumberland County, Pennsylvania 17257, and has resided there since October of 2005. 3. The Plaintiff has been bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 10, 1996, in Harrisburg, Dauphin County, Pennsylvania and separated on August 18, 2006. 5. There has been no prior action for divorce or annulment of the marriage between the parties hereto in this or any other jurisdiction. 6. Plaintiff avers that there are four (4) children ofthe parties under eighteen (18) years of age. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member on active duty ofthe Armed Forces of the United States of America nor any of its allies. 9. The Plaintiff avers that the grounds upon which this action is based is that the marriage is irretrievably broken. 10. 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. COUNT II COMPLAINT UNDER SECTION 3301(a)(6) OF THE DIVORCE CODE 11. All of the averments in Paragraphs 1 through 10 are incorporated herein as though each was set forth under Count II as in Count 1. 12. In the alternative, Plaintiff avers that the Defendant hath offered such indignities to the person of the Plaintiff, the innocent and injured spouse so as to render his condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant and for such further relief as the Court may determine equitable and just COUNT ill REOUEST FOR CHILD CUSTODY 13. All of the averments in Paragraphs 1 through 12 are incorporated herein as though each was set forth under Count ill as in Count I and Count II. 14. Plaintiff is Marcellus Moore, an adult individual, residing at 527 S. 15th Street, Harrisburg, Dauphin County, Pennsylvania 17110. 15. Defendant is Camellia Moore, an adult individual, residing at 301 Shepherd Lane, Shippensburg, Cumberland County, Pennsylvania 17257. 16. The subject minor children are MARCELLUS MOORE, II, born on February 21, 1992, being fourteen (14) years of age; MALIK A. MOORE, born on April 10, 1996, being ten (10) years of age; ESSENCE A. MOORE, born on March 3, 1998, being eight (8) years of age; and, MAHKI MOORE, born on March 1, 1999, being seven (7) years of age. 17. The relationship ofthe Plaintiff to the subject minor children is that of father. 18 . The relationship ofthe Defendant to the subject minor children is that of mother. 19. The aforementioned children are presently in the physical custody of their mother who currently resides at 301 Shepherd Lane, Shippensburg, Cumberland County, Pennsylvania. 20. Said minor children have resided at the following addresses since birth: ADDRESS DATE PERSONS RESIDED WITH 2118 N. 4th Street Harrisburg, P A Since birth to approximately October 2005 Mother and Father 301 Shepherd Lane Shippensburg, P A 10/2005 to 0812006 Mother and Father 301 Shepherd Lane Shippensburg, P A 08/2006 to present Mother 21. Plaintiff/natural father seeks full legal and primary physical custody of the subject minor children, Marcellus Moore, II, Malik A. Moore, Essense A. Moore and Mahki Moore. 22. Plaintiffhas not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the said minor children in this or another court. 23. Plaintiff has no information of a custody proceeding concerning the minor children pending in a court in this Commonwealth. 24. Plaintiff knows of no other person or party to the within proceeding who has physical custody of said minor children or who claims to have custody or visitation rights with respect to said children. 