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Home My WebLink About01-5534JESSE L. PALMER, SR., Plaintiff CttRISTAL L. PALMER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001- ~'~t/' CIVIL TERM : CIVIL ACT1ON - 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 divorce is indignities or irretrievable breakdown of the marriage, you ma>' request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT 1S 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 JESSE L. PALMER, SR., Plaintiff CHRISTAL L. PALMER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 200I- ..~ 3 ~ CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff; Jesse L. Palmer, Sr., through his attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Jesse L. Palmer, Sr., is an adult individual who currently resides at 2061 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Christal L. Palmer, is an adult individual who currently resides at 7793 Wertzville Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on November 24, 1995 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff; Jesse L. Palmer, Sr., respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX VERIFICATION 1 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. § 4904, relating to yl~ L. unsworn falsification to authorities. PALMER, SR., Plaintiff CI IRISTAL L. P/kLMER, l)e fendanl NIIS~L~ AND DII~HL : IN I';IF COURT OF C()MMON PIJ!AS ()1: : C[]MBILRI,AND ('O[!NTY. PENNSYI.VANIA : NO. 2001-5534 CIVIL TERM : CIVIL ACTION - I,AW : IN DIV( R(I. AFFIDAVIT OF SERVICE AND NOW. this 11~h day of ()ctober 2001. comes 'lhomas S. l)ichl. Esquire. Attorne', tbr thc J)lainlifl] Jesse 1,. Palmer, Sr., and states that he had cause to be mailed a ccrtilied cop? (71' a Complaint in Divorce to thc Defendant, Christal 1,. Palmer, by certified, restricted delivery, relurn-receipl requested. A copy of said rcccipt is attached hereto indicating service was made on October 10, 2001. Respect full3 submitted, ) I 'I boreas S. l)ichl Attorney for thc Plaintiff One West t ligh Street, Suite 208 Post Office Box 1200 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 2404)893 - }:AX 8PO0 g69~ ~000 0~I 000£ -0'0'0 n I~W pe~n~ul ri ~ e.~,,R~s ~/.~ood .mqmnN elol3~g' glOLI ~I ~Iq~ (~0] ~a '~I '~IhE-ID 's~!u~ed eoecls ~. ~.uo,~ e~uo eta ~o ~tOeCl eql o;~ i:ueo Slq~'llO~l,l¥ · 'no~ ol I:UeO eta u~n;la~ tmo e~ Trna o~ e]eldmoo ~ .~: pue ~: ,~. eu.'e~l e,leldmo0 · JESSE L. PALMER, SR., Plaintiff CHRISTAL L. PALMER, Defendant : IN THE COURT OF COMMON PIJEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-5534 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on September 24, 2001. 2. The marriage of the 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unswom falsification to authorities. Date: ~- / ~-0..~ ~q~_~-c~ {~. 1~)~, CHRISTAL L. PALMER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree in Divoroe 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 iDivorce Decree is entered by the Court and 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. § 4909 relating to unsworn falsification to authorities. CHRISTAL L. PALMER, Defendant FEB 2 2003 JESSE L. PALMER, SR., Plaintiff CHRISTAL L. PALMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5534 CIVIL TERM : : CIVIL ACTION - ][,AW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on September 24, 2001. 2. The marriage of the 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. § fi9~09~ relating to unsworn falsification to authorities· A / } [I · -- ' - Jl~/~'''~ ~-E L. PJ~LMER, SR., Plmn'~i[f"-~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECm : trSI ER §3301(c) TI-IE DIVORCE CODE 1. I consent to the entry of a Final Decree in 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 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 co~ct;I understand that false statements herein are made subject to the penalties ~J?-4 8 Pa.C.S. ,~ 909/f, elating to u_nswom falsification to authorities. __ ' ] /' / / ~ /J ~ tE'L. P,4~ SR., Plaintiff JESSE L. PALMER, SR., Plaintiff CHRISTAL L. PALMER, Defendant PRAECIPE TO : IN THE COURT OF COMMON PI JEAS OF : CUMBERLAND C. OUNTY, PENNSYLVANIA : : NO. 2001-5534 CIVIL TERM : : CIVIL ACTION - ]LAW : IN DIVORCE 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 § 3301(c) 33Gl(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on October 10, 2001 by certified mail, restricted delivery to Defendant, Christal L. Palmer. Code: Code: 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce by the Plaintiff: February 22, 2003; by the Defendant: February 12, 2003. (b) (1) Date of execution of the Plaintiffs Affidavit required by § 3301(d) of the Divorce (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: None 5. (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by § 3301(c) of the Divorce Code: by the Plaintiff: February 22, 2003; by the Defendant: February 12, 2003. Date: March 4, 2003 Thomas S. Diehl, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY StATE Of ~~.~.~.~ ~ PENNA. JESSE L. PALMER: SR... Plaintiff C, HR!RTAI VERSUS I PAl MI:R, Defend~n{ N o. 2001-5534 DECREE IN DIVORCE AND NOW,~ DECREED THAT JESSE L. PALMER, SR. , PLAINTIFF, AND CHRISTAL L. PALMER , 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. ROTHONOTARY