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Home My WebLink About07-0149Paul J. Esposito, Esquire LD. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. 0. Box 1268 Harrisbwg, PA 17108-1268 (717) 234-4161; (717) 234-4161 (facsimile) Counsel for Plnintr(f VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. C)7 - ~~~]' Civil Term GLENN FEGAN, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFEND 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 with 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 also 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. When the ground for 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. 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. 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 Court Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 Guy H. Brooks, Esquire I.D.#49672 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (7171234-4161; (717) 234-4161 (facsimile) Counsel or Plarnti VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS O Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. V 7 • ~ y `~ Civil Term v. GLENN FEGAN, CIV 1L ACTIO?~i - I,A`ti' Defendant IN DIVORCE WAIVER OF COUNSELING VIOLET M. FEGAN, being duly sworn according to law, deposes and says: I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I to participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in cowsseling prior to a divorce de::ree being handed down b;i the Cnurt. 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. Section 4904 relating to unsworn falsification to authorities. ~.-- Date: -22-06 VIOLET M. FEG Paul J. Esposito, Esquire I.D. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-4161 (facsimile) Counsel or Plainti VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA • NO. 0~1 - ~~ q' Civil Term v. GLENN FEGAN, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE Plaintiff, VIOLET M. FEGAN, is an adult individual, who currently resides at 21 Anthony Drive, Lot # 16, Marysville, Cumberland County, Pennsylvania 17053. 2. Defendant, GLENN FEGAN, is an adult individual, who currently resides at 209 North 26~' Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff avers that she has been a bona fide resident in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint. 4. The parties were married on August 10, 2002 in East Pennsboro, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment filed by either of the parties hereto. 6. Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling. 7. Plaintiff requests the court to enter a decree of divorce. COUNTI The averments of paragraphs 1 through 7 herein are hereby incorporated by reference thereto. 9. The marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court to: a) Enter a Decree in Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant; and b) Order such other relief as the Court deems just and reasonable. GOL ERG TZMAN, P.C. Paul J. osit squire Attorney I.D. 25454 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 (717) 234-6808 (facsimile) 3 a ao~ Attorney for Plaintiff Date: ~ / '' U 2 VERIFICATION I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 1 R Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: g ' 22' Df0 ~. VIOLET M. FEG t^ ~- '"~Q c d ~J r "(1 ~.~.,,- i.~ . . ,_ :~ ~~~ _f' r;" C~:' ~ ti~ C_ N q _~ CO .~ ~~ ~t '~1 t, L ~:;~ ~~ ~rn =c Paul J. Esposito, Esquve LD. #25454 GOLDBERG KA'fZMAN, P.C. 320 Market Street P. O. Box 1268 .Harrisburg, PA 17108-1268 (717) 234-4161;(717) 234-4161 (facsimile) Coarse/ for Plaintiff VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ~, NO. 07-149 Civil Term GLENN FEGAN, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, GLENN FEGAN, Defendant, acknowledge that I received a copy of the Complaint in Divorce which was filed with the Court on January 8, 2007, in the above-referenced matter by personally accepting service thereof. Date: ~ J 1 u - , 2007 GLENN FEGAN, DEFE ANT ~ ,~, ~ -s~ ...~ .. ~ ~ ~ -rt ~ ~ ~ e.D ~ } ~'- p, "SJ r-~ t ~'' ` ' ,~ ~ ~ C1 . ._ t._~' ~ _-{ Paul J. Esposito, Esquire LD. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-4161 (facsimile) Counsel (or Plaintin` VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-149 GLENN FEGAN, CIVIL ACTION -LAW Defendant 1N DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 8, 2007. 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 s±~t~ments herein are mat•?a subjec*, to tiYie, r•e. cities of ? R Pa.C.S. Sec:i~r. 4904, relating :o unsworn falsification to authorities. Date: y ' 2 3" ~'~ VIOLET M. FE A ~_=.W ' : , c~ : ;,,,~ rn c~ ~ ~~~cL.~ _ , ~'- is=; c ~ J}r-~ N Paul J. Esposito, Esquire [.D. ti25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (7l7) 234-4161; (717) 234-4161 (facsimile} Connse! (or Plainti/1 VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-149 GLENN FEGAN, CIVIL ACTIO;~t - L,~3`~' Defendant IN DIVORCE AND CUSTODY 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 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 unsworn falsification to authorities. Date: y - 2 3 -0 7 VIOLET M. FEG N c-a ~ o c. ~ -n -T, u ~°, ~ ,, . U3 sv t7ti ~ c t 7 ~'~ ~ ,~ , "L? <'~ ~~ -. ~ Paul ]. Esposito, Esquice I.D. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161;(717) 234-4161 (facsimile) Counsellor P/aintiry VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-149 GLENN FEGAN, CIVIL ACTION -LAW Defendant IN DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 8, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received a copy of the Complaint in Divorce on or about January 14, 2007, via Acceptance of Service executed by me. I verify that the statements made in this Affidavit aze 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. Date: `1 ~ a2J - ~ ~ 7 ~ ~ GLENN FEGAN r-~ Q ,~ cl :~r -- ~ ~ rf~~ ~ { - , i' Y / /„ l C3 :=<- 7 -t^ \~ ~ f" Y 3 _i.f'fr tt •• .~'tiI 1...~ Paul J. Esposito, Esquire LD. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-4161 (facsimile) Counsel !ar Plaintil! VIOLET M. FEGAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-149 GLENN FEGAN, CIVIL ACTION -LAW Defendant IN DIVORCE AND CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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 affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~ ~ ~~ `~ ~ ~ ~ ~~ -~ GLENN FEGAN ~ ~ N °~ , .~, _, ;, ~., ~ N Paul J. Esposito, Esquire [.D. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-4161 (facsimile) VIOLET M. FEGAN, Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v GLENN FEGAN, Defendant NO. 07-149 CIVIL ACTION -LAW IN DIVORCE AND CUSTODY 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) of the Divorce Code. 2. Date and manner of service of the Complaint: January 14, 2007, via Acceptance of Service, executed by Defendant. 3. (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on Apri123, 2007 ; by Defendant on Apri123, 2007 (b)(1) Date of execution of the Affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of Plaintiff s Affidavit upon the Defendant: 4. Related claims pending: 5. (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 Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: Apri126, 2007 Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: r-~ f~ N„ °' 'y.~ ~ ,,.,. , t~ ~~ x~ - r~-~ 1. `„ ~ ~a 1 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '~ PENNA. ~ . ~. -:, - VIOLET M. FEGAN, Plaintiff VERSUS GLENN FEGAN. Defendant N O. 07-149 .~.iyi DECREE IN DIVORCE •. Cp~, lT IS ORDERED AND AND NOW, ~ ~< S ~ ~-. DECREED THAT AND VIOLET M. FEGAN GLENN FEGAN 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; .~~ ~~~ ~Q. {r~~ Lo- ~~~'~