25. The best interest and welfare of the said minor children will be served by granting the relief requested because: a. Plaintiff/father is well able to adequately provide for the continuing health, educational needs and general welfare of the children; b. Plaintiff/father is well able to adequately provide the said children with a proper and wholesome environment, physically, emotionally, psychologically and socially, within which to live; c. Plaintiff/father is able to provide the said children with a safe and stable environment; d.. Plaintiff/father has been a primary caretaker of his four children since all of their births and loves them all deeply; e. It is, therefore, in the best interest of the said children that full legal and primary physical custody be granted to their natural father, Marcellus Moore, Plaintiff herein. WHEREFORE, Plaintiff, MARCELLUS MOORE, respectfully requests that this Honorable Court enter a Decree In Divorce: A. Dissolving the marriage between the Plaintiff and Defendant; B. Grant Plaintiff full legal and primary physical custody of the subject minor children; C. For such further relief as the Court may determine equitable and just. Respectfully submitted, BATURIN & BATURIN ~ " onica E. Baturin, Esquire ttorney I.D. No. 73356 (Attorney for the Plaintiff) 2604 North Second Street Harrisburg, P A 17110 (717) 234-2427 By: DATED: September 13, 2006 " .. . '. ' VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~~1~1(~ (SEAL) DATE: September 13, 2006 9 \....- ;r::"'.... -rJ (\~ rT~ ~'\ --;,.* ,-' ., r--' <:~:;l ,-:=." C~-... (/) \'...'1 .--, ...., -pC) ~ -4q. ~'\. - ~ 4..0 P - 0- lv . - 0 VI"" ~ Vl. ~ ~ C C'C> \ W -::t r~ ~ ,~~ ;--,,') (.}l ""'0 -;',' ..,.~.- o -rt -4 :r: :r:\ 0' t::. -f~\ I t 'H-}Y ;\~;~'; ~:-=J rn ~ :;J .- rG t.;':: (J) 0'. MARCELLUS MOORE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-5581 CIVIL ACTION LAW CAMELLIA MOORE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 17, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at MDJ }~1a'.llove, 1901 State ,~t., Camp l!!I!~~,_17011 on _,}'hursday, November ,02,2006 , the conciliator, at 11:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT. By: Isl Melissa P. Greevy, Esq. Custody Conciliator ~ I The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the couti, 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, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT HA VE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~c.v ?, cP1J'"' ~ go- L.I O( .~ tlLd '1/'- ~-~ 1(1-0-<11 p1"/" p/7t7 ~ 4<<;-,P1(l 100' (71 ~ ~~rr/ _ , .. (1') pn .j- '11 I ,J" . ' _.' i! I'" t- ." / I. ,'.... . I. \il'll ~_ .'. juG , ,------------ MARCELLUS MOORE, Plaintiff ) IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ) vs. NO. 06 - 5581 CAMELLIA MOORE, Defendant ) ) CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Monica E. Baturin, Esquire, of the Law Firm of Baturin & Baturin, attorneys for the Plaintiff in the above-captioned matter, do hereby certify that on October 23,2006, I deposited in the United States Mail, Harrisburg, Pennsylvania, an article of Certified Mail, Return Receipt Requested, a clocked-in copy of the Complaint For Custody and Order of Court attached thereto, bearing Article No. 7005 1820000276163321, addressed to:Ms. Camillia Moore, 301 Shepherd Lane, Shippensburg, Pennsylvania 17257. The said article of Certified Mail, as shown by the Postal Return Receipt Card, was received by the Defendant on October 26, 2006, and according to same, was signed, to wit: by Camillia Moore, which card is attached hereto and marked as Exhibit "A", along with the deposit slip dated October 23, 2006, for said article of Certified Mail aforementioned. BATURIN & BATURIN Date: October 30, 2006 B;-!>/fmj~ ~-~ L ~onica E. Baturin, Esquire Attorney I.D. # 73356 2604 North Second Street Harrisburg, P A 17110 (717) 234-2427 Attorney for Plaintiff r-"I ru rn rn ~ r-"I ~ l'- U.S. Postal Service".. CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) OFFICIAL us Postage $ .39 2.40 1 .85 // "~:E~R'~ '-" ~~, ';;/ ~ ~\ '. f\.j \ ,- \ "I c.u I'::' , "- ' ~' ru Cl Cl Cl Return Receipt Fee (Endorsement Required) Cl Restrfcted Delivery Fee ru (Endorsement Required) to r-"I Total Postage & Fees Certified Fee I \ ~. U1 Cl Sent To Cl I"'- MS. CAMILLIA MOORE ~2"::;XoTmSHEijHE'RD--iANEm_m_--mmmmm city,'sraili;ZiP;;j" 1))............. ..V.......... .......m........m..........n. . Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mall piece, or on the front If space pennits. 