HomeMy WebLinkAbout02-3076IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Donna Marie Stevens,
VS.
Edward L. Stevens, Jr.,
) Civil Action - Law
Plaintiff, )
)
) No. e -507(0
)
)
Defendant, ) In Divorce a v.m.
NOTICE TO DEFEND AND CLAIM RIGHTS
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 tights 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 of
the Cumberland County Court House, 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 SHt~ULD 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
Two Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or heating.
1086860__1 .DOC
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Donna Made Stevens,
VS.
Edward L. Stevens, Jr.,
) Civil Action - Law
Plaintiff, )
)
) No. Oaq~ ~- 3o~6
)
)
Defendant, ) In Divome a v.m.
COMPLAINT UNDER SECTION 3301(e) OR 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Donna Made Stevens, who currently resides at 205 Meanshollow Road,
Shippensburg, Cumberland County, Pennsylvania, 17257 since approximately May of 2002.
2. Defendant is Edward L. Stevens, Jr., who currently resides at 1175 Baltimore Road,
Shippensburg, Cumberland County, Pennsylvania 17257, since approximately June of 2002.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least
six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 19, 1977 in Shippensburg,
Franklin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. The Plaintiffhas been advised that counseling is available and that Plaintiffmay have the
right to request that the court require the parties to participate in counseling.
8. Plaintiffrequests the Court to enter a decree of divorce.
1086860_1DOC
I verify that the statements made in this Complaint are tree 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.
CX~onna Ma~ri~ Stevens, l~l~ntiff - - -
BARLEY, SNYDER, SENFT & COHEN, LLC.
Date:
Esquir[
Attorney for Plaintiff
1086860_1.DOC
H105,157 REV 9-80
COUNTY
Cumberland
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF HEALTH
VITAL RECORDS
RECORD OF
DIVORCE OR ANNULMENT
[] (CHECK ONE) []
STATE FILE NUM13ER
STATE FILE DATE
HUSBAND
1. NAME (First) (Middle) (Last) 2. DATE OF
Edward L. Stevens, Jr. BIRTH April 1, 1958
3. RESIDENCE (Street; City, 13oroOrTwnshp; County; State) 4.
1175 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania
NUMBER I 6. RACE
OF THIS WHITE BLACK OTHER(SPECIFY)
MARRIAGE 1st [] [] []
PLACE OF
131RTH (State or Country) Pennsylvania
USUAL OCCUPATION
Laborer
WIFE
8. MAIDEN NAME (First) (Middle) (Last) 9. DATE OF
Donna M. Coldsmith BIRTH April 5, 1959
10. RESIDENCE (Street; City, BoroOrTwnshp; County; State)
205 Meanshollow Road, Shippensburg, Cumberland County, Pennsylvania
12. NUMBER /13. RACE
OF THIS i WHITE BLACK OTHER(Specify)
MARRIAGE 1st / [] [] []
15. PLACE OF (County) (State or Foreign Country)
THIS
MARRIAGE Franklin County, Pennsylvania
1713. NUMBEROF 118. PLAINTIFFHE~
DEPENDENT
CHILDREN UNDER 18 HUSBAND WIFE OT (SPECIFY)
o [] []
17A. NUMBER OF
CHILDREN THIS
MARRIAGE
11. PLACE OF
BIRTH (State
or Count~/I Pennsylvania
14. USUAL OCCUPATION
Office automation assistant
2
20. NUMBER OF HUSBAND WIFE SPLIT CUSTODY OTHER(sPECIFY) 21. LEGAL GROUNDS FOR DIVORCE
OR ANNULMENT
CHILDREN TO [] [] [] [] Irretrievable breakdown
CUSTODY OF
22. DATE OF DECREE (Month) (Day) (Year) 22. DATE REPORT SENT TO VITAL
RECORDS
23. SIGNATURE OF TRANSCRIBING CLERK
16. DATE OF
THIS
MARRIAGE February 19, 1977
19. DECREE GRANTED TO
HUSBAND WIFE OTHER(sPECIFY)
1088624-I
Donna Marie Stevens,
VS.
Edward L. Stevens, Jr.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3076 - Civil
In Divorce a v.m.
ACCEPTANCE OF SERVICE
I, WAYNE F. SHADE, Esquire, attorney for Defendant in the above-captioned matter, do
acknowledge that I have received a tree and attested copy of the Complaint Under Section 3301 (c)
or 3301 (d) of the Divorce Code filed in the above-captioned matter on June 26, 2002.
I certify that I am authorized to accept service on behalf of Defendant.
Date:\~D.j~ ~, ~o c~ ~
F. Shade, Esquire
Attorney for Defendant
1086869_1 DOC
Donna Made Stevens,
VS.
Edward L. Stevens, Jr.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3076 - Civil
In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on June 26, 2002.
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 tree 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.
Donna Made ~tevens, Plaintiff
1087696-1
Donna Made Stevens,
VS.
Edward L. Stevens, Jr.,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action- Law
No. 02-3076-Civil
In Divorce a v.m.
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 divome 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 tree 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.
Date:
~ ~nna Made S~6'x~e~s, Plaintiff
1087696-1
Donna Marie Stevens,
VS.
Edward L. Stevens,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3076-Civil
In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on June 26, 2002.
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 tree 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.
Date: 10_o~ $~_ 0,~.
Edward L. Stevens, Defenda~
1087696-1
Donna Marie Stevens,
VS.
Edward L. Stevens,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3076-Civil
In Divorce a v.m.
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 ifI 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 tree 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.
Date: /t9 - ,2g- 15 .L
Edward L. Stevens, Defendant
1087696-1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Donna Marie Stevens,
VS.
Edward L. Stevens, Jr.,
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3076
In Divorce a v.m.
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) of the Divorce Code.
2. Date and manner of service of the Complaint: July 8, 2002 - Acceptance of Service signed by
Defendant's Attorney.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
by Plaintiff, October 28, 2002; by Defendant, October 28, 2002.
4. Related claims pending: Resolved through private Agreement;
5. (a) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: October 30, 2002;
(b) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: October 30, 2002.
BARLEY, SNYDER, SENFT & COHEN, LLC
Walker, Esquire
Attorney for Plaintiff
1124411-1
i! E COURT Of COMMON
IN TH PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
Donna Marie Stevens
........ P~aiBt $._f~$ ............
Verstls
............. Defend~ ..........
DECREE IN
AND NOW,~ .... I..~,1~,, .2. QQ;~, it i'- 's ordered and
decreed that ...~0~A.~zg. szgw~s ............................ plaintiff,
and ... ~pw~. ~. ~T~Y~. ]3.. ................................. 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;
......................... ...................................
Prothonotary