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Home My WebLink About06-6399ALICIA D. DELL, VS. JASON DELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Term : ACTION IN DIVORCE Defendant 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. 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 at 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 ALICIA D. DELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. b4-63-9q Civil Term JASON DELL, ACTION IN DIVORCE Defendant : COMPLAINT IN DIVORCE 1. Plaintiff is Alicia D. Dell, a competent adult individual, who has resides at 6 East King Street, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. Defendant is Jason Dell, a competent adult individual, who resides at 6 East King Street, Shippensburg, Cumberland 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. The Plaintiff and the Defendant were married on October 5, 2002 in Shade Gap, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers 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. r, A Alicia D. Dell, Plaintiff Respectfully submitted, Date: lb . A5 .. Q J Adams, Esquire . No. 79465 4 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 1? ) V cv h.? rms-, r V jri ALICIA D. DELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 06 - 6399 Civil Term JASON DELL, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this November 24, 2006, I, Jane Adams, Esquire, hereby certify that on or about November 15, 2006, a certified true copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT was served, via certified mail, return receipt requested, addressed to: Jason Dell ¦ Complete Items 1, 2, and 3. Also complete 6 E. King St. item 4 If Restricted Wivery Is desired. Shi ensbur Pa 17257 ¦ Print your name and address on the reverse pp g, . so that we can return the card to you. ¦ Attach this card to the hack of the mailplece, DEFENDANT or on the front if space permits. 1. Article Addressed to: ,7%70'7 T)-LTi 1715 7 A. X 13 Agent ?^- 0 Addressee B ived by (Printed Name) C. Date of Delivery igscw Dd D. Is delivery address different from item 1? ? yes If YES, eater delivery address below: `Mo 100 Type Mal 0 EW*n Mall istered 13 Refum Receipt for Merr ha wbe ? Insuted Mal 0 C.O.D. -- 2. MArticle Number araAsr ftm fiom serrk+e Asbe (Iians 7004 1350 0003 7147 1571 - J ,_ - Ps Form 3811, February 2004 Domestic Return Receipt 102595.02.M-1540 Submitted: Jane dams, Esquire I.D o. 79465 64 uth Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?-- ?;-, ' = - r ? rtS, " ? , ._..t i, _ _ : +r'Y' '. LY. . £? ?. ??' . 6, t.?""r ALICIA D. DELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 6399 Civil Term JASON DELL, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 2, 2006 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. the decree. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of 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: 1 Z 67 20&V Jaso ell, De en an WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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 t u worn falsification to authorities. Date: J Dell, Defendant ??? ' ? ? ? ? - . Vin c ? ,. + -... ,,, '? ?,?_?_? ? --t W ALICIA D. DELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 06 - 6399 Civil Term JASON DELL, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 2, 2006 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. the decree. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of 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: d4o.- i Alicia D 1 ti .Del , Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND §3301(d) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. 1 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. 1 understand that l 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 unswom falsification to authorities. Date: a 3Alicia D. Dell, Plaintiff ': ,' ` ern ALICIA D. DELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 6399 Civil Term JASON DELL, ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please 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: Certified mail, restricted delivery, return receipt requested, served November 15, 2006. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: By Defendant 12/31/2007 12/07/2007 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 18, 2007. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 9, 2008. Date: /(0 Q 8, Respectfully SubAitted: a Adams, Esquire . No. 79465 VS. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ? ? ? r7 -ri? ? T s < ` ' -- _? t r,: t ;. fem. ? . _ ? .? ?; tt9 AL 11% IN 11% lik It III, re IN THE COURT OF COMMON PLEAS + OF CUMBERLAND COUNTY + + + STATE OF PENNA. + Alicia D. Dell, Plaintiff =y N + No. 06 - 6399 Civil Term + + + NO. + + + + + + + VERSUS + Jason Dell, Defendant + + DECREE IN + + DIVORCE + + + + + AND NOW, ?owJ0.v y 110A IT IS ORDERED AND + + Alicia D. Dell + DECREED THAT PLAINTIFF, Jason Dell + AND 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 THE COURT: + ?* I + ATTEST: J + a !? a + PROTHONOTARY + + + + + + 'PIP! V I -V! 4 wt It $1 W11 I It 1. i v . ?/ / ,y(- ill ,/