1. Article Addressed to: CAMILLA MOORE 301 SHEPHERD LANE SHIPPENSBURG, PA 17257 'j~.' -,tt 2. Article Number (rransfer from service IBbe/) PS Fonn 3811 , February 2004 3. ServIce Type RJ CertifIed Mall CJ Express Mall CJ Registered CJ Return ReceIpt for MerchandIse CJ Insured Mall CJ C.O.D. 4. Aes!ricted Delivery? (Extra Fee) 0 Yes 002 7616 3321 Domestic Return ReceIpt 102595-02-M-1540 EXHIBIT" A" ~~" ~g ~ r--:> = = <:::r> :z o <::: ...~) ='t: ~ ~-n rI1p: -ot;:Q ;~:i~:, -:~; ~~-~ __J ~lJ ..- r:? r-,J l , t . ... ... MARCELLUS MOORE, Plaintiff ) IN THE COURT OF COMMO PLEAS : CUMBERLAND COUNTY, PENNS LV ANIA ) vs. NO. 06 - 5581 CAMELLIA MOORE, Defendant ) ) CIVIL ACTION - LAW IN DIVORCE/CUSTODY AMENDED CERTIFICATE OF SERVICE I, Monica E. Baturin, Esquire, of the Law Firm of Baturin & Baturin, attorneys for the Plaintiff in the above-captioned matter, hereby file this Amended Certificate of Servic and certify that on October 23, 2006, I deposited in the United States Mail, Harrisburg, Pe nsylvania, an article of Certified Mail, Return Receipt Requested, a clocked-in copy of Complain in Divorce and Notice to Defend and Claim Rights along with a Count for Custody and rder of Court attached thereto, bearing Article No. 7005 1820000276163321, addressed to: s. Camillia Moore, 301 Shepherd Lane, Shippensburg, Pennsylvania 17257. The said article of Certified Mail, as shown by the Postal Return Receipt Card, as received by the Defendant on October 26,2006, and according to same, was signed, to wit: by Camillia Moore, which copy of said card is attached hereto and marked as Exhibit" A" along with a copy the deposit slip dated October 23, 2006, for said article of Certified Mail aforementioned. The original Postal Return Receipt Card and deposit slip were filed Court on November 1, 2006. Date: November 8, 2006 BAJt.~~~6 By: I ~L'-J.' I Monica E. Baturin, Esquir Attorney I.D. # 73356 2604 North Second Street Harrisburg, P A 17110 (717) 234-2427 Attorney for Plaintiff II , " It , '. r-i ru m m ..D r-i ..D f'- U.S. Postal Servicer... CERTIFIED MAIL., RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) OFFICIAL PostIge S . 3 9 Certified Fee 2 . 4 0 USE ru c:J c:J c:J RelIlm Receipt Fee (Endorsement Required) c:J RestriCllld DelIvery Fee ru (Endorsement Required) 00 r-i Total Postage & Fees /~ "":L?~ ;'''i ~ ..... f -...., T"ICIM'. ,.~.' ,..,.,;) ",:'\ c.." 1. 85 $ 4. 4 ,. ~ "" ~ U"l c::I c:J f'- . Complete Items 1, 2. and 3. Also complete Item 4 If Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. ArtIcle Addressed to: CAMILLA MOORE 301 SHEPHERD LANE SHIPPENSBURG, PA 17257 :r~/ '.'~?f 3. Service Type gJ CertlfIed Malt 0 ExpnIss Mail o Registered 0 Retum Receipt for M Ise o Insured Mall 0 C.O.D. 4, R~c:tecI Delivery? (Extra Fee) 0 Yes o 0 2 76 1 6 3 321 2. ArtIcle Number (Tmnsfer !tom service label) PS Form 3811. February 2004 Domestic Retum Receipt '~-M- 540 ' I EXHIBIT "A" (') !,-,,") '1 <::'"::) C c:.:.:.:> :Ti CT' I C') , ' ;->'-,,) , . :> f'V .,:.,....., .J...-' -... ,< ~ . NOV 1 a 2006 j 'A Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5581 CIVIL TERM CIVIL ACTION - LAW MARCELLUS MOORE, v. CAMELLIA MOORE, IN CUSTODY Defendant ORDER OF COURT AND NOW, this \ ~ ~" day of November, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Leaal Custody. The parties, Marcellus Moore and Camellia Moore, shall have shared legal custody of the minor children, Marcellus Moore, II, born February 21, 1992; Malik Moore, born April 10, 1996; Essence A. Moore, born March 3, 1998; and Mahki Moore, born March 1, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa.C.S. ~5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school night, and the like. 2. Physical Custody. The physical custodial time for the children shall be arranged as follows: A. So long as father is working second shift (2:00 p.m. until 10:30 p.m., Monday through Friday), Father shall have custody every weekend with the exception of his Army National Guard duty weekends. Father's custodial weekend shall commence after he gets off work on Friday night and continue until Sunday at 8:00 p.m. unless he has otherwise arranged with Mother to pick up the , . NO. 06-5581 CIVIL TERM children on Saturday morning. Father will give Mother notice of any change in plan as to the pick-up time. B. Father may have additional periods of partial custody arranged by mutual agreements of the parties. C. When Father does not have custody, Mother shall have custody. 