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Home My WebLink About06-6546• _ ., SHELBY R. JONES, Plaintiff vs. BRIAN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. ~ ~ - ~~L ~' IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set fa~rth in the foregoing pages, you must take prompt action. You are warned that if you fail to db so, the case may proceed without you and a decree in divorce or annulment maybe 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 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 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 SHELBY R. JONES, Plaintiff vs. BRIAN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. L'~ ~ - ~ S'~( IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. SHELBY R. JONES, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANXA CIVIL ACTION -LAW NO. O ~ _ ~ .S``/ (o BRIAN R. JONES, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, SHELBY R. JONES, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is SHELBY R. JONES, an adult individual who currently resides at 355 Martingale Drive in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is BRIAN R. JONES, an adult individual who currently resides at 355 Martingale Drive in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 13 January 1996 in Camp Hill, Cumberland County, County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. ~, COUNT I -IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. ~```S~amuel L. An s Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). `/ Date: /(? 3b D(o SHELBY R. O S w s~ ~~ ~~ ~r r- ; t~._t c :s -.__a _~. ~:u ~., r.;.~. _) ~~ -~-~ --.- -t ~- ,.,~; :a _~ .~ SHELBY R. JONES, Plaintiff vs. BRIAN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE AGREEMENT AS TO VENUE The undersigned, being both parties to the above-captioned action, hereby stipulate and agree that this action may proceed before the Court of Common Pleas of Cumberland County, Pennsylvania, and waive their rights under the Pennsylvania Rules of Civil Procedure, to challenge or object to venue before that court. ;; s Shelby R. Jo es, intiff ~..~ ~~ 1 Brian R. Jones De endant ~~~~ ~ Z~b i SHELBY R. JONES, Plaintiff vs. BRIAN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. IN DIVORCE STIPULATION AND NOW come the above-named parties and stipulate and agree that this matter, for the convenience of the parties and witnesses, shall proceed before the Court of Common Pleas of Cumberland County, Pennsylvania, and each of the parties does hereby waive their right to challenge or otherwise object to the venue of that court under Pa. R.C.P. 1815.2. A j ~ ~~ Shelby R on laintiff Brian R. Jones, e ndant c"~ :~ c~ `--_~ -~ - r-i _ ._r~. T _ ~~ _-.' r ~ _ L.' ... ~ ~: .... ^{ rl ~~ SHELBY R. JONES, PLAINTIFF vs. BRIAN R. JONES, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED MAIL AMY M. HARKINS, being duly sworn according to law, deposes and says as follows: 1. That she is an employee of Samuel L. Andes, attorney for the Plaintiff herein. 2. That on November 15, 2006, she delivered to the U.S. Postal Service in Lemoyne, Pennsylvania, as certified mail (Receipt No. 7004 0750 0002 7282 3980) return receipt requested, addressed to the Plaintiff/Defendant herein, a true and correct copy of the Divorce Complaint filed in the above-captioned action duly endorsed with a Notice to Defend and Claim Rights. 3. Said return receipt card is attached hereto as Exhibit A showing a date of delivery to the Defendant on November 16, 2006. AMY M. HARKINS Sworn to and subscribed before me this 2/ s~` day of /1/o/e,~,13e~ , 2006. Y/j^-~ Notary Public. ~o~rNE~ „ 'CU~ea Iwo Yr co~t~S81oN aPIRE~ PH. ~. 900 r~ ^ 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 mailpiece, or on the front if space permits. 1. Article Addressed to: Mr. Brian R. Jones 355 Martingale Drive Camp Hill, PA 17011 A. ~ ~ ~ B. Fj$ceived by (Piiilbd Name) ~ C. delivery address different trorn item 1? YES, enter delivery address below: ~. 3. ice Type ified Mail ^ Express Mail Registered ^ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (ExMa Fee) ^ Y~ 2. Artici (ra„ 7D04 D750 ODD2 7282 398D PS Form 3811, Ault 2001 Domestic Retum Receipt 102595-02-M-1540 EXHIBIT A ~ -~ --a-a ,~-• --~ < ~' ~ _.. ~ -' ~ ~ ~ ; w SHELBY R. JONES, Plaintiff vs. BRIAN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-6546 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 13 November 2006 and was served on 16 November 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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 in 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. Section 4904 relating to unsworn falsification to authorities. :.~ 3~ rJ'7 Dated: HELBY JO ES ~~ °~~ ~ .a ~ ~t r,`__ 1 ~~ .,~ 'y' ~~Si J -': _~ ~ ~~y/~~ SHELBY R. JONES, Plaintiff vs. BRIAN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-6546 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 13 November 2006 and was served on 16 November 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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 in 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 1 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. Section 4904 relating to unsworn falsification to authorities. -- x-30-- o~ Dated 0 B IAN R. J S r'a ;:3 l°~ ra .:~ '`J ~,: ~. ~.S ...-; _~ tK . `}, ..~- . -d ~ :- ~, SHELBY R. JONES, Plaintiff vs. BRIAN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-6546 CIVIL TERM 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 Section 3301(c). 2. Date and manner of service of the Complaint: Service by certified mail on 16 November 2006 (Affidavit of Service filed on 18 December 2006!. 3. Complete either Paragraph (al or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: 30 March 2007 by Defendant: 30 March 2007 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 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 to Transmit Record, a copy of which is attached: Ib) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 30 March 2007, filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 30 March 2007, filed contemporaneously herewith. Date: ~ r/~~~~.V ( j Sa I L. Andes Attorney for Plaintiff ~ t.~ t , rt ' ~ ~ --a "'~ ;1 (' _ l , i ~} ....,,} -'3 ~,~ -~ ~~ .j ~~ ~~ ~ ~ -^ ~~ '~ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SHELBY R. JONES, `~~' ~~~" Plaintiff VERSUS BRIAN R. JONES, Defendant No. 06-6546 DECREE IN DIVORCE AND NOW, ~V ~~ ,~, IT IS ORDERED AND DECREED THAT SHELBY R JONES PLAINTIFF, AND RRI N R.- InNES ,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 PROTHONOTARY I~ ~f v ~,~ a ~s~,~'~ 2Q~7 ~~~f~ ~;i~ 1! ~ ~;< f~ w ;;~~;~,~~;-~ ~ } A ( y \._ ~v -~'~ ~ ~~'~. ~~"'~ ~~