HomeMy WebLinkAbout06-6564V 11W .
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Thomas M. Fulcomer, )
Plaintiff )
vs. )
Michelle C. Fulcomer, )
Defendant )
No. 06- ?,5-6 1 of Civil Term
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.
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
Room 100, 1 Courthouse Square Carlisle Pennsylvania 17013
(Room Number - Address)
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, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
Cumberland County Bar Association
32 South Bedford Street (Name)
Carlisle, PA 17013 1
(717) 249-3166
(Address)
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Thomas M. Fulcomer, )
Plaintiff )
vs. )
Michelle C. Fulcomer, )
Defendant )
No. 06- "-'s 6 Y of Civil Term
COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Thomas M. Fulcomer, who currently resides at 7 Bellmore Road,
Camp Hill, Cumberland County, Pennsylvania since October 9, 1995.
2. Defendant is Michelle C. Fulcomer, who currently resides at 7 Bellmore Road,
Camp Hill, Cumberland County, Pennsylvania since October 9, 1995.
3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on August 5, 1995 at Harrisburg,
Dauphin County, Pennsylvania.
5. There have been no prior actions of 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. Plaintiff requests the court enter a decree of 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 unworn falsification to authorities.
6
omas M. Fulcomer, Plaintiff
Date:
VERIFICATION
I verify that the statements made in the forgoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§ 4904, relating to unworn falsifications to authorities.
Dated: J` ?? (O
Thomas M. Fulcomer, Plaintiff
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In the Court of Common Pleas of
Cumberland County, Pennsylvania
Thomas M. Fulcomer, )
Plaintiff
)
)
vs. ) No. 06- 6564
}
Michelle C. Fulcomer, )
Defendant )
PROOF OF SERVICE
¦ Complete items 1, 2, and 3. Also complete 4SJg item 4 If Restricted Delivery Is desired. ¦ Print y
our 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:
Ala C?^ r f?,d ?= ? ? is
of Civil Term
? Agent
C. Date of
D.. Is delivery address different from
M YES, enter delivery address ? . No
OW
3. Type
certified mail O Express mail
? Registered 0 Return Receipt for Merdwndbs
0 insured mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
2. ArditNuff*w 7005 3110 0002 1863 6672
MwM0br fbm wrMce hdw
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540
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In the Court of Common Pleas of
Cumberland County, Pennsylvania
Thomas M. Fulcomer, )
Plaintiff )
vs. )
Michelle C. Fulcomer, )
Defendant )
No. 06- 6564 of Civil Term
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on
November 13, 2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
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 unworn falsification to authorities.
Date: V30/0 ?
Thomas M. Fulcomer, Plaintiff
C)
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Thomas M. Fulcomer, )
Plaintiff )
vs. )
Michelle C. Fulcomer, )
Defendant )
No. 06- 6564 of Civil Term
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(c) AND 3301(d) 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 unworn falsification to authorities.
Date: 3 0-7 J!:v e,
ThAm"as M. Fulcomer, Plaintiff
CJ r-a C?
r`te' ;
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Thomas M. Fulcomer, )
Plaintiff )
vs. )
Michelle C. Fulcomer, )
Defendant )
No. 06- 6564 of Civil Term
AFFIDAVIT OF CONSENT
4. A complaint in divorce under § 3301(c) of the Divorce Code was filed on
November 13, 2006.
5. The marriage of plaintiff and defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
6. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
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 unworn falsification to authorities.
Date: g M1,1A L'Z4 Ole,
Mi elle C. Fulcomer, Defendant
Ei
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Thomas M. Fulcomer, )
Plaintiff )
vs. )
Michelle C. Fulcomer, )
Defendant )
No. 06- 6564 of Civil Term
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(c) AND 3301(d) OF THE
DIVORCE CODE
4. I consent to the entry of a final decree of divorce without notice.
5. 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.
6. 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 unworn falsification to authorities.
Date:
. JAJA? f9AW 1,? -t e
Michelle-
chelle C.Fulcomer, Defendant
c_
Y?
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Thomas M. Fulcomer, : IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL DIVISION
Michelle C. Fulcomer, :
56 CIVIL TERM
Def endent NO. (? ?^ C
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 §3301(c)
(Strike out inapplicable section).
2. Date and manner of service of the complaint: M)1/E r1'1 he r /1 HOC Ay,
e.r 1 r"t M 41 `
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code:
by plaintiff 1-gCbrIJ 9!2, o146-'? by defendant P4Ctr-G/ '1 36oxbd ?
4. Related claims pending: AVri n 0
art1Fl?(bf ecrvirP Of th noti[`?6tf Intentl0R3n filP.fnr ----tiS,po=?-?,'",^"^"t-rp-C?f?- a
(b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: 141"d 36, ;Lop-?
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: lt4u'`L
Attorney or Piain iff / Defendant
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
VERSUS
c4e1lp C, )C? fcGen e, r,
PC -n do-'14
No. DG - (n Sry
DECREE IN
DIVORCE
00i:t f. %.o Am "
l Mn?
AND NOW, 3a IT IS ORDERED AND
DECREED THAT ?41GnZC(? A. r?AICOP16y- PLAINTIFF,
AND -m I,r 4 -, `ILA r- , /--4f lcox?lap- 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;
1llnne
THE
A EST: J.
PROTHON T RY
7IV
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
DMnS r1 i -Cram
Plaintiff J _ ? ??
Vs File No. 06 Y
IN DIVORCE
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking `Y J
prior to the entry of a Final Decree in Divorce,
or , X after the entry of a Final Decree in Divorce dated ' 0
hereby elects to resume the prior surname of,- ?yT?E?L , and gives this
written notice avowing his / her intention pursuant.to the provisio of 54 P.S. 704.
Date: 7
Signature
'r A 1 1 4. -4,# J L4d2i-el
Signature of name being r#fumat
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF8
On the 21 day of ?: -, 200a before me, the Prothonotary or the
notary public, personally appAP-A the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
' Notaryblic
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