3. No later than November 13, 2006, Father will provide Mother with a copy of his 2006/2007 National Guard schedule. 4. In the event that either party would want to move from the addresses indicated in the Complaint for Divorce, and the move would be such that the Parties would be at a distance greater than a one (1) hour drive from each other or would involve a change in school district for the children, the party desiring to move should provide the other parent with sixty (60) days written notice of their intended relocation and the reasons therefore. 5. During any period of custody or visitation the parties to this Order shall not possess or use controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 6. Neither party shall do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 7. Vacation. Each parent shall be entitled to vacation in accordance with the following schedule: A. June - One (1) week B. July - Two (2) weeks C. August - One (1) week, not to include the last full week before school begins. The parties shall provide with not less than sixty (60) days written notice of their intended vacation plans in order to avoid conflicting vacation schedules. In the event of a scheduling conflict, the parent first providing written notice should have choice of the vacation period. , . NO. 06-5581 CIVIL TERM 8. schedule. Holidavs. The attached holiday schedule shall supersede the regular BY THE COURT: J. Dist: Monica E, Baturin, Esquire, 2604 North Second Street, Harrisburg, PA 17110 Camellia Moore, 301 Shepard Lane, Shippensburg, PA 17257 I~~ /I. Il-- 0(, 9- :Ie! . ..-.=? v'~!nJ o I :01 ~,!V 91 l.m',1900Z AtJVICJi:C,i.LCSd 3H1 :10 ;:]IJiO-G311:J . - HOLIDAYS AND TIMES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday Memorial Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday Independence Day From 6pm the evening before the Mother Father holiday to 6pm the day of the holiday labor Day From 6pm the evening before the Father Mother holiday to 6pm the day of the holiday Thanksgiving From Barn Thanksgiving Day until Bam Father Mother the day after Thanksgiving Christmas From Barn Christmas Day until 12/26 Mother Father at Bam Mother's Day From 6pm the evening before the Mother Mother holiday to 6pm the day of the holiday Father's Day From 6pm the evening before the Father Father holiday to 6pm the day of the holiday Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5581 CIVIL TERM CIVIL ACTION - LAW MARCELLUS MOORE, v. CAMELLIA MOORE, IN CUSTODY Defendant CUSTODY CONCiliATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the children who is the subject of this litigation is as follows: NAME DA TE OF BIRTH CURRENTLY IN THE CUSTODY OF Marcellus Moore, /I Malik Moore Essence A. Moore Mahki Moore February 21, 1992 April 1 0, 1996 March 3, 1998 March 1, 1999 Mother Mother Mother Mother 2. Father filed a Divorce Complaint on or about October 13, 2006. A Custody Conciliation Conference was held on November 2, 2006 with the following individuals in attendance: the Father, Marcellus Moore, and his counsel, Monica E. Baturin, Esquire; the Mother, Camellia Moore, participated pro se. 3. Despite the significant tension between the parties, the parties were able to reach an agreement in the form of order as attached. Vlu.v /ljPf Dae elissa Peel Greevy, Esquir Custody Conciliator :286385 MARCELLUS MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-5581 CNIL TERM CAMELLIA MOORE, Defendant : CNIL ACTION - LAW : IN DNORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 25, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree in 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 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. 