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HomeMy WebLinkAbout06-6547 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JEFFREY S. CONNACHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0 ~ - 10 S- 4 { q ,)l ( -tcr,.... ANGELA J. CONNACHER, Defendant CIVIL LAW - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend agaimst the claims set forth in the following pages, you must take pro~pt action. You are warned that if you fail to do so, the case ~ay proceed without you, and a Decree of Divorce or Annulment may:: be entered against you by the Court. A jUdgment may also be enteried against you for any other claim or relief requested in these pap~rs by the Plaintiff. You may lose money or property or other rigijts important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrieva~le breakdown of the marriage, you may request marriage counseling. .: A list of marriage counselors is available in the Office of the Prothonotary at: 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 GRANTEp, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU PO 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 (717) 249-3166 OR (800) 990-9108 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JEFFREY S. CONNACHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Ofo-lo~'-/l C-).J,I -ttr",,- ANGELA J. CONNACHER, Defendant CIVIL LAW - DIVORCE COMPLAINT IN DIVORCE COUNT I Reauest for a No-fault Divorce Under ~3301(c) of the Domestic Relations Code resides at 126 Willow View Drive, Cumberland County, Carlisle,PA 1. Plaintiff is JEFFREY S. CONNACHER, who currently 17013. resides at 2509 Warren Way, Mechanicsburg, PA 17050. 3. Plaintiff has been a bona fide resident in the 2. Defendant is ANGELA J. CONNACHER, who currently Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 2000 in Cambria County, Pennsylvania. 4. The Plaintiff and Defendant were married on June 2~, 5. There have been no prior actions for divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. There are no children borne of the marriage. 9. Defendant is not a member of the armed services. WHEREFORE, Plaintiff respectfully requests this Cour~ to enter a Decree of Divorce pursuant to S 3301(c) of the Dome~tic Relations Code. DATED: 11/10/06 TH . LEWIS, ESQUIRE ney for Plaintiff . ~ VERIFICATION I hereby verify that the statements made in the foreg0ing document are true and correct to the best of my knowle~ge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4~04, relating to unsworn falsification to authorities. Dated:lljlO lOb ~/~ JE E ~ CONNACHER C) f'-) ~ .i4- t:-= ~-:-:'~) l"'- e::..) c:.r~ ~ ~ -- CJ ~ ~ -.<:.:: - ~ ;j' -. w 0{ - 0 ..--"'} "'" - , \ v.) ~ '-.0 -S) - j ... ~ "\::) ~-( r- C""- ~ \.D ~ ~ r- t V KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JEFFREY S. CONNACHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6547 ANGELA J. CONNACHER, Defendant CIVIL LAW - DIVORCE ACCEPTANCE.OF SERVICE I accept service of the Complaint in Divorce. DATE: \.\ \ \\1 \ ()Lt ~o~~cS:~ 2509 Warren Way Mechanicsburg, PA 17050 "", = = 0"" () -n --i I"T'l fl1p u,; 1.;--, - ~'- C') ~ N ~ ~ .r:- N \.D KENNETH F. LEWIS, ESQUIRE 1.0. #69383 1101 North Front street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JEFFREY S. CONNACHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6547 ANGELA J. CONNACHER, Defendant CIVIL LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce was filed under section 3301 (c) of the Divorce Code on November 13, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. 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. Dated: 2,}L3/01 ~E~~C~A~ (") c "-. ~~. L' t. . \::r211 .re- -' fJ/ ,--- '.-" "'-- 'J.::" t-~ :2~ .,:. j:;~C ~ ,...., = .~ Z ::>'" :;0 ~ ~-n m~ :9d -,) I qo :,"\2, =i~J_ ~~ (-=) 6rn --\ ?O -=-< I (J1 :P'> ~ C5 ., N KENNETH F. LEWIS, ESQUIRE 1.0. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff JEFFREY S. CONNACHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6547 ANGELA J. CONNACHER, Defendant CIVIL LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on November 13, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. 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. Dated: 3/1101 ~~~ JE F Y S. CONNACHER s.::; ~ /">.) <=;> = .,....,J' 'nl: ' )> ;:0 I CJ1 o ." s:! n'l:I! I :-y!:O .-;~i. ....1') :-:; t} ':T~ ""'r, _,,)--n +0 i_3m ~ :n -< :l= :J: <;? N " ;,,).::':..:t( v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6547 JEFFREY S. CONNACHER, Plaintiff ANGELA J. CONNACHER, Defendant CIVIL LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE ONDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: 3/1 /0'1 ~~L~ J F EY S. CONNACHER ,..., = = --' 3. );>' :;:0 I <J1 ~ ::& '2 ~ :;1-n [UF -um :by C)(':) ~~:-J :~.:.: ::St) ?=rn '-~ ~ N JEFFREY S. CONNACHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6547 ANGELA J. CONNACHER, Defendant CIVIL LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (0) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document 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. Dated: ~/B /01 \ Jw~k ~ ~~. ANGELA J. CON CHER ,...., <::::> = -..f :x ::-;... :;.-0 f U'I o '"Tl :J!~ n1 -:.! r- um "_::90 [') J. ":'lC' ;~ =r~ '~C~ 6rf~ -~ 1) -< :.':> :::1'.: S? N JEFFREY S. CONNACHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6547 ANGELA J. CONNACHER, Defendant CIVIL 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 section (X) 3301 (c) () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service signed 11/16/06 and filed 11/21/06. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree: by the Plaintiff on 3/1/07; by the Defendant on 2/23/07. 4. Related claims pending: NONE. onlv no-fault divorce filed. DATED: 3'" 2-D? ~~LEWIS' ESQ. Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff ~ ~ g ~~ -0 f1~ -':;;59 '::3~, 'C-n :P" ~~o '::!t6 rn S? -~ ~ :Jt. ~ 1 U"I N :tl :tl :tl :tl :tl iii iii iii iii IF. iii iii iii iii:tl :tl :tliii iiiiiiiiiiii :tliiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiii~iii iii~iiiiiiiii iiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiiii ~iii IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. iii f .T~FFR ey S, {{)/J/JlrcHfR :.,"- 06-65'1-7 iii iii iii '" iii iii iii iii iii iii iii iii iii iii iii iii iii iii No. VERSUS ffN~E1..A J; wJJNITCtfB iii DECREE IN DIVORCE AND NOW, fV\D l L 7 ' 200? , DECREED THAT JE.FfREY 5, {J)NNItQ!E-1< AND~N~ELA :r {f))JAlfJCH~R IT IS ORDERED AND , PLAI NTI FF, , 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; !lOf)e iii "'", PROTHONOTARY AmST'~~ iii :tl:tl :tl:F.iii :tl:F.:tl:tl:tl ~:tl :F. :F.:F.:F.iii:tl:F.iii:tl:tliii:tl:tliiiiiiiiiiiiiii iiiiii iiiiiiiiiiii iiiiiiiii iii:tliii iiillilli"'lIi'" J. iiiiii -;/rP ~?!lJ!lL. (.fl' ~ - f' ~ fl.vrj-1!- ~. jr/(;f7'p71 L(/' t I' '\ ' . . ~~. ' ,. - - '.......... '. ,-:-.,,.'. -~-.,.,