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HomeMy WebLinkAbout06-7148r AMY J. STEVER-HEADLEY, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. d? • 7/f?? 64411 ALAN W. HEADLEY, 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 foregoing 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 in 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: 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 AMY J. STEVER-HEADLEY, Plaintiff vs. ALAN W. HEADLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0 G - ? /'ice 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. AMY J. STEVER-HEADLEY, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 196- lI yd' - ;. _ 0,4 ALAN W. HEADLEY, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, AMY J. STEVER-HEADLEY, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is AMY J. STEVER-HEADLEY, an adult individual who currently resides at 905 Williams Grove Road in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is ALAN W. HEADLEY, an adult individual who currently resides at 4 East Factory Street in Mechanicsburg, 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 28 August 1999 in Enola, Cumberland 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 el L. Andes 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: /a/7/0& AMfJ J. STEVER-HEADLEY ?r v J ®r- wr:; 'r l -TI - 1} _ -t I 019 AMY J. STEVER-HEADLEY, Plaintiff Vs. ALAN W. HEADLEY, Defendant PRAECI PE TO THE PROTHONOTARY: Please reinstate the Complaint in this matter. 12 March 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7148 CIVIL IN DIVORCE Sarr'nuel L. An6bs Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 r-? ? a t ?'' -- ?1 . , . ?_ `-?'- --t'? " ` ?'t ?7 ... t " t ?% ; - _ =,', -s ; -= f' s " _,_.. r r=t?t T"J . t-? : ?? r ..yam, ?-, AMY J. STEVER-HEADLEY, Plaintiff VS. ALAN W. HEADLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. L1? 7141?r- 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 foregoing 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 in 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: 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 i estimmy whermot, I here unto set my ha? the sem Of sajo court -it CarIM, Pa. i dale It. ?, ? n?n?fhnnn?a?. 41 A AMY J. STEVER-HEADLEY, Plaintiff VS. ALAN W. HEADLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 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. AMY J. STEVER-HEADLEY, Plaintiff VS. ALAN W. HEADLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, AMY J. STEVER-HEADLEY, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is AMY J. STEVER-HEADLEY, an adult individual who currently resides at 905 Williams Grove Road in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is ALAN W. HEADLEY, an adult individual who currently resides at 4 East Factory Street in Mechanicsburg, 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 28 August 1999 in Enola, Cumberland 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 el L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12'' 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: AMY j. STEVER-HEADLEY SHERIFF'S RETURN - REGULAR CASE NO: 2006-07148 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STEVER-HEADLEY AMY J VS HEADLEY ALAN W WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon HEADLEY ALAN W the DEFENDANT at 1916:00 HOURS, on the 26th day of March 2007 at 4 EAST FACTORY STREET MECHANICSBURG, PA ALAN W HEADLEY by handing to a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Postage .39 Surcharge 10.00 .00 3 Sworn and Subscibed to before me this day of I _ So Answers: -.40 R. Thomas Kline 03/27/2007 SAMUEL ANDES By. ` Deputy Sheriff A. D. AMY J. STEVER-HEADLEY, ) Plaintiff ) vs. ) ALAN W. HEADLEY, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7148 CIVIL TERM IN DIVORCE d a v? o L avs_G A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 18 December 2006 and served upon the Defendant, by the Sheriff of Cumberland County on 26 March 2007. 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. 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. Section 4904 relating to unworn falsification to authorities. 6i Zy 00 Dated: 11 ALAN W. HEADLE C7 -r , N c-n t_) lD PQ r AMY J. STEVER-HEADLEY, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7148 CIVIL TERM ALAN W. HEADLEY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 18 December 2006 and served upon the Defendant, by the Sheriff of Cumberland County on 26 March 2007. 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 33010 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. 2 Y a8 a... o 4zu,,._- a4-AL,, Dated: AM J. STEVER-HEADLE sv --? r - F3 `- AMY J. STEVER-HEADLEY, Plaintiff VS. ALAN W. HEADLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7148 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: 26 March 2007 by Sheriff's Service. 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: 24 June 2008 by Defendant: 24 June 2008 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: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: filed contemporaneously with this Praecipe. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: filed contemporaneously with this Praecipe. Date: 45 Vt?nCs el L. Ande Attorney for Plaintiff (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 Defendant's Affidavit upon the Respondent: c7 - C= r7 71 C- '- k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. AMY J. STEVER-HEADLEY, Plaintiff VERSUS ALAN W. HEADLEY, Defendant No. 2006-7148 CIVIL TERM DECREE IN DIVORCE AND NOW, -s y\I _? ---20.& IT IS ORDERED AND DECREED THAT AND AMY J. STEVER-HEADLEY ALAN W. HEADLEY ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,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 BEEN ENTERED; NONE BY THE COURT: ?% ?A' ?.I'\ ATTEST: / , J. P R OTVI ON OTA RY Vow -p -.0, ?- ? " -0 'Oov? 4(q? ? -z-, AMY J. STEVER-HEADLEY, ) Plaintiff ) vs. ) ALAN W. HEADLEY, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-7148 CIVIL TERM IN DIVORCE NOTICE TO RESUME PRIOR SURNAME NOTICE IS HEREBY GIVEN that AMY JO STEVER-HEADLEY, Plaintiff in the above matter, having been granted a Final Decree in Divorce on the 7TH day of July 2008, hereby elects to resume the prior surname of AMY JO STEVER, and gives this written notice pursuant to the provisions of 54 P.S. § 704. Date: 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMW(Y STEVER-HEADLEY AMY J S VER (SS.: On the lr* day of , 2008, before me, the undersigned officer, personally appeared AMY JO ST VER- EADLEY, known to me (or satisfactorily proven) to be the person whose name is signed to the within Notice to Resume Prior Surname and acknowledged that she executed the foreg-,ning for the purpose therein contained. 11 IN WITNESS WHEREOF, I hereunto set my hand and official seal. __ ? ? ? ? ? C/' Y ?°` >.:. ? '• lv {,r ? fi ? ?, . ,.. P