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Home My WebLink About02-3114HERMAN W. COLLINS, JR., VS. VALERIE COLLINS, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. oa - CIVIL ACTION - AT LAW IN DIVORCE 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 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 Ofiice of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT Fn.g. 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 SIIOULD 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 Wm~RE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 HERMAN W. COLLTNS, JR. VS. VALE P~T~ COT,LTNS, Defendant IN THE COURT OF COMMON PT,~,AS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3801(c) or 3801(d) The Plnlutiff, Herman W. CO111nA, Jr., by and through his attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following ComplAint in Divorce: 1. The Plai~tifF~ Herman W. C0111nA, Jr., is an adult individual who resides at 142 W. Penn Street, Cumberland County, Carliale, PennsylvAnia 17013. 2. The Defendant, Valerie Co111nA, is an adult individual whose current mnillng address is 3426 Greatneck Road, .Amltyville, New York. 3. The P1Aint2ff has been bona fide resident of the Commonwealth of Penn.~ylvAnla for at least six months immediately prior to the filing of thls ComplAint. 4. The PlAintiff and the DefendAnt were married on April 19, 1971 in Suffolk County, New York. 5. There have been no prior actions of divorce or for aanulment between the parties. 6. The marriage is irretrievably broken. HERMAN W. COLLINS, JR. Plain~ VS. VAI,F, RIE COLLINS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. : : CIVIL ACTION - LAW : IN DIVORCE V~T{T1VT~ ATTOI~d I verify that the statements made in ~:hig Complaint 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 ful.ui~cation to authorities. I-I~RMAN W. COta,rNS, JR. Plaintiff VS. VAL~,I~.rm, COLLr~IS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBE~ COUNTY, PENNSYLVANIA :No. OD---- : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS I~301(c) or 3301(d) The Plaiutiff; Herman W. Collins; Jr., by and through his attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce: 1. The P]alntiff, Herman W. Collins, Jr., is an adult individual who resides at 142 W. Penn Street, Cnmberland County, Carlisle, pennsylvania 17013. 2. The Defendant, Valerie Collins~ is an adult individual whose current moiling address is 3426 Greatneck Road, ~mltyville, New York. 3. The Plaintiff has been bona fide resident of the Commonwealth of pennsylvania for at least six months immediately prior to the Sling ef thls ComplAint. 4. The Plaintiff and the Defendant were married on April 19, 1971 in Suffolk County, New York. 5. There have been no prior actions of divorce or for annnlment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that court.ling is available and that the Plaintiff may have the right to request that the court require the parties to participate in ~o~l~g. 8. Th~.~ action is not conus/ve. WHEREFOKE, the Pl~tiff requests th~.~ Honorable Court to enter a Decree of Divorce in ~h~.~ matter. Resp..e~ffully/submitted, Matthew J. E[sh~ an, Esquire 2108 Market Street, Aztec Bui!d~ng CAmp H/Il, penn.~ylvAnla 17011-4706 ~ 72655 Tel. (717) 763-1800 HERMAN W. COI,LrNS, JR. Plai~ VS. V~T,ERI~ COT,T,TNS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, pENNSYLVANIA : No. : : CIVIL ACTION - LAW : IN DIVORCE I verify that the statements made in ~hi.~ Compluint are true and correct. I understand that false statements her~n are made subject to the penalties of 18 Pa.C.S. § 4904, relating to ,,~.~wom falsi/ication teauthorities. Herman W. Colllns, Jr. HERMAN W. COLLINS, JR. Plaintiff VS. VALARIE COLLINS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 02-3114 : : CIVIL ACTION- LAW : IN DIVORCE PRAECIPE FOR NAME CORRECTION TO THE PROTHONOTARY: Please be advised the correct spelling of the Defendant's first name is VALARIE, not VALERIE. Kindly correct the caption of the case as set-forth above. Date: Res ~iled, Mat Mw J.~shelman, Esquire 2108 Marke~t Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 HERMAN W. COLLINS, JR. Plaintiff VS. VALARIE COLLINS, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 02-3114 · CIVIL ACTION- LAW · IN DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON' YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on/in 1980 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken· 3. 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. 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 unswom falsification to authorities· Herman W. Collins, Jr., Plaintiff/ HERMAN W. COLLINS, JR. Plaintiff VS. VALARIE COLLINS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 02-3114 : : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENTION TO ]REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: VAI,ARIE COLLINS, Defendant 3426 G-reatneck Road Amityville, NY 11701 You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after the 5th day of February, 2003, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a coumer-affldavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have akeady filed with the court a written claim for economic relief, you must do so by the above date, or the court may grant the diwarce and you will lose forever the fight to ask for economic relief. The filing of the attached form counter-affidavit alone does not protect your economic claims. 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 Wi~RE YOU CAN GET LEGAL 1;ELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3115;6 HERMAN W. COLLINS, .IR. Plaintiff VS. VALARIE COLLINS, Defendant · IN THE COLrRT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 02-3114 · CIVIL ACTION - LAW · IN DIVORCE COUNTER-AFFIDAVIT UNDER § 3301(d) OF ~ DIVORCE CODE 1. Check either (a) or (b): [] (a) I do not oppose the entry of a divorce decree. [] (b) I oppose the entry ora divorce decree because: Check (i), (ii), or both: [] (i) The parties to this action have not lived separate and apart for a period of at least two years. [] (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): I"i (a) I do not wish to make any claims for economic relief. 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. [] (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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: Valarie Collins, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT HERMAN W. COLLINS, IR. Plaintiff VS. VALARIE COLLINS, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERL~ND COUNTY, PENNSYLVANIA · No. 02-3114 · CIVIL ACTION - LAW · IN DIVORCE AI~'II~A~ t31~ SERVIC[] TO THE PROTHONOTARY: I, Matthew J. Eshelman, Esquire, verify that the Complaint in Divorce has been Served upon the Defendant indicated above by first class, Certified Mail No. 7000-1670-0005.2769_3586, postage prepaid, remm receipt requested, pursuant to the requirements of Pa. R.C.P. 1930.4. I mlrd to ),uu. I ~AU Cl m~U: -,, t a~___.~thlsfon'ntothofrontofth~mailpi~,m, onth~backif~kme~ ! 1 I--I Addressee's Add · .g"~""~,~ ~,~ a,~,~.o, ~.-...,,-- b,~ ........ I '-~ _n~ I ..... ' ! Conault _ooe__b~, for fee ~! 3, A,~-_---~e .~a,~,~.,___~_-_.~_ to: ~ 14& Afl]cie N~mber ...... ' ~ V ~ ~ L~/~ ~~ '~, );~ . 14b. Service Type ~ [] Registered !! A/V--// I [] '~o ~.,,, ~ 1, ~,G~,:.-~.~,- 1...T ~ ~o~,~-~7-~o~7~ Doml4~ic R4Kum Receipt Date: _ ~/,lo ]~)~ Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill. Pennsylvania 17011-4706 IDg 72655 'I'd. (717) 763-1800 HERMAN W. COLLINS, JR. Plaintiff VS. VALARIE COLLINS, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 02-3114 · CIVIL ACTION - LAW · IN DIVORCE PRA~IPE Tf} TRANe'MIT R~f~RYI To the Prothonotary: Transmit the record, together with the following i~.fforrnafion, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown trader f.~ofOi(v) § 3301(d)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and Manner of service of the Complaint: Service by certified mail #7000-1670-0005-2769-3586, delivered on July 20, 2002. See attached Affidavit of Service. 3. (Complete either paragraph (a) or (3).) (a) Date ofexecufion of the affidavit ofeonsent required by § 3301(e) of the Divorce Code: by the Plaintiff by the Defendant (b) Date of'execution of the afl~davit r~exluired by § 330 l(d) of the Divorce Code: De~e~nher lg. Date of filing of the Plaintiffs afl]davit ~m-thaa;~mdeat: Do~emhm- Date of service of the Plaintiffs affidavit upon the respondent: 4. Related claims pending: Nnno. 5. No elalrn.~ (Complete either paragraph (a) or (3)0 (a) Date and manner of service of'the Notice of Intention to File Praecipe to Transmit Record, a:~opy of'which is attached, (b) Date Plaintiffs Waiver of'Notice in § 3301(c) Divorce was filed wi~ the prothonotary: Date Defendant's Waiv~ the prothonotary: iled with Matthew $. Eshel~an, Esquire 2108 Market Street, Aztec Building Camp ~ Peansylvania 17011-4706 II~ 72655 Tel. (717) 763-1800 iN HERMAN W. THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~~ PENNA. COLLINS, JR., Plaintiff VERSUS VALARIE COLLINS, Defendant NO. 02-3114 PLEAS DECREE iN DIVORCE AND NOW, DECREED ThAT AND HERMAN W. COLLINS, JR. VALARIE COLLINS ARE DIVORCED FROM THE BONDS OF MATRIMONY. , _2003 , it iS ORDERED AND , 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; NONE. ATTEST: