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Home My WebLink About06-6109 DAVID C. CAREY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO.&. -(,idf CIVIL TERM v. NANCY J. CAREY, Defendant : IN LA W - 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 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 grounds 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, First Floor, Cumberland County Courthouse, 1 Courthouse Square, 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. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 DAVID C. CAREY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 0- - ~IO'f CIVIL TERM v. NANCY J. CAREY, Defendant : IN LAW - DIVORCE COMPLAINT IN DIVORCE AND NOW COMES the Plaintiff, DA VID C. CAREY, by his counsel, William L. Grubb, Esquire, and complains of the Defendant, NANCY J. CAREY as follows: COUNT I COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is DAVID C. CAREY, who currently resides at 322 Somerset Drive, Shiremanstown, Cumberland County, Pennsylvania, 17011. 2. Defendant is NANCY J. CAREY, who currently resides at 130 Victoria Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on October 22, 2005, at Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither party is in the Armed Services of the United States or its allies. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving the marriage between the parties. Respectfully submitted, Date:O~ llel ~lo ~~~~~~ ' J.D. # 72661 3803 Gettysburg Road Camp Hill, P A 17011 (717) 763-5580 Attorney for Plaintiff . . VERIFICATION r, DA VrD C. CAREY, verify that the statements made in this document are true and correct. r understand that false statements herein are made subject to penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Date: /r;6'" ac.~ David C. Carey, Plaintiff ' C) ~ ~ t :<s 8 0 . .lJ ~ -- ~ - ......, ~ ..t ~ ~ c::::t <::::I 0'" ~:n ~ 0 rROJ n w ,..,,~ ~Fn z[:b --I f' ~ ~I,;:: ex> 06 {J)"'c" -<.e_ =ri -;, kCi -0 ...,- :!J Q?ri ~ ~c; :x is 0 c: .s::- -.:..j Z .. ~ =< \D Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DAVID C. CAREY, v. : NO. 06-6109 CIVIL TERM NANCY J. CAREY, Defendant : IN LA W - DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING DAVID C. CAREY, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in COU..11seling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of Pa. C.S. ~4904, relating to unsworn falsification to authorities. (Nt David C. Carey, Plaintiff 2 s:. ..,..}rc.:-' rnr' ---;7 ~-:-. ~~t~-. o'..~.. .....'.... ~-~ t;:~'~, -~ - ~t;' ;.,:_- 5;!~~ 3 g <:f' o (J _\ V' o ""0 ::1' ;"~ ~ :?'-n fn~ :Do ("~~21 Q. ~y: ~4 "'; r::?() ::'0, ,11 ~ ~ t:? (:::) s- Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DAVID C. CAREY, v. : NO. 06-6109 CIVIL TERM NANCY J. CAREY, Defendant : IN LAW - DIVORCE ACCEPTANCE OF SERVICE NCM\c.-'f j. $+OLo..t I, Nancy J. Carey, a.k.a. ~JaAey L. itgut, accept service of a copy of the above captioned COMPLAINT IN DIVORCE. IJ~ (PI Z()O~ Date Y\~ ~Ce^Q-1 Nancy J. Ca ~~ :;C OJ\c..y J. 0 L... -\- 130 Victoria Drive Mechanicsburg, PA 17055 ~ C~ <:=> <::1'"' o .1 --1 :r rfiE ~.!~ :=.?: ~ """"'- w -;:.1 ..t..- w Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DAVID C. CAREY, v. : NO. 06-6109 CIVIL TERM NANCY J. CAREY, Defendant : IN LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 18, 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 the 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 falsification to authorities. Date:&/' ~ ,)0,7 f <2u~' ~. -? ~ C c-. Daviv C. Carey, Plaintiff o c S -0 OJ nic;' ~:~. ~,~.. ~C, ~i~~~ Z Sl "'" g --J ....." ~ N N -0 3 N .. v:> '" ~ ~~ J5t9 06 =:i -T, =.L :!J 00 ::"!:..rn o ~ ~ DAVID C. CAREY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6109 CIVIL TERM NANCY J. CAREY, Defendant : IN LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST DIVORCE DECREE UNDER 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 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: (f;B. t I ~f1~'1 (-'/ . /,:,/ C! 'David C. Carey, () I'.) ~ = C <::::I ~ ...... ::". '"Tl ~ "TJCD CfJ f~p fTl ", :JJ ~-"."",". 0;, r- _;":.~: i" N :rJ~ (/) ) _..::1 N 6 !:-: ---l ::;l -~'j- -r~ ~E -0 (0- :u ::It "~ C') )>c: ~ om -~ ~ ~ w '" -< Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DAVID C. CAREY, v. : NO. 06-6109 CIVIL TERM NANCY J. CAREY, Defendant : IN LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 18, 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 the 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 falsification to authorities. Date: ~ - \t-rn ~ ~cy ~J~\~rS; AD~kndant () ~ ~'- -UiXi mfr Z.~:~ -7; (n,... ~'.:l ;<:: ~i:=: -!"",;o. I"-~- "'Z ~ ......:> c::;:> ^C::::>> --.I -:"I'l rn CO N N ~ ~:n --chi ::at? S~Q '-r'& 11 -~-n ';)- '~7~ ~~ ?E ~ -0 :r: N .- W U) DAVID C. CAREY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6109 CIVIL TERM NANCY J. CAREY, Defendant : IN LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST DIVORCE DECREE UNDER 3301 te) 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 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. 94904 relating to unsworn falsification to authorities. Date: d.-lie> - 0'1 '{\<>~~('~ Nancy J~ rey, Defendant ~ ~.. '"11f:9 ITlr'c ~:t~~' (.0 , ;::::. ~ ~~ :;; ~ -T1 f'T\ OJ N N -0 ~ ~ ~~ -o~ -rJ 'L C-?o :~r! :r; (-j -C.") -.7m t~ J:::: ~ N .- w \J:) Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DAVID C. CAREY, v. : NO. 06-6109 CIVIL TERM NANCY J. CAREY, Defendant : IN LAW - 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 13301 (c)of the Divorce Code. 2. Date and manner of service of the complaint: 11/06/2006, Acceptance of Service; filed 11/13/2006 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by Plaintiff February 6, 2007 by Defendant February 16, 2007 4. Related claims pending: NONE 5. Complete either (a) or (b). (b) Date plaintiff's Waiver of Notice in 93301 (c) was filed with the Prothonotary: February 22, 2007 Date defendant's Waiver of Notice in 93301 (c) was filed with the Prothonotary: February 22, 2007 Date: m 2k~~" l ~i~q:.,~ - 1.0.72661 3803 Gettysburg Road Camp Hill, PA 17011 Attorney for the Plaintiff (717) 763-5580 f""..;) = = ~ ..." f'T1 OJ N en o .." ~.." m- r- -om -::nCl (JI ,,'lCl S?~ ,3m ~ ::0 -< W I..D IN THE COURT OF COMMON PL AS OFCUMBERLANDCOUNTY STATE OF PENNA. DAVID C. CAREY, No. 06-6109 Plaintiff VERSUS NANCY J. CAREY, Defet ,dant DECREE IN DIVORCE AND NOW, r ~b~u~-r,\ 1/ David C. Carey , 100), IT IS OR DECREED THAT Nancy J. Carey , PLAI AND ANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS t lCH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORD HAS NOT YET BEEN ENTERED; . NONE NOTARY '~ ,,' ~~~~~~~~~~~~~~~~~~~~~ ~~~~~ ~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~ J. -rh' 'J ~ ~w, L.O- 1-[' tr'f7' f;: 7 ~'~ ~ LV' 1-c , , . .'..'" .. . ~'t'."/. --------