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HomeMy WebLinkAbout02-3052HAROLD 8. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (7t7) 243-6090 ATTORNEY FOR PLAINTIFF : IN THE COURT OF COMMON PLEA8 OF ~O~TATE, : v. : CIVIL ACTION - LAW MERLE. TATE, : NO. 02 -~ CIVIL TERM Defendant : IN DIVORCE Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NOTICE 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 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 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, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 LORI A. TATE, MERLE. TATE, Plaintiff Defendant : IN THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW ; : NO. 02-3(~/.Z CiViL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT Tn_ SECTION 330t(C) OF THE DIVORr I= COD, NOW, comes the plaintiff and files this complaint in divome against the defendant, representing as follows: 1. The plaintiff is Lori A. Tate, an adult individual residing at 1560 McClures Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Merl E. Tate, an adult individual residing at 1560 McClures Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on March 17, 1993, in Jamaica. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as your Honorable Court maY deem equitable and just. I veriflj that the statements made in this complaint 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 unswom falsification to authorities. June 24, 2002 ~-ORI A. TATE, Plaintiff Carlisle, Pennsylvania 17013 (717) 243-6090 LORI A. TATE, MERLE. TATE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02 - ~ CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. June 24, 2002 ~ ~_~(~ LORIA. TATE, Plaintiff LORI A. TATE, Ye MERLE. TATE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : : NO. 02 - 3052 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about June 25, 2002 and served upon defendant on June 25, 2002 (See Affidavit of Service filed on June 25, 2002.) 2. The marriage of plaintiff and defendant is iirretrievably broken and ninety days have elapsed from the date of the 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 divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authoriities. December 9, 2002 LORI A. TATE, Vw MERLE. TATE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : : NO. 02 - 3052 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRE~= UNDER SECTION 3301(C) OF THE D'VORCE CODF 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. Section 4904 relating to unsworn falsification to authorities. December 9, 2002 MERLE. TATE LORI A. TATE, Ye MERLE. TATE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 3052 CIVIL TERM : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, 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 counseling prior to a divome decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. December 9, 2002 ,~/~/~~- ME~RL E.-'I'ATE ' LORI A. TATE, : IN THE COURT OF COMMON PLE-4-~ OF MERLE. TATE, Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02 - 3052 CIVIL TERM : IN DIVORCE p~a. INTIFF'S MARRIAGE COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, 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 counseling prior to a divorce decree being handed down. January 6, 2003 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. LORI A. TATE LORI A. TATE, : IN THE COURT OF COMMON PL~--a- G OF MERLE. TATE, Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02 - 3052 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about June 25, 2002 and served upon defendant on June 25, 2002, by personal service (See Acceptance of Service filed June 25, 2002). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. January 6, 200.~ LORI A. TATE LORI A. TATE, : IN THE COURT OF COMMON PLEAS OF MERLE. TATE, Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 3052 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE UEST 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. 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. January 6, 2003 LORI A. TATE HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF LORI A. TATE, : IN THE COURT OF COMMON PLEAS OF MERLE. TATE, Plaintiff Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02 - 3052 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: decree: Transmit the record, together with the following information, to the court for entry of a divorce 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about June 25, 2002, defendant was served with a copy of the divorce complaint. See Acceptance of Service filed on June 25, 2002. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: January 6, 2_003. By the defendant: December _/q__, 2002. (b)(1) Date of execution of the affidavit required .by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. Related claims pending: None January ..t~_._, 2003 Complete either (a) or (b): (a) Date and manner of service of the notice of i~tention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date plaintiff's Waiver of Notrice in Section 3301(c) divorce was filed with the Prothonotary: January ~_, 2003. Date defendant's Waiver of Notice in Section 3301© Divorce was filed with the Prothonotary: HAROLD S. IRWIN, I~1'- / Attorney for Plainiiff~// z4 :~ IN LORI A. THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~ PENNA. TATE PLEAS Plaintiff VERSUS MERLE. TATE Defendant NO. 02-3052 CIVIL TERM DECREE iN DIVORCE A N D N OW, JANUARY , _2~Q3_, IT IS ORDERED AND DECREED THAT LORI A. TATE , PLAI NTI AND MERLE. TATE , DEFENDANT, ARE DIVORCED fROM THE BONDS OF MATRIMONY. 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 ATTEST: ~~P R~THONOTARi' NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 35 EAST HIGH STREET CARLISLE PA 17013 (7t 7) 243-6090 ATTORNEY FOR DEFENDANT Plaintiff LORI A. TATE~ MERLE. TATE, IN THE COURT OF COMMO~ :CUMBERLAND COUNTY, PE Defendant : CIVIL ACTION - LAW :NO. ~'- 3052 CIVIL TERN : IN DIVORCE PLEAS OF ~INSYLVAN IA NOTICE OF INTENTION TO RETAKE AND USE PRIOR NAME I, LORI A. TATE hereby give notice, avowing my intentioll to resume and hereafter use my prior surname, to wit: LORI A. WlMER, in ac(:~rdance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, S{,ction 704 (a) (54 Pa.C.S.A. Section 704 (a)). My divorce, docketed to the above term and number was granted on the 11TM day of March, 2003. , I verify that the statements made in this document are tr~Je and correct. I understand that false statements herein made are subject to th® penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities.i IN WITNESS WHEREOF, I have hereunto set my hand and sieal this 26th day of March, 2003. -~ C~-~~ (SEAL) Witness: LORI A. TATE T~),~BE KNOWN AS: LORI A. WIMER ",,,1