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Home My WebLink About02-3116 JUDE R. SMITH, Plaintiff v, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA : NO, O:2.~ d lit.. eo~L~~ : CIVIL ACTION - LAW t : IN DIVORCE JANELLE A. SMITH, Defendant 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 Office of the Prothonotary at: CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE. CARLISLE, PENNSLVANIA 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 COUNRTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 JUDE R. SMITH PLAINTIFF VI. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLVANIA : NO, O~-3t1Co (3coi.l /~ : CIVIL ACTION - LAW l JANELLE A. SMITH, DEFENDANT : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE AND NOW COMES the above named Plaintiff, Jude R. Smith, and seeks to obtain a decree in Divorce from the above named Defendant, upon grounds hereinafter more fully set forth: COUNT 1 1, Plaintiff is Jude R. Smith, who currently resides at 611 West North Street, Carlisle, PA 17013, having resided so since 1998, Plaintiff's social security number is 201-48-7448, 2, Defendant is Janelle A. Smith, who currently resides at 611 West North Street, Carlisle, PA 17013, having resided so since 1998, Defendant's social security number is 197-38-5208, 3, Plaintiff and Defendant have both 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 August 26, 1994, in Luzeme County, Pennsylvania, 5, The Plaintiff is aware of the availability of counseling and that he may have the right to request that the court require the parties to participate in counseling, 6, There have been no prior actions in divorce or for annulment between the parties, 7, The marriage is irretrievably broken, 8, The Defendant is not a member of the Armed Services of the United States or any of its allies, 9, The Plaintiff and Defendant are both citizens of the United States, 10. Plaintiff avers that there are no minor children of the parties, WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony, Date: {9./~OJ- Respec: ~ JUdO: Smith 611 West North Street Carlisle, PA 17013 (717) 249-5854 VERIFICATION I verify 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, 94904 relating to unsworn falsifications to authorities, (;; ,;)S.-o).- Date ~~ JUDE R. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA VIII. NO. 02-3116 CIVIL ACTION - LAW JANELLE A. SMITH, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 4. A Complaint in Divorce under ~ 3301 (C) of the Divorce Code was filed on June 28, 2002. 5. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filinfl and service of the Complaint. 6. 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 statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: :J J-7.{}3 By: 8 0 ~ w <'" ." ----I "'OeD i'T1 =1= :!'! N' If-' CO i'i'l 2-!-' f"-" -'- N rn 2'-,.",. (::,) (I)~.. -.J J -<.,.c.:.. :~:_, C.J ~CJ -0 . . ,J ""'~.' ".. -r; ~C :t: ," )-- :..,..~(..) :f:;CI .r::- ';5 frI r--- '- b! _..'~ :3 '" :0 ... C\ -< JUDE R. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA VI. NO. 02-3116 CIVIL ACTION - LAW JANELLE A. SMITH, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (C) of the Divorce Code was filed on June 28, 2002. 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 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 statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Date: \ 6/ 31 ~ 200?/ ~-u (') c s:: ""0 OJ mn-: Z::J Zr;,~, (/) ~,,:, ~f= )>0 zc' >c: ~ c W ." ~ CO N -.J ~o 'O.,., ---/ ~~ ;!! ....,m "\0 51. ,,'<J ~~ S; -< -0 ::x - - i') ~ JUDE R. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA VII. NO. 02-3116 CIVIL ACTION - LAW JANELLE A. SMITH, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUESTE ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (C) OF THE DIVORCE CODE 4. I consent to entry of a final decree of divorce without notice. 5. 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. 6. 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. 9 4904 relating to unsworn falsification to authorities. Date: J,'J1~ By: Yde R. Smith, Plaintiff () C 7" '"'0 CD mrT'i Z :x.~.t ZC" ciS ~l;' .::...- / ~C ~Q --c' >c Z ~ o W -rt I"TI CO N -.J o '"11 -:!J -,r:1 t f j '-'0 ..~~ ',}; :!1 ~~O /-m S~ 55 ~ -0 :::ll: r.:- N -.J JUDE R. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 02-3116 CIVIL ACTION - LAW JANELLE A. SMITH, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUESTE ENTRY OF A DIVORCE DECREE UNDER ~ 3301 IC) OF THE DIVORCE CODE 1. I consent to 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. 9 4904 relating to unsworn falsification to authorities. Date: 1D /3' ~ 1ooz,. By: ..~ (") C'.) 0 c (.0,) ..,.; s: '"T\ -oc.c j"T1 '~T" mrn CO Z""" ., r-rl ......... N ZS ::-,C,~'l en 1', ....J 2'~ (J c-C -0 " ~'C' ; -...i :P;C Z ' ) ._- .~;..() .4- (~ ~5rn 5> -' r C --t Z; '" -\> =< (T\ ~ JUDE R. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW' JANELLE A. SMITH, Defendant NO. 02-3116 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of December, 2004, upon consideration of the Praecipe To Transmit the Record, and it appearing that Defendant's affidavit of consent under ~3301(c) of the Divorce Code was executed on October 31,2002, and was not filed until February, 2003, a divorce decree will not be entered at this time, without prejudice to the parties' rights to file a new praecipe to transmit the record when a new affidavit of consent of Defendant has been executed and timely filed. BY THE COURT, J. J. Aude R. Smith 611 West North Street Carlisle, P A 17013 Plaintiff, pro se / '~ (:,3-0 ~ If: v1'"'anelle A. Smith 558 South Hanover Street Carlisle, P A 17013 Defendant, pro se :rc ,ufo !. to,.... "....,---:; :nnJ \~ S :G t"; (" '-, j :'_3Q ~DaZ :JC; JUDE R. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA VII. NO. 02-3116 CIVIL ACTION - LAW JANELLE A, SMITH, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUESTE ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (C) OF THE DIVORCE CODE 4, I consent to entry of a final decree of divorce without notice. 5, 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 granled. 6. 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 lhat 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. S 4904 relating to unsworn falsification 10 authorities. Date: !J-l{,,{7t( By: \~t~ l,C--A, J(Jqe R. Smith, Plaintiff" v' V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA NO. 02-3116 CIVIL ACTION - LAW JUDE R. SMITH, Plaintiff JANELLE A, SMITH, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUESTE ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (C) OF THE DIVORCE CODE 1. I consent to 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 prolhonotary. I verify that the statements made in this affidavit are true and correci. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. (' 'i; / BY:I'5\..lvl-HL -1-( ':1vw,,t( \ iJ~nelle A. Smith, Defendant /,,1 _ 11 L' [)d Date: I.t-f-' '1 VIII. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA NO, 02-3116 CIVIL ACTION - LAW JUDE R. SMITH, Plaintiff JANELLE A. SMITH, Defendanl IN DIVORCE AFFIDAVIT OF CONSENT 4. A Complaint in Divorce under ~ 3301 (C) of the Divorce Code was filed on June 28, 2002. 5, 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. 6, I consent to the enlry 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. , understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relaling to unsworn falsification to authorities. /', Date: l)-,).l,cd By: "~~:-:.;";::~~ JUDE R. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA VI. NO. 02-3116 CIVIL ACTION - LAW JANELLE A. SMITH, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (C) of lhe Divorce Code was filed on June 28, 2002, 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 of divorce afler service of notice of intention to requesl entry of the decree. 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 10 unsworn falsification to authorities. By: c~I\.lLlc ~l . S1fl,:t!\. Janelle A, Smith, Defendant l'Il/lill Date: (J"- lJj JUDE R SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 02-3116 CIVIL ACTION - LAW JANELLE A SMITH, Defendant IN DIVORCE CERTIFICA TE OF SERVICE I, Jude R Smith, Plaintiff, do hereby certify that I am this 26th day of December, 2004, serving a true and correct copy of the Affidavit of Consent upon Janelle A. Smith, Defendant, via postage prepaid first class United States mail addressed as follows: Janelle A Smith 558 South Hanover Street Carlisle, Pennsylvania 17013 '1 . ',,~l, j\~-:,,~,~~~':.-~- Jude R. Snilth, Plaintiff JUDE R. SMITH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 02-3116 CIVIL ACTION - LAW JANELLE A. SMITH, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Jude R. Smith, Plaintiff, do hereby certifY that I am this 31" day of October, 2002, serving a true and correct copy of the Affidavit of Consent upon Janelle A. Smith, Defendant, via postage prepaid first class United States mail addressed as follows: Janelle A. Smith 558 South Hanover Street Carlisle, Pennsylvania 17013 ~ !,; t..J... 'c:7 ID~3ICo... J R. Smith, Defendant /jl\6k R ,~;,~~~ ?I~,,\j{,-\~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS, '-:XV"" It{ ,\ \'"l\,\h) , ' be ~f I'J{/q IVt CIVIL DIVISION NO, L\~ - s II L CIVIL TERM 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 !l3301(c) JJQ1 (s)(1) vi II ,e DivSFGS Csss, (Strike out inapplicable section), 2. Date and manner of service of the complaint: /):'IN<' ,).2, ':'l.o~'"'l 'I (fK-\~' "A rYl.\,(, Lj~es 3, Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by !l3301 (c) of the Divorce Code: by plaintiff b"N>>\PI"''(;) L", .)w-j ; by defendant D<lC'p"",b,<QJl..) J...tXJ-1 (b) (1) Date of execution of the affidavit required by !l3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4, Related claims pending: 5. Complete either (a) or (b). (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 of plaintiff's Waiver of Notice in !l3301 (c) Divorce was filed with the Prothonotary: 1JR('~'n bl~ ,)(, )6~L/ , Date defendant's Waiver of Notice in !l3301 (c) Divorce was filed with the Prolhonotary:\) (, <,,,-, ,''' b@ ;;C, ,.}CCL/ , ,'Ac~ ~ ~i.:~ C/i Attorney for Plaintiff / Defe~dant J(A~\L ~. S(ll ("11-\) .p l~<w1,~+ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ~f\Ne \ k A SI(Y) :\ H) ~l\IJ~w\- CIVIL DIVISION NO, 6;), - 31/ V CIVIL TERM 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 93301 (c) 1~01 (&1)(1) sf thil ni\lr\l"('~ rode. (Strike out inapplicable seclion), 2. Date and manner of service of the complaint: -XIV€' ;J R, dOOd } (f?R1"fFIF,f.) )'1'k, '/ L{,SPS 3, Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff FebR'U\~J ~l) d..bO S ; by defendant C:cn,lSeK' ~ I':) ~1:lo:L (b) (1) Date of execution of lhe affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: 5. Complete eilher (a) or (b). (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 of plaintiff's Waiver of Notice in S3301 (e) Divorce was filed with the Prothonotary: RlxUr./lj d/) ;;1.00 <,. Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: DC1ol!.e< .5 J) ';;002 ~-~ orney for Plaintiff / Defendant '+i'+i'+i:f. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f.:f.;t,:+::f.:+::+: :f.:+: :+::+: :f. ;f.:+: . :+: :+::f.:f. :f.~;f.:f.'+i~~ :f.:+: :f.:f.:f.:f.:+::+::f.:f.~:+::+::+::f.:+::f.'+i:+:~ . .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA, TL\N~ K SM\\~ \)l~\lr(+:~+ No, O;J.-3i/(p VERSUS :fAl\le\\e. A" SIY\IT~ j)e,f€{'IJ~I\l+ DECREE IN DIVORCE AND NOW, D,.,c. 7<;; :::s- I.U~ e.. R. . ~m I '\ l-\- ~A..t\.)e.~I...Q. ~, SmiTH , z.."o"~, IT IS ORDERED AND DECREED THAT , PLAINTIFF, AND , 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; . . . . . . . . . . . . . . . . . . . . . AT c:::1 ':~~ PROTHONOTARY . 'I';t,:+:~;!i :+:'1' ;fH,+ 'f. :f.:f.:f. :f.:f. :f.'+' ... . . . . 'I' ;+. 'I'~;!i . . . ~:+: Of. ~'.f. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . ,* .::?- ~P-vt' ?"ilYlL. 5'v,;; I ~~~~..~ ~/ r?)'iv ->./