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HomeMy WebLinkAbout06-7314ALFRED W, FARRIS, III, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2006- MY DONNA MARIE FARRIS, : CIVIL ACTION -LAW Defendant : IN DIVORCE NOTICE TO PLEAD 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 (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. 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 32 South Bedford Street Carlisle, Pennsylvania 717-249-3166 ALFRED W, FARRIS, III, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO.2006- 7 3 y v DONNA MARIE FARRIS, CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT Plaintiff, Alfred W. Farris, III, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff is Alfred W. Farris, III, an adult individual residing at 940 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Donna Marie Farris, is an adult individual residing at 6503 Salem Park Circle, Mechanicsburg, Cumberland County, Pennsylvania. 3 Plaintiff and Defendant were married on September 3, 1994 in Cumberland County Pennsylvania. 4 Plaintiff and Defendant have lived separate and apart for a period of two years. 5 There have been no prior actions of divorce or for annulment between the parties. 6 The marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing him from the Defendant. BROUJOS & GILROY, P.C. By u ert !fo /Pla; Esquire Attornetiff Bro ujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717-2434574 VERIFICATION OF ALFRED W FARRIS, III I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. D W. FARRIS, III r-J LL ?VT'f . fr i T t l rc? 1 0 A 7_1 O ^ ?? "] ..lam F.`.FILES\Clients\1'_393 Fan,u\12393. I. consaffAlfred Created. 9.20 ii0 0.00M Revised. 3'11:08 2.29PM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ALFRED W. FARRIS, III Plaintiff V. DONNA MARIE FARRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-7314 CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cc) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on December 29, 2006. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about January 5, 2007 3. The marriage of the 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 of divorce without notice. 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. 1 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. §4904 relating to unsworn falsification to authorities. Date: "tL ) ?,L,)o? -' ALFRED W. FARRIS, III%Defendant Y O Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (71?) 243-3341 Attorneys for Plaintiff -.fl ~..._. ._,,._.. i" .fir ~t i ~,_.,F - iQifl J~~~ ~ 3 ~'~i'i f~~ r 7 f ~l~,~+': ALFRED W. FARRIS, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-7314 CIVIL ACTION -LAW DONNA MARIE FARRIS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 29, 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. 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.5. § 4904 relating to unsworn falsification to authorities. Date• .3 Z01 C~ Donna Marie Farris, Defendant Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES T.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ALFRED W. FARRIS, III Plaintiff v. DgNNA MARIE FARRIS, Defendant ~iL~G~- ;t. .~.. .. ,,raY 2~i1~ .~~~ 13 R=i i2~ i CUflr,~:- ~v,~.ai~lY r~.> yr~E~ ti,r~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 200E-7314 CNIL ACTION -LAW IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(cLAND § 3301(d~ OF THE DIVORCE CODE 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 waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: Z©~Q ~- Donna Marie Farris, Defendant ALFRED W. FARRIS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA III DONNA MARIE FAR~RIS AND NOW, _ ALFRED W. FARRIS DONNA MARIE FAI~RIS ~~ , it is ordered and decreed that plaintiff, and bonds of matrim defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente I to if any economic claims remain pending. The court re ains jurisdiction of any claims raised by the parties to this action for which a final or er has not yet been entered. Those claims are as follows: (If no claims remain indi ate "None.") NONE By the Court, Attest: J. c Prothonotary NO. 2006-7314 DIVORCE DECREE ~1~ ~,o ~ - a.o - ~ ~ L'.cr-.~ . cs~ c~c~ ~ ~~ -+a G• ~ rah. 7-ao-(o ~c~~- ma=~~~c1 -~ ~~.