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Home My WebLink About06-6017NOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. JOSEPH R. WHITE, NO. Caen - 60/7 CIVIL TERM Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301 c OF THE DIVORCE CODE NOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO.Cla- 1,()17 CIVIL TERM JOSEPH R. WHITE, : 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, 1 Courthouse Square, Carlisle, Pennsylvania 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 LEGAL HELP. Cumberland County Bar Association NOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO.OL - ??a CIVIL TERM JOSEPH R. WHITE, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Noel M. Burch, an adult individual who is sui juris and resides at 512 Appalachian Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Joseph R. White, an adult individual who is sui juris and resides at 7068 Beavers Spring Road, Harrisburg, Dauphin County, Pennsylvania 17111-4795. The present whereabouts of the Defendant, Joseph R. White, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 5, 2002 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. TUCKER ARENSBERG, P.C. By: Sandra L. Meilton No. 32551 P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorney for Plaintiff VERIFICATION 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. Section 4904, relating to unsworn falsification to authorities. Noel M. Burch Dated: o --5- 0& 78466.1 o C- ) N 71 t NOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 06-6017 CIVIL TERM JOSEPH R. WHITE, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF DAUPHIN ) AND NOW, this day of 2006, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Gloria M. Rine, paralegal to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on October 18, 2006, she mailed a certified copy of a Complaint in Divorce to Joseph R. White, 7068 Beavers Spring Road, Harrisburg, PA 17111-4795, by certified mail no. 7004 2890 0002 8004 6754, return receipt requested, and the same was received on October 20, 2006 by him, as indicated by the return receipt card which is attached hereto. Gloria M. Rine Sworn to and subscribed before me this ? ` day of 2006. Notary Public (SEAL) N--oT?-sEN MICHELE KUSERY-GRAN Notary PublIC C11Y OF C=Wftdon E>WRINSKMG. DAUPHIN COWN MY pMu Nov 6.2x0? 4 ?-T - • - Ln (Domestic Mail Only; No Insuran ce Coverage Provided) 0 For delivery information visit our we bsite at WWW.L C3 ca Postage $ ru certified Fee Q Pos C3 r-3 Return Receipt Fee (Endorsement Required) 0 Here Er Restricted Delivery Fee (Endorsement Required) CO rU Total Postage & Fees $ - -I ° C3 Sent To JOSEPH R. WHITE - ------- -- - N .... Street Apt. No.; orPOBox^b•7068 BEAVERS --------- .... - SPRING ROAD .......................................... -- - cm TRISBURG PA 1711 ¦ Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. X ¦ 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 mailpiece, or on the front if space permits. 1. Article Addressed to: MR. JOSEPH R. WHITE 7068 BEAVERS SPRING ROAD HARRISBURG PA 17111-4795 3. by (Printed Is If ao ar r' - -r > a C. Date of Delivery from gem 1? ? Yes as below: ? No CkCert e ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. Restricted Delivery? (Extra Fee) )Yes 2. Article Number (lranswf mservice1abW) 7004 2890 0002 8004 13754 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 I r-a C7 _Y'5 ^t1 cr- w Sandra L. Wilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 6574795 smeilton a,dzmmglaw.com NOEL M. BURCH, JOSEPH R. WHITE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 06-6017 Civil Term. CIVIL ACTION - LAW Defendant IN DIVORCE 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 SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about June 29, 2005 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: q 1!3 9 q 0 Noel M. Burch, Plaintiff 1 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 or (800) 990-9108 Sandra L. Meilton, No. 32551 Quintina M. Laudermilch, #94664 Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive, Harrisburg, PA 17109 Attorney for Plaintiff Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton _dzmmglaw.com NOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. JOSEPH R. WHITE, : NO. 06-6017 CIVIL TERM 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, 1 Courthouse Square, Carlisle, Pennsylvania 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 LEGAL HELP. Sandra L. Wilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton@dzmmglaw.com NOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. JOSEPH R. WHITE, : NO. 06-6017 CIVIL TERM Defendant : IN DIVORCE AMENDED COMPLAINT UNDER SECTION 3301(c) and 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Noel M. Burch, an adult individual who is sui juris and resides at 316 Berkshire Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Joseph R. White, an adult individual who is sui juris and resides at 7068 Beavers Spring Road, Harrisburg, Dauphin County, Pennsylvania 17111-4795. The present whereabouts of the Defendant, Joseph R. White, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 5, 2002 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. Ninety (90) days has elapsed from the date of the filing of this Complaint. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on or about June 29, 2005 as evidenced by the Marital Settlement Agreement entered into by them on that date. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. Respectfully submitted, Date: Lto Lo 7- Daley Zucker Meilton Miner & Gingrich, LLC By: andra L. Meilton, Esquire, #32551 Quintina M. Laudermilch, Esquire, #94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff VERIFICATION I verify that the statements made in this Amended Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. ?]=D Noel M. Burch Dated: T Id- 07 CERTIFICATE OF SERVICE I, Jennifer L. Carl, Paralegal, hereby certify that on this Vday of 2007, a true and correct copy of the Amended Complaint was served upon the Defendant, Joseph R. White, by United States Mail, Certified, Postage pre-paid, to the following address: Joseph R. White 7068 Beavers Spring Road Harrisburg, PA 17111-4795 Defendant/Pro Se Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC By: Of, J if r L. Car , P gal 10 cenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 T?f ? I .? =ol Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeiltonCaD-dzmmglaw.cornNOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 06-6017 CIVIL TERM JOSEPH R. WHITE, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF DAUPHIN ) / -) AND NOW, this ! day of Opersonally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Jennifer L. Carl and Gloria M. Rine, Paralegals employed at Daley Zucker Meilton Miner & Gingrich, LLC, who being duly sworn according to law, depose and say that on July 17, 2007, Jennifer Carl mailed a time stamped copy of the Amended Complaint in Divorce, time stamped copy of Plaintiffs Section 3301(d) Affidavit and a blank Counter-Affidavit to Joseph R. White, 7068 Beavers Spring Road, Harrisburg, PA 17111-4795, by certified mail no. 7004 2890 0001 3911 0629, return receipt requested. See return receipt card which is attached hereto; copy of said July 17, 2007 letter and the U.S. Postal Service Certificate of Mailing evidencing the mailing of the copy of the said letter by "confirmed delivery". Attached hereto is a copy of the U.S. Postal Service Track and Confirm Search Results for the above certified mail, confirms that notice was left for Joseph R. White on July 18, 2007. On August 8, 2007, Mrs. Rine spoke with a U.S. Postal Service employee at the Derry Street, Harrisburg, PA Post Office, who confirmed that since section (c) Date of Delivery section of the return receipt card was not completed by the recipient or a U.S. Postal Service employee, that the date of service would be on or before July 20, 2007 inasmuch as the: "HARRISBURG PA 171 20 July 2007 PM 4 L" stamped at the top of the Sender side of the attached return receipt card (copy attached) was affixed at the Crooked Hill Post Office on or after the delivery section of the card was completed. Therefore, service of the documents was established on or before July 20, 2007. J nn' er L. CaH \J Gloria M. Rine to and subsqrjbed me thiday ?l V t?s .2007. Public (SEAL) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL PATRICIA A. PATTON. Notary Public Lower Paxton Twp., Dauphin County Commission Expkes June 20, 2010 J KATHLEEN CAREY DALEY, ESQ. PATRICIA CAREY ZUCKER, ESQ. SANDRA L. MEILTON, ESQ. STEVEN P. MINER, ESQ. KATHLEEN MISTURAK-GINGRICH, ESQ. LINDSAY GINGRICH MACLAY, ESQ. QUINTINA M. LAUDERMILCH, ESQ. PATRICIA A. PATTON OFFICE ADMINISTRATOR July 17, 2007 VL4 CERTIFIED MAIL Joseph R. White 7068 Beavers Spring Road Harrisburg, PA 17111-4795 Re: Burch v. White Dear Mr. White: Enclosed please find a time-stamped copy of the Amended Complaint in Divorce and Plaintiffs Section 3301(d) Affidavit. Also enclosed is a blank Counter-Affidavit. Very truly yours, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC (Jei2n3fer L. Carl, Paralegal JLC REPLY TO: Enclosures EAST SHORE OFFICE cc: Joseph R. White, Confirmed Delivery (w/enclosures) Noel M. Burch U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: 13 7l X I One piece of ordinary mail addressed to: sJ- ?, lAh, fe ? ? lb at " ?[ 17il ! - L! 79,x ' PS Form 3f177, January 2001 W U) a - n C7 0 Lf p 1m °. Mm L00?f" bH 1f r"' 199 Io7 .tld EAST SHORE: 1029 SCENERY DRIVE, HARRISBURG, PA 17109 - 717-657-4795 - 717-657-4996 FAX WEST SHORE: 1035 MUMMA ROAD, SUITE 101, WORMLEYSBURG, PA 17043 - 717-724-9821 - 717-724-9826 FAX USPS - Track & Confirm W -P UAfITEDST/1TES MAL SEWCE- Track & Confirm Search Results Label/Receipt Number: 7004 2890 0001 3911 0629 Detailed Results: • Notice Left, July 18, 2007, 4:08 pm, HARRISBURG, PA 17111 • Acceptance, July 17, 2007, 5:15 pm, HARRISBURG, PA 17112 r ack (M p U$r Page Home 18"1 I S n in Track & Confirm FAQs Track & COn ?m Enter Label/Receipt Number. cation options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. ifC?i ; ® POSTAL INSPECTORS site map contact us government services jobs National & Premier Accounts Preserving the Trust Copyright O 1999-2004 USPS. All Rights Reserved. Terms of Use Privacy Policy http://trkcnfrml.smi.usps.com/PTSIntemetWeb/InterLabelDetail.do 8/9/2007 CERTIFIEC (Domestic Mail Or a n- m $ r•9 M Certified Fee O o m ui (End red) en Req O Restrbted Delivery Fee ? (Endorsement Required) r u C- ' ; C 'r ? •? ?ut+- ice' %9, Total Postage & Fees Q nto U y? p M1 or P------ xo `, -- ------------ 1-1t1 - ¦ 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 ma)Ipieoe, or on the front ff space permits. 1. Article Addressed to: spring pg ?-7 L/ 7A-1 9 A. X r .1 ? Agent B. Received bj (Prt rfed Name) G. Date of Delivery D. Is delvery a*km dinerern from kem 1? ? Yes If YO, enter delivery address below: ? No 3. TA*l cwffW ? Express Mail ? egistere ? Return Reoelpt for M&ThwWbe ? Insured Mil ? C.O.D. 4. PAd&ied DeNlvery'i P ft Fee) O Yes M` 2' ArWe gy'm (TfwMw 7004 2890 0001 3911 0629 ar?sli?r from servlw irbe? PS Form 3811, FeWtwy 21)04 Domestic Rd= Reoeipt 102595-02-M-1540; t UNITED STAT' ;?t?3?L g? `G ?'A 1r' ? -crate, ? JIM . 037 Pit 4 • Sender: Please print your name, address, and ZIP+4 in this box • ?-L-C'2 ( 02 N?.mS.bur(I , rL\) b-I Iftt??}tttitffitt?tfrtt?ttliflttt??ftfllitrlt?ffitilfltttflftl C? ,;._ __,, .-t ?? 1. _ ? ?ry?w t ???> _ [ ?? _ // }} 4??1 f? /% fr Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smei ItonAdzmmglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOEL M. BURCH, Plaintiff No. 06-6017 Civil Term CIVIL ACTION - LAW JOSEPH R. WHITE, Defendant IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF 43301(d) DIVORCE DECREE To: Joseph R. White, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the §3301(d) affidavit. Therefore, on or after September 7, 2007, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 INFROMATION 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 OFFIER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 or (800) 990-9108 j NOEL M. BURCH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 06-6017 Civil Term CIVIL ACTION -LAW JOSEPH R. WHITE, Defendant IN DIVORCE uo?_Aopy 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(d)(1) of the Divorce Code. 2. Date and manner of service of Complaint: Certified mail, October 20, 2006 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 ; by defendant (b)(1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: July 3, 2007 ; (2) Date of filing and service of the plaintiffs affidavit upon the respondent: . filed on July 13, 2007; mailed on July 17, 2007; served on or before July 20 2007. 4, Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: _ August 17, 2007, first class mail (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: Date Defendant's Waiver of Notice was filed with the Prothonotary: Sandra L. Meilton, No. 325'51 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Gloria M. Rine, Paralegal, hereby certify that on this 17th day of August, 2007, a true and correct copy of the Notice of Intention to Request Entry of Section 3301(d) Divorce Decree with attached copy of Praecipe to Transmit and a blank Counter-Affidavit was served on Joseph R. White, by first class United States Mail, Postage pre-paid, to the following address: Joseph R. White 7068 Beavers Spring Road Harrisburg, PA 17111-4795 Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC By: - Gloria M. Rine, Paralegal 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 (P rs l f s? z",g d/ Cs' ) SANDRA L. MEILTON, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton0dammzlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOEL M. BURCH Plaintiff No. 06-6017 Civil Term CIVIL ACTION - LAW JOSEPH R. WHITE, Defendant IN DIVORCE PRAECIPE PROTHONOTARY: Please withdraw the appearance of Arensberg, P.C. as counsel for the Plaintiff L. Meilton, Esquire, of Tucker DATED: O FN s G. MorganU quire ER ARENSB RG, P.C. . Front Street, P.O. Box 889 arrisburg, PA 17108 17) 234-4121 Please enter the appearance of Sandra L. Meilton, Esquire, of Daley Zucker Meilton Miner & Gingrich, LLC, as counsel for t e Plaintiff. andra L. Menton, quire, I.D. 32551 Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive r Harrisburg, PA 17109 Dated: [ ?? ?` (717) 657-4795 y CA) cs? NOEL M. BURCH, V. JOSEPH R. WHITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6017 Civil Term CIVIL ACTION -LAW Defendant 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(d)(1) of the Divorce Code. 2. Date and manner of service of Complaint: Certified mail, October 20, 2006 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 ; by defendant (b)(1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: July 3, 2007 ; (2) Date of filing and service of the plaintiffs affidavit upon the respondent: filed on July 13, 2007, mailed on July 17, 2007, served on or before July 20, 2007. 4, Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: August 17, 2007, first class mail (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: Date Defendant's Waiver of Notice was filed with the Prothonotary: Sandra L. Menton, No. 32551 Attorney for Plaintiff tlt t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. NOEL M. BURCH VERSUS JOSEPH R. WHITE No. 06-6017 DECREE IN DIVORCE , P 1 *PW7 AND NOW IT IS ORDERED AND DECREED THAT NOEL M. BURCH AND JOSEPH R. WHITE ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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. PROTHONOTARY LL,2-