94904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. DATE:~ ~~W0 M '. C US MO (SEAL) () c: ? -ol~" rrlre ~if !<t. J>;~ ~ ~"._~j ._l,,-. ..... c_ ~ f"-..) = = ...... ~ ~-n m- hi ]39 i~g ~- ,t ,t-:u ;;;?o 2m 9 ~ ::Ii: :P"" :;:0 N N -0 :J: l')? \.0 MARCELLUS MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 06-5581 CNIL TERM CAMELLIA MOORE, : CIVIL ACTION - LAW Defendant : IN DIVORCE/CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 eCl 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 concerning alimony, division of property, lawyer's fees and 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 TO THE PENALTIES OF 18 PA.C.S. ~4904 TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: b21 \ctl en ~ ~ J1 VL- (SEAL) CELLUS MO (') c: s:: -ore fTHT' Z::r ~~: zt..~: eel -c 7 ~ I"'.:l (::;) = ~ ::lit ::0- ::::0 N ....~ -0 ::I; ~ o -n :e nl:D -oFT; :00 ~Cj ~-r} (:5 :!J zO (Sfl1 -I 3:i -< \D ... . MARCELLUS MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-5581 CIVIL TERM CAMELLIA MOORE, Defendant : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 25, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree in 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 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. ~4904 RELATING TO UNSWORN F ALSIFICA nON TO AUTHORITIES. DATE:' 1J3/ 0 C; /07 ( / (SEAL) ,..., g ~ ~ ~ '" rv C? c.: S. -oeD rnni 7-') &/~. ~- ' r:::;C ""':..- ~... '---'1 %Cl YC: ~ -0 -:r; ~ ~""1 " -f:: -of11 --R c;:> ?5~ ""$.A g' '2' ~ ~ - u:r- . .' "- 'r MARCELLUS MOORE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY~ PENNSYLVANIA VS. : NO. 06-5581 CIVIL TERM CAMELLIA MOORE, : CIVIL ACTION - LAW Defendant : IN DIVORCE/CUSTODY 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 concerning alimony~ division of property, lawyer's fees and 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 TO THE PENALTIES OF 18 PA.C.S. ~4904 TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE:J t3/t 'I /t21 ( I (SEAL) o c s: -rJ i~: 0'; f.;' :;~ .?- ~, ~~:~; ~::(".? 5:.,:-() ::;.., (,:: -" ,.;.. ::;! f"'-) <:::::> 5 :x SO N N ~ ~:!l M=i ~~ -:: ~11~ (':J (') 2m ~ ~ ~ -0 :x N ., \oD IN THE COURT OF COMMON PLEAS MARCELLUS KX>RE, Plaintiff VS. CAMELLIA ~, Defendant CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 06-5581 CIVIL TERM 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) I.tirti~(iYrlYWti.JirJ:JItJiil. (Strike out inapplicable section). Date and manner of service of the complaint: Defendant was served by Certified Mail and personally signed for same on October 26, 200 I . . 2. 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 March 19, 2007 ; by defendant March 9, 2007 (b) (1) Date of execution of the affidavit required by ~3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: No claims pending 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 of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: March 22, 2007 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: March 22, 2007 Date: March 21, 2007 ., ~ (") ~ c. ....... ~ ~8:; L_,,'c Zl:'" ~,!> ~ $=(=: :;;:~ z =z ::J: > :::0 N N ~ -I :t::n mFn :By 00 ...-I..,., I-n qo Om ?E -< -0 :x ~ "" ~~~~ ~ ~~ ~ ~~~ ~ ~~~~~~ ~ ~~~~ ~~~ ~~~~ ~~~~~~~ ~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY 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; STATE OF PENNA. Marcellus Moore Plaintiff No. 06-5581 VERSUS Camellia Moore Defendant DECREE IN DIVORCE AND NOW, ~~ Z--'1 ~ 2007 DECREED THAT MARCELLUS ~ AND CAMELLIA ~ ARE DIVORCED FROM THE BONDS OF MATRIMONY. None ~~~~~~~~~~~~~~~~~~~~~~~~~~ ~~ ~~~~~ ~~~~~~ ~~~ ~ Civil Tenn IT IS ORDERED AND , PLAI NTI FF, , DEFENDANT, J. PROTHONOTARY _ .;Ir !/- ~ ~ (O!;e'L ~<;r r -1- ~ ~F"'J LiJ- be , . .. , . ,'" "t'''; '. .. ~ . .;';" Ie, ~..# .' ,,' '"..