The URL can be used to link to this page

Home My WebLink About06-6902ANGELA L. GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2006- ~9~a CIVIL JOHN L. GARMAN, Defendant IN DIVORCE 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. 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 Carlisle, PA 17013 Telephone: (717) 249-3166 ANGELA L. GARMAN, Plaintiff vs. JOHN L. GARMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- 49'GZ CIVIL IN DIVORCE COMPLAINT UNDER SECTIONS 3301~C) AND 3301 ~D) OF THE DIVORCE CODE 1. Plaintiff is Angela L. Garman, an adult individual who currently resides at 401 North Walnut Street, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is John L. Garman, an adult individual who currently resides at 401 North Walnut Street, Mount Holly Springs, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in 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 August 25, 2001, in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARK & SCHERER By Mic . Sc erer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. ,~.1 Angela L. Garman Date: ~ ~~2 ~! d~G b O ~~ °~ ~ "'~ ~ ,;'~ 1 Ig .1 ~~ 0 ('~ ^~ °~ Q o -. 12i ~ ~ ; ' 4 ~~ ~ ( v '7 ~' Z m" ` ~ . ..i_~ ~ -~ _~ - .~ ~, C Y:. .3 --~ - ... _ y (, ;~ 3~ ~ r, _~ ,...~ T, ;"1'7 ~-' . ~ .. x ~ry. .,. C~ ~.,. .. ANGELA L. GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2006- 6902 CIVIL JOHN L. GARMAN, ; Defendant IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ~~ day of ~c~~ber' , 2006, I, John L. Garman, Defendant above, hereby accept service of the Divorce Complaint filed in the above- captioned case. John L. Garman e~ ~ C ~ ~ •-n {: c=, `~ ` --~ ~r•~ ~~at~ ~ e ~~~ L~' _ - r •J _ ~ r~3 .. .~ ANGELA L. GARMAN, Plaintiff V. JOHN L. GARMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- 6902 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE. OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c~ OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 1, 2006. 2. Defendant signed an acceptance of service form on December 7, 2006. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: March ~~, 2007 V G ~-- ~-C~ ~y~~ gela L. Garman ~ "~ " ~ ~_ ..~.- .~ s + ~..' -' 't ~ Y ,. .»~ ~f ~...~ F.~ s' '~ j'Ci ~ .` _ ANGELA L. GARMAN, Plaintiff V. JOHN L. GARMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- 6902 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO RE@UEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301~c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 1, 2006. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ;, ~1 Date: March ~ i , 2007 ~ ' John L. Garman C> `-- ~ ~~ ~ - ;n -- .~ ' ;? ~ ' - N _ :' ~ ., - ;, -, _,. t-`, _,. ~~ ~~ ~ rc ANGELA L. GARMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2006- 6902 CIV1L JOHN L. GARMAN, Defendant 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)of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed an Acceptance of Service form December 7, 2006. 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: by Plaintiff on March 31, 2007; and Defendant on March 31, 2007. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARK & SCHERER Mic ael A. Scherer, Esquire S ~' ~ t~ +. J r~ `i"3 , ~^a :v -"~ 4= IV ~ ,j ` ,, .r , .. ,P. J 'j __. ,_ _,w ,~..! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA f~hGt'[G ~. C a rr~ ~1 Plaintiff Vs File No. ~ 6 - b~ oa ~~ Y ,~ ~ ~rA f VY~'1 r IN DNORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by marking "x"] ,~ prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of ~y~l'S~'r{'~ ,and gives this written notice avowing his /her intention pursuant to the provisions of 54 P.S. 704. Date: ~ D ~ ~ '~~,~ Signature lQ . L~~c4L `' Si tore of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF C~ml~rlnnc~ On the ~~` day of _Ap~; i , 200, before me, the Prothonotary or the notary public, personally appeared 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. NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 Prothonotary or otary ublic "~ ~. ;~. .... C ~O A ~f; ~`' ~~ r-- ~ -- _r _ ~ 7"i _ '~ `-cr ~~ - -~ , ~~ ~, ;: -- - ; , =: _~i I l'~I THE COU 1RT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. ~, _ ~. ~. _,;•-~ - ANGEL~A L. GARMAN, Plaintiff VERSUS JOHN ~ GARMANR Defendant A,NC~ NOW,~G',,~,'/ /`~ A ~ L007 IT IS ORDERED AND -~ DIVORCE DECREED THAT ANGELA L. GARMAN PLAINTIFF, AND N O. 2006-6902 Civil DECREE IN JOHN L . GARMAN ARE DIVORCED FROM THE BC)NDS OF MATRIMONY. DEFENDANT, 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 B1.EN ENTERED; BY THE COURT: ~` r PROTHONOTARY _ ~' d ~ ,-. fT/f" Y ~' Y y t ~ ~ ry. ~-T s