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Home My WebLink About06-6166HEATHER R. WHITE, IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2006 - (p) (e L CIVIL TERM DANEYON S. WHITE, Defendant. IN DIVORCE NOTICE 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 in 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 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 Courthouse, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 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 must attend the scheduled conference or hearing. HEATHER R. WHITE, Plaintiff, V. DANEYON S. WHITE, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2006 - CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C) AND JM OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Heather R. White, by and through her attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Daneyon S. White, representing as follows: 1. The Plaintiff is Heather R. White, an adult individual residing at 125 Third Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant is Daneyon S. White, an adult individual currently residing at 2 Stonegate Lane, Derry, New Hampshire 03038. 3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on November 21, 2003, in Sudbury, Massachusetts. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. Dated: October 23, 2006 By: Respectfully submitted, IRWIN & McKNIGHT C? Esquire Suprem Court I.D. No. 25 76 West Porn Professional ildin 60 West Pomfret treet Carlisle, Pennsylvania 17013-3222 (717) 249-2353 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Wj? G HEATHER R. WHITE Date: October 23, 2006 HEATHER R. WHITE, Plaintiff, V. DANEYON S. WHITE, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2006- CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's Office, 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: October 23, 2006 HEATHER R. WHITE ?., 0 <-n -n -? rn - Q? - F -77 Lo 7 ` GJ -- i I=mo :;7 r . w HEATHER R. WHITE, Plaintiff, V. DANEYON S. WHITE, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2006 - 6166 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA . . SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Daneyon S. White, on October 27, 2006, by certified, restricted delivery mail, addressed to him at 2 Stonegate Lane, Derry, New Hampshire 03038, with Return Receipt Number 7004 3150 0003 7289 2528. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of a. C.?ction 4904, relating to unsworn falsification to authorities. ?--? 3 A. McIf NTgHT, III, ESQUIRE for Plai tiff Date: October 31, 2006 s ? v CO ru Ln ru Er CO I'L i r- m C] O 4 4 tJ) M rq O 0 N Total Postage & Fees ¦ Complete Items 1, 2, and 3. Also,complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so d-wfe_s,kiAtu . the card to you. ¦ Attach this 4 ?d to the back of the mailplece, or on the frog space permits. 1. ArticleAd;;-,;;to: Mal: DANOMW S WHITE ?AFtY l?Ay 2 STONEGATS LANE DERRY NH 03038. Oct A. Agent B. Recelved-by O" tad Name) C. Date of Delivery D. Is delivery aciresa different from item 1? 0 Yes If YES, enter delhwy address below: 0 No 3. Service Type 0 Certified Mali 0 Express Mali 0 Registered JR Return Receipt for Merchandise 0 C.O.D. IOWMdjd@L 4. Restricted DeNveryi' (Ebbs Fee) es 2. Article Number 7004 1350 0003 7289 2528 Mwalbr fYom smom lrbef) PS Form 3811, February 2004 Domestic Ratan Reosipt 102595-02-W ISO '" C 7 t _l rt.. y l i _ -_ /L ? rn HEATHER R. WHITE, Plaintiff, V. DANEYON S. WHITE, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2006 - 6166 CIVIL TERM IN DIVORCE STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiff intends to proceed with the above-captioned matter. Respectfully submitted, IRWIN & WKNIGI?'jf, P.C. By: Marcus. McKn li III, Esquire Suprem Court I.D. No: 25476 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Date: October 27, 2009 FILED-OFFICE OF THE F9011'HO DTARY 2009 OCT 27 PM 2: 46 CUNT E::r f? r, d r C;,)IjN Y PENK,i LVANIA David D. Bueff Prothonotary Y,irkS. Sohonage, ESQ, Solicitor ;'f Cr. Knee X. Simpson rl Deputy Prothonotary o 11, Irene E. 96rrow 2" d ,Deputy Prothonotary Office of the Trothonotary Cumberland County, Pennsy(vania OID-- twWr CIVILTERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 30TH DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P. 230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, -4 17013 • (717 240-6195 o Fa.A? (717 240-6573