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HomeMy WebLinkAbout07-0189SUSAN M. LOVE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. :NO. 07- j/? CIVIL TERM GARY D. LOVE, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS WAYNE F. SHADF Attorney at Law 53 West Pomfret Stree Carlisle, Pennsylvania 17013 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 CUMBERLAND COUNTY COURTHOUSE, CARLISLE PENNSYLVANIA 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 Wayr* F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 SUSAN M. LOVE, Plaintiff V. GARY D. LOVE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 07- 10017 CIVIL TERM : IN DIVORCE COMPLAINT Plaintiff in this Action in Divorce is SUSAN M. LOVE, an adult individual who resides at 200 Meadow Boulevard, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is GARY D. LOVE, an adult individual and citizen of the United States of America who, at the date of this Complaint, resides at 200 Meadow Boulevard, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. Plaintiff and Defendant were lawfully joined in marriage on September 3, 1971, in WAYNE F. SHADE Oakland, California. Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 11 S. The parties have been living separate and apart since the date of filing of this Complaint. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. In the alternative, Plaintiff avers as the grounds on which this action is based that Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff intolerable and the life of Plaintiff burdensome. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. This Action in Divorce is not collusive. 9. Both parties to this Action in Divorce are legally capable of managing their own concerns. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -2- 10. Defendant herein is not a member of the armed forces of the United States of America. 11. There were two children born to the parties, both of whom are adults and are emancipated. 12. Plaintiff has no adequate means of support for herself. 13. 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. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. elwo W, / Wa Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -3- I verify that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relatin to unsworn falsification to authorities. g Date: January 5, 2007 NA- Susan PM. Love WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 l c? 'y o c- -n o Q f> C" _ ? r ? R7 ?D i C.3 "? SUSAN M. LOVE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. GARY D. LOVE, CIVIL ACTION - LAW NO. 07-189 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE TO: Curtis R. Long, Prothonotary I accept service of the Complaint in Divorce in the above-captioned matter. Date: January , 2007 ary D e f r _ ?] r n 14 SUSAN M. LOVE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 07-189 CIVIL TERM GARY D. LOVE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under §3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on January 10, 2007, and served on January 10, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 days have elapsed from the date of filing and service of the Complaint. Ir 3. I consent to the entry of a Final Decree of 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 of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 7. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 participate in counseling prior to a Divorce Decree's being handed down by the Court. -2- t 9. 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: June 2, 2007 usan M. Love WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -3- C'? r? ? ? ?-- t °tti'q"? C.? ?'Z"1 _ ? °:r: f-' ? ? '-:mot i r y.` N :? '?" -G C+:W ft SUSAN M. LOVE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 07-189 CIVIL TERM GARY D. LOVE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under §3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on January 10, 2007, and served on January 10, 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. .,y *10 3. I consent to the entry of a Final Decree of 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 of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 7. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree's being handed down by the Court. -2- 06 9. I verify that the statements made in this Affidavit 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. Date: June 1, 2007 ary D. Love -3- a ' eTt '1 1 a. SUSAN M. LOVE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 07-189 CIVIL TERM GARY D. LOVE, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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. The date and manner of service of the Complaint were January 19, 2007, by acceptance of service. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code by Plaintiff was June 2, 2007, and by Defendant was June 1, 2007. 4. Related claims pending: None. Date: June 5, 2007 //.. - -'/? ?!! ? ?i Wayne . Shade Attorney for Plaintiff WAYNE F. SHAD Attomey at Law 53 West Pomfret Stre Carlisle, Pemmsylvani 17013 n r-3 C ? -rt r -40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ir4h STATE OF PENNA. SUSAN M. LOVE Plaintiff VERSUS GARY D. LOVE, Defendant AND NOW, J uQe 1-2-1 , , IT IS ORDERED AND DECREE IN DIVORCE DECREED THAT AND No. 07-189 CIVIL SUSAN M. LOVE GARY D. LOVE ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, 7 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; BY THE COURT: PROTHONOTARY ep. S/ - -,7 e o. 01.07