HomeMy WebLinkAbout94-01566
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '*' PENNA.
JAYNE D. JOYE
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_A.~l)R~W P.
JOYE
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DECREE IN
DIVORCE
ANDNOW""'~,~,,J,~"",. 19,~,~".
it is ordered and
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decreed that ......,....".. ~!W~~, ,Q., ,.,TPXJ;:, , , .. , .. , .. , .. .. ". plaintiff,
and, , , " " " , , , , " , ", , , , , ,l\~I,ll{~,W , '~'" , ,.;rP:y'Ei., , , , , , , , , , , ". defendant,
are divorced from the bonds of matrimony.
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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;
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JAYNE D. JOYE . IN TilE COURT OF COMMON PLEAS OF
.
PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
. 94 - 1 566
v. .
.
.
ANDREW P. .
JOYE . CIVIL ACTION - LAW
.
DEFENDANT , IN DIVORCE
.
PRAECIPE TO TRANSMIT RECORD
TO TilE PROTHONOTARY:
Transmit the record, together with the following information,
to the Court for entry of a Divorce Decree:
1. GROUNDS FOR DIVORCE: Irretrievable breakdown under Section
( ) 3301(c) OR ( ) 3301(d)(1) of the Divorce Code.
(X) 3301 (a) (1) (Check one)
2, DATE AND MANNER of service of the Complaint:
PUBLICATION BY COURT ORDER, 11/24/95 Sentinel, 12/01/95 LnW J.
3, COMPLETE EITHER PARAGRAPII (a) or (b)):
(a) Date of execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code:
By Plaintiff
; by Defendant
(b) (i)
Date of execution of the Plaintiff's Affidavit
required by Section 3301(d) of the Divorce Code:
(ii) Date of service of the Plaintiff's Affidavit,
upon the Defendant:
4. RELATED CLAIMS PENDING:
NONE
5, DATE AND MANNER OF SERVICE OF TilE NOTICE OF INTENTION TO
FILE PRAECIPE TO TRANSMIT RECORD, a copy of which is
attached, if the Decree is to be entered under Section
3301 (d) (1) (i) of the Divorce Code:
~~
AMES M. BACH
Atto ney 1.0. No. 18727
352 South Sporting Hill Road
Mechanicsburg, PA 17055
(717) 737-2033
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JAMES M. BACH
ATTORNEY AND COl.tlSELORAT LAW
352 SOUTH SPORTING HILL ROAD
MECHANICSBURG, PENNA 17055
,
0(717) 737-2033
...
JAYNE D. JOYE
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 91/- ,,- (, (,
Civil Action
IN DIVORCE
Civi1/~
- Law
ANDREW P. JOYE
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 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 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 on the first floor of the Cumberland
County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE T~E 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,
Court Administration
Fourth Floor
Cumberland County Courthouse
CarliSle, PA 17013
(717) 240-6200
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JAYNE D, JOYE
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 91/. l-s(,t... CIVIL -r:(,,..~
CIVIL ACTION - LAW
vs.
ANDREW p, JOYE
DEFENDAN1'
IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I
AND NOW, comes the Plaintiff, by Attorney James M. Bach,
and avers as follows:
1, Plaintiff is
JAYNE D, JOYE
, who currently resides
at 4707 BRYON ROAD, MECHANICSBURG, PA 17055,
2, Defendant is ANDREW p, JOYE
, who currently resides
at 4707 BRYON ROAD, MECHANICSBURG, PA 17055
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 10/17/87,
5, There have been no prior action of divorce or annulment
between the parties.
6, The marriage is irretrievably broken.
7, Plaintiff has been advised of the availability of
counseling and also the Plaintiff may have the right to request
that the Court require the parties to participate in counseling,
and after being so advised, Plaintiff does not desire counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree in
Divorce.
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By:
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JAHlS M. BACH, ESQUIRE
352 South Sporting Hill Road
Mechanicsburg, PA 17055
(717) 737-2033
Attorney for Plaintiff
Attorney 1.0, No, 18727
VERIFICATION
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein made are
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subject to penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
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JAYNB D. JOYB
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94 - 1566 CIVIL
v,
ANDRBW P. JOYB
Defendant
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
days after this Affidavit has been served on you or the
.
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDBR SBCTION 3301(d)
OF THB DIVORCE CODE
1. The parties to this action separated on MARCH 27, 1994
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 if I 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 unsworn falsifications to authorities.
Date:
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JAYNE 0, JOYE : IN '1'III~ COUn'1' OF CmlMON PLEAS
PLAINTIFF : CUI1OEnLANO COUN'l'Y, PENNSYLVANIA
:
vs, : 94 - 1566 CIVIL I\C'rION
:
ANDREW P. JOYE :
DEFENOANT : IN tJlVOnCE
NO'l'ICE '1'0 OEFEllD AND CLAIM RIGU'rS
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. 1\ judgement may also
be entered against you for any other claim or relief requested
in these papers by the Plaintiff. You may lose money or
visitation of your children.
When the grounds for divorce are indignities or irretrievable
breakdown of the marriage, you may request marriage counseling,
1\ list of marriage counselors is available in the OFFICE OF
TilE PRO'1'1I0NO'1'AnY, on the first floor of I:he Cumberland County
Court 1I0use, Carlisle, Pennsylvania, 17013.
IF YOU 00 NO'1' FILE A CLI\H1 FOR I\LlMONY, OIVISlON OF PROPER'l'Y,
LMIYERS FEES, OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS
GRAN'rED, YOU MAY LOSE 'l'IIE RIGII'1' '1'0 Cr,AII1 ANY OF TIIESE.
YOU SIIOULO TAKE 'l'IIIS PAPER '1'0 YOUR f,AWYER A'r ONCE. I F YOU DO
110T lIAVE 1\ LAWYER OR CANNO'l' AFFORD ONE, GO '1'0, OR '1'ELEPlIONE
TilE OFFICE SET FOR'l'II BELOW 'l'O FIND OU'1' WIIERE YOU CAN GE'r LEGI\L
HELP.
Court Administration
Fourth Floor
Cumberland County Court lIouse
Carlisle, PA 17013
717-240-6200
.
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JAYNE D. JOYE . IN THE COURT OF COMMON PLEAS OF
.
PLAINTIFF , CUMBERLAND COUNTY, PENNSYLVANIA
,
.
.
vs, . 94 - 1566 CIVIL TERM
.
.
.
ANDREW P. JOYE .
.
DEFENDANT . IN DIVORCE
.
AMENDED COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, JAYNE D. JOYE, by her Attorney,
JAMES M. BACH, and avers as follows:
1. Plaintiff is JAYNE D. JOYE, who currently resides at 4707
Bryon Road, Mechanicsburg, PA, 17055.
2. Defendant is ANDREW P. JOYE, who currently resides at 4707
Bryon Road, Mechanicsburg, PA 17055.
3. Plaintiff and Defendant have been bona fide residents of
the Commonwealth for at least six months immediately prior to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on 10/17/87.
5. There have been no prior actions of divorce or annulment
between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling
and also the Plaintiff may have the right to request that the
Court require the parties to participate in counseling, and
after being so advised, Plaintiff does not desire counseling.
Page 1,
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8. The Defendant wilfully and maliciously deserted the
Plaintiff. The Defendant has been absent from the dwelling house
of the parties, without reasonable cause, for a period of one
or more years. The Defendant absented himself from the marital
abode without the knowledge, information or consent of the
Plaintiff and has not revealed his whereabouts or presence to
the Plaintiff since the time of departure which was on or about
March 27, 1994. Since March 27, 1994, Plaintiff has made
diligent efforts to find the Defendant and these efforts have
not been successful.
Since the time of desertion, the Defendant has not communicated
with the Plaintiff or any of the Plaintiff's family members,
and has made no attempts to have his whereabouts known to the
Plaintiff for service of process, or otherwise.
WHEREFORE, Plaintiff requests the Court to enter a Decree in
Divorce,
Page 2
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/6/~(f~ By:
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S H. BACII, ESQUIRE
South Sporting lIi11 Road
Hec anicsburg, PA 17055
(717) 737-2033
Attorney for Plaintiff
Attorney I,D, No, 18727
VERIFICATION
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein made are
subject to penalties of 18 Pa, C,S, 4904, relating to unsworn
falsification to authorities.
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II
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587. upproved Muy 16, 1929), P. L.1784
STATE OF PENNSYLVANIA:
55.
COUNTY OF CUMBERLAND:
Roger M, Morgenlhal, Esquire. Editor of the Cumberland Law Journal. of the County
and Stute aforesaid, being duly sworn, according to law, deposes and says thutthe Cumberland
Law Journal. II legal periodical published in the Borough of Carlisle in the County and Stute
Ilforesaid. was estllblished January 2. 1952. und designated by the local court.~ as the official
legal periodiclll for the publication of all legal notices, and has. since January 2, 1952. been
regularly issued weekly in the sllid CountY.llnd thlltthe printed notice or publication attached
hereto is exactly the same n.~ was printed in the regular editions and issues of the sllid
Cumberland Law Journal on the following dates,
viz:
DECEMBER I. 1995
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal. Illegal periodicul of general circulation. and that he is not interested in the subject
mailer of the Ilforesaid notice or advertisement. and that ull ullegations in the foregoing
stutements n.~ to time. place und charucter of publication ure true.
~ /11 tllt'"'-^-
Roger M. Morgenthal. ditor
SWORN TO AND SUBSCRIBED before me this
01 duyof DECEMBER ,1995
l1]~ AlbA ~~WL~
Notary
NOTARIAL SEAl
MERlENE lIARHEVIC.I. NolIIy PIllli:
Cirillo, CIIItoltIndColnY, Po.
II Comm_ EJpinIoHl
~
NOTICE
DEFOllE A DIVORCE OR ANNUL-
MENT IS GRANTED, YOU MAY LOSE
TIlE RlOI rrlOC(.o\JMANY OFTIlESE.
YOU SIlOULDTAKETIlISNanCE
TOYOURlJ.WYERATONCE,IFYOU
DO Nor f1AVE A LAWYER OR CAN,
Nor AFFORD ONE, GOlO, OR1l!:LE.
PflONE TIlE OFFICE SET FORTI!
DELOW TO FIND OUT WHERE YOU
CAN GET LEGAL f1ELP,
Court AdmlnlslrnUon
Fourth Floor
Cumberland County Court Mou""
CarUsle. PA 17013
717.240.6200
In the Court of Common l'lena
Cumberland County. PenJ18ylvnnla
94.1566 Civil Term
JAYNE 0, JOVE
PLAlN11FF
Vll,
ANDREW p, JOVE
DEFENDANr
Dee,I
COMPLAllIn'lN DIVORCE
NanCE 1'0 DEFEND
AND CLAIM RIGHTS
You have been sued In Court. Ir
you wl8h to defend. you mUllt take
prompt BcUon. You must enter a
wrttten appearance pe"",naUy or by
attorney and me your defelUlell or
obJecU0n8 In wrtUng wtth the Court.
You are warned that If you faU to do
110. the c.... may proceed wtthoutyou
and a decree In divorce or annulment
may be entered aga\n8t you by the
Court, AJudgement may u1llo be en.
tered agaInlIt you wtthout further no-
Uce for any other claim or reuer....
quested by the PlalnUff, You may lose
money or properly or vIIIlluUon of
your chUdren,
When the grounds for dIvorce are
IndlgnlUes or Irretrlevable break.
down of the mantage, you may reo
quest marriage coUlUlellng, A Ust of
ml1l'l1oge coulUlelom 18 avuJlable In
the OFFICE OF TIlE PR01ll0NO.
TARY. on the llnlt Door of the Cum.
berland County Court Mou"", Cur.
Usle. PelUlllylvnnla 17013,
IFYOU DO Nor FILE AC(.o\JM FOR
ALIMONY. DMSION OF PROPER1Y,
LAWYERS FEES, OR EXPENSES.
4
Cumberland Notice.
f.,._,.,....~.,~~
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State of PennsylvanIa,
ss'
County of Cumberland, .
Marian M. Welsh of THE SENTINEL,
of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of
general circulation In the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881,
slnca which date THE SENTINEL has been regularly Issued In said County, and that the printed notice or
publication allached hereto Is exactly the same as was printed and published In the reular editions and Issues of
THE SENTINEL on the following dates, vlz
Copy of Notice of Publication
IlAYNID,JOYI"
, .... l'LAIlITl'"
. ...,....
November 24, 1995
va':' "
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AllDIIIW,o ;.on,. .
, ' _,DIII'IHO~.c _-',I',
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"IN TH. COUIlT 0'
_lION ,LIA... '
, . cunlllUHD COliim',
.,- 'I'IlINaYLVANlA.'
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, ,M;IMlCMLTlllII'
L :;'> r ':'"-,,,
" "";-;)i#I,LAiNrIN'DIYORCI
,'.....".; .l.,.-i _ ,., ,'.
:,;,,~_aIIJl
,;,.,': '.....: ~', ':: ,-",'.. .\'. ":.' .'. '. '
,;. yoU 11M bOon _In Courl. K you wIIh 10
, ' dIIond. you muolllU prompt.Ctlon, You
. m"'_' __ po1IOIlIIlyot
, ..,.llomIyoncllloyourdo_. otabjlcllan.
.1n__....COUrt. You ""' wamod DIll.
you 11I10 do 10. !hI_ m.y pIOCHd_
you and. decrH.,.. cIvoR:e or annulm,nt mly
be _ .goJnIl you by !hi Court. A
~ntm.y_be .nI_ .goJnIlyou
_ furtIlI,_1or any oIhI,cIoim Of
_I roquDIad by tho Plolnllll, You may 10M
ononoyot_rtyOfvillllltlonol\'OU,...drIn,
_n!hl gRlUndt IOfdlYon:. _lndlgn'U..
or ItmritvabIe btlelr:down of the merrtaOf/ you
mey NqUtI' mantage COUnHllna, A hit 0
morJtooo_noolorolo ..._..!hI OFFICE
OF TH1: PROTHONOTARY, on lho lirIt_
01 !hi Cum_ County COurt Hou..,
~. P.MIyIvonlo 17013, '
IF YOU 00 NOT FILE A CLAIM FOR ALIM()o
.NY OMSIONOFPROPERTY,LAWYERS
FEES, OR EXPENSES, SEFORE A DIVORCE
OR ANNULMENT IS GRANTED, YOU MAY
LOSE THE RIGHT TO CLAIM ANY OF ,
THESE.
I YOU SHOULO TAKE THIS NOnCE TO
YOUR LAWYER AT ONCE. IF YOU 00 NOT
I HAVE A LAWYER OR CANNOT AFFORD
, ONE. GO TO. OR TELEPHONE THE OFFICE
, BET FORTH SELOW TO FIND OUT WHERE
,YOU CAN GET LElIALHELP,
I COurlAdm_'
--,
C_Counl1__
_,'Allllll .
71T-I_
Affiant further deposes that he Is not Interested In
the subject matter of the aforesaId notice or
advertisement, and that all allegations In the
foregoIng statement as to time, place and character
of publication are true.
n;ttfA- -:??! td4L
12/12/95
Sworn to and subscribed before me thIs 12th
day of December .19 95
~ /-- ~arYPUbIlC
My commission expires:
Notarial Seal
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JAYRB D. JOm
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94 - 1566 CIVIL TERM
vs.
AImRBW P. JOm
DEFENDANT
IN DIVORCE
ORDER
AIm NOW, on this day of
upon consideration of the within MOTION
PUBLICATION, leave is hereby granted to
Process, by Publication.
, 1995,
TO ALLOW SERVICE BY
obtain Service of
BY THE COURT:
J.
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.
.
.
JAYRB D. JOYB
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PBNNSYLVANIA
va.
94-1566
CIVIL TERM
AImRBW P. JOYB
Defendant
IN DIVORCE
MOTION TO ALLOW SERVICE BY PUBLICATION.
AIm NOW comes the Plaintiff JAYRB D. JOYB, by her Attorney
JAMBS M. BACH, and fUes the within MOTION TO ALLOW SERVICE
BY PUBLICATION :
1. The Plaintiff is JAYNE D. JOYE, an adult individual,
residing at 4707 Bryon Road, Mechanicsburg, PA 17055.
2. Defendant is ANDREW P. JOYE, an adult individual, whose
last known residence was 4707 Bryon Road, Mechanicsburg, PA
17055.
3. On or about March 30, 1994, the Plaintiff commenced
an action in the Court of Common Pleas of Cumberland County,
seeking a Divorce.
4. On or about March 27, 1994, the Defendant wilfully
and maliciously deserted the Plaintiff without just cause. The
Defendant absented himself from the marital home without the
knowledge, information or consent of the Plaintiff, and has
not, since that time revealed his whereabouts to the Plaintiff
or any member of her family.
5. All reasonable and diligent efforts have been made
to locate the Defendant and to ascertain his whereabouts. Set
efforts are more particularly described in attached exhibit.
See Exhibit "A".
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6. The Plaintiff reasonably believes that she will never
be able to find the exact location of the Defendant and ahe
will never be able to serve process upon him.
WBBRBFORB, the Plaintiff respectfully
be granted to serve the process upon
publication, according to Pa. R.C.P. 430(b).
requests that leave
the Defendant, by
Reapectfully aubmitted,
DATE: 11/02/95
~BACB~~
Atto ney I.D. No. 18727
352 S. Sporting Hill Road
MECHANICSBURG, PA 17055
(717) 737-2033
.
.
"
JAYRB D. Jon
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PBNNSYLVANIA
VB.
94-1566
CIVIL TERM
ANDRBW P. JOYB
Defendant
IN DIVORCE
AFFIDAVIT OF INVESTIGATION.
James M. Bach, Esquire, being duly sworn according to law,
depose and says that he is an attorney at law duly authorized
to practice law in the County of Cumberland, Commonwealth of
Pennsylvania, and that the following information is true and
correct to the best of his knowledge, information and belief:
1. Plaintiff is JAYNE D. JOYE, who currently resides
at 4707 Bryon Road, Mechanicsburg, PA 17055.
2. Defendant is ANDREW P. JOYE, whose last known address
was 4707 Bryon Road, Mechanicsburg, PA 17055.
3. On or about March 30, 1994, the Plaintiff commenced
an action in the Court of Common Pleas of Cumberland County,
seeking a Divorce.
4. On or about March 27, 1994, the Defendant deserted
the Plaintiff and has not revealed his whereabouts or presence
to the Plaintiff since the time of departure.
5. The Plaintiff and her Attorney has made a good-faith
efforts to locate the Defendant and to ascertain his whereabouts,
in order to serve process upon him.
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6. There has been no contact between the parties of any
nature or sort since the date of separation.
7. The Plaintiff has no knowledge as to former residences
of the Defendant and knows very little about his background.
and
8. The
they had
Plaintiff contacted Defendant's
no knowledge of his whereabouts.
former
employer
9. The Plaintiff made inquiries with the postal authorities
to no avail. The Post Office indicated there are no records
of any address changes made by the Defendant.
10. Michael Oleyar, a law clerk for Attorney James M. Bach,
contacted Cumberland County Clerk of Courts and attempted to
ascertain an address of the Defendant. The Defendant has
no criminal record in Cumberland County.
11. Michael Oleyar, the law clerk for James M. Bach,
personally appeared in the Clerk of Court's Office of Dauphin
County to ascertain a prior address of the Defendant. The
Clerk of Court's Office in Dauphin County revealed the last
known address of the Defendant to be 19 Jury street, Highspire,
Pennsylvania.
12. Michael Oleyar personally went
street, Highspire and attempted to serve process.
was not found at 19 Jury street, Highspire
not known to the residents living at that address.
to 19 Jury
The Defendant
and he was
13. The Plaintiff avers and believes that all reasonable
and diligent efforts have been made by the Plaintiff and her
Attorney to serve process upon the Defendant, without success.
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ReBpectfully submitted,
DATE: 11/02/95
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BACH, BSQUIRE
rney 1.0. No. 18727
S. Sporting Hill Road
ME ANICSBURG, PA 17055
(717) 737-2033
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JAYNE D, JOVE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
ANDREW P. JOVE,
DEFENDANT
94-1566 CIVIL TERM
ORDER OF COURT
AND NOW, this 6th day of November, 1995, plaintiffs affidavit should be
amended to provide any Information plaintiff may have as to the name and addresses
of any relatives of defendant, and If such information is known, that efforts were made
through such sources to obtain a current address of defend any
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By the co~ry,':I"
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Edgar B, ley, J,
James M. Bach, Esquire) /
For Plaintiff elrptl "''Iollldu{ 'I ~/q r
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Nav II ~ 3iAH '95
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JAYRB D. JOYB
PLAINTIFF
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94 - 1566 CIVIL TERM
AImRBW P. JOYB
DEFENDANT
IN DIVORCE
AND NOW, on this
consideration of
PUBLICATION, leave
by Publication.
ORDER
11 day of fI)~ , 1995, upon
the within MOTION TO ALLOW SERVICE BY
is hereby granted to obtain Service of Process
BY THE COURT:
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JAYRB D. JOYB
Plaintiff
IN THE COURT OP COMMON PLEAS
CUMBERLAND COUNTY, PBNNSYLVANIA
VB.
94-1566
CIVIL TERM
ANDRBW P. JOYB
Defendant
IN DIVORCE
MOTION TO ALLOW SERVICE BY PUBLICATION.
AND NOW comes the Plaintiff JAYNE D. JOYB, by her Attorney
JAMBS M. BACH, and files the within MOTION TO ALLOW SERVICE
BY PUBLICATION :
1. The Plaintiff is JAYNE D. JOYE, an adult individual
residing at 4707 Bryon Road, Mechanicsburg, PA 17055.
2. Defendant is ANDREW P. JOYE, an adult individual, whose
last known residence was 4707 Bryon Road, Mechanicsburg, PA
17055.
3. On or about March 30, 1994, the Plaintiff commenced
an action in the Court of Common Pleas of Cumberland County,
seeking a Divorce.
4. On or about March 27, 1994, the Defendant wilfully
and maliciously deserted the Plaintiff without just cause. The
Defendant absented himself from the marital home without the
knowledge, information or consent of the Plaintiff, and has
not, since that time revealed his whereabouts to the Plaintiff
or any member of her family.
5. All reasonable and diligent efforts have been made
to locate the Defendant and to ascertain his whereabouts. Set
efforts are more particularly described in attached exhibit.
See Exhibit "An.
. "
. It .
5. All reasonable and diligent efforts have been made
to locate the Defendant and to ascertain his whereabouts. Set
efforts are more particularly described in attached exhibit.
See Exhibit "A".
6. The Plaintiff reasonably believes that she will never
be able to find the exact location of the Defendant and she
will never be able to serve process upon him.
WIIBRBFORE, the Plaintiff respectfully
be granted to serve the process upon
publication, according to Pa. R.C.P. 430(b).
requests that leave
the Defendant, by
ReBpectfully Bubmitted,
DATE: 11/1 0/95
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J~S ~ BACH, ESQUIRE
Attorney I.D. No. 18727
352 s. Sporting Hill Road
MECHANICSBURG, PA 17055
(717) 737-2033
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JAYNE O. JOYB . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VS. . 94-1566 CIVIL TERM
.
.
.
AImRBW P. JOYB .
.
Defendant . IN DIVORCB
.
AMBNDBD AFFIDAVIT OF INVESTIGATION.
James M. Bach, Esquire, being duly sworn according to law,
deposes and says that he is an attorney-at-law, duly authorized
to practice law in the County of Cumberland, Commonwealth of
Pennsylvania, and that the following information is true and
correct to the best of his knowledge, information and belief:
1. Plaintiff is JAYNE D. JOYE, who currently resides
at 4707 Bryon Road, Mechanicsburg, PA 17055.
2. Defendant is ANDREW P. JOYE, whose last known address
was 4707 Bryon Road, Mechanicsburg, PA 17055.
3. On or about March 30, 1994, the Plaintiff commenced
an action in the Court of Common Pleas of Cumberland County,
seeking a Divorce.
4. On or about March 27, 1994, the Defendant deserted
the Plaintiff and has not revealed his whereabouts or presence
to the Plaintiff since the time of departure.
5. The Plaintiff and her Attorney has made a good-faith
efforts to locate the Defendant and to ascertain his whereabouts,
in order to serve process upon him.
1 .
E.')(fil ~ IT 'Aft
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6. There has been no contact between the parties of any
nature or sort since the date of separation.
7. The Plaintiff has no knowledge as to former residences
of the Defendant and knows very little about his background.
8. The Plaintiff haB no knowledge of the Defendant'B
relativeB - does not know who they are, where they reside,
their relationship to the Defendant, and indeed, does not even
know if there are any relativeB at all.
and
9. The
they had
Plaintiff contacted Defendant's
no knowledge of his whereabouts.
former
employer
10. The Plaintiff made inquiries with the postal authorities
to no avail. The Post Office indicated there are no records
of any address changes made by the Defendant.
11. Michael Oleyar, a law clerk for Attorney James M. Bach,
contacted Cumberland County Clerk of Courts and attempted to
ascertain an address of the Defendant. The Defendant has no
criminal record in Cumberland County.
12. Michael Oleyar, the law clerk for James M. Bach,
personally appeared in the Clerk of Court's Office of Dauphin
County to ascertain a prior address of the Defendant. The
Clerk of Court's Office in Dauphin County revealed the last
known address of the Defendant to be 19 Jury street, Highspire,
Pennsylvania.
13. Michael Oleyar personally went to 19 Jury
street, Highspire and attempted to serve process. The Defendant
was not found at 19 Jury street, Highspire and he was
not known to the residents living at that address.
2.
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14. The Plaintiff avers and believes that all reasonable
and dUigent efforts have been made by the Plaintiff and her
Attorney to serve process upon the Defendant, without success.
ReBpectfully submitted,
DATE
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~s M. BACH, BSQUIRE
orney I.D. No. 18727
2 S. Sporting Hill Road
MECHANICSBURG, PA 17055
(717) 737-2033
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e. MAIDEN NAME
KAUFFMAN
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JAYNE D. JOYE
StrHf tJt R_O. CIf)( 8oto tJt "*p. County
Hills Road, Apt. #6, Dillsburg, PA 17019
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ANDREW
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(Sf." (W FotwIgn CounIryJ
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I. NUMBER
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10. RESIDENCE
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(m." Of FotwIgn CounIryJ
Pennsylvania
". Pl.ACE OF (CounIr) (sr." Of Fcwfgn Country) 1.. DATE OF I-I _, /rHO
THIS Cumberland Pennsylvania THIS 10 17 87
MARRIAGE MARRIAOE
17A. NUMBER OF 170. NUMBER OF DEPENDENT ,. PLAINTIFF 11. DECREE GRANTED TO
CHILDREN THIS CHILDREN UNDER 11 HUSBAND WIFE HUSBAHD WIFE OTHER 1_
MARRIAGE 0 0 0 [jg 0 [] 0
20. NUMBER OF HUSBAND WIFE SPlIT CUSTODY DTHER (SPKlty)
CHILDREN TO 0 0 0
CUSTODY OF
... DATE OF DECREE (Month) IIMrI (IN'I
... SIGNATURE OF
TRANSCRIBING CLERK
DATE REPORT SENT (AIonIh}
TO VITAl. RECORDS
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2'. LEGAL GROUNDS FOR
DrYORCE OR ANNULMENT
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In The Court Of Common Pleas Of Cumberland County Prothonotary's Office
COURTHOUSE
Carlisle, pa 17013
Civil Action No.: 1994-01566
JOYE ANDREW P
4707 BRYON ROAD
MECHANICSBURG PA 17055
JOYE JAYNE D
Plaintiff
** VERSUS **
JOYE ANDREW P
Defendant
You are hereby notified that a Decree in Divorce was entered
in the above captioned case on January 16, 1996. This letter should
not be used in place of the actual Decree. If you desire a certified
copy of this Decree, you can obtain the same by coming into ou~~ J . L
office, Please bring this letter with you. The fee is $?t?O (Ja()h tn ~~
If request is made by mail, please enclose $ 9.00 for the
Defendants copy of Decree. Also, do not forget to indicate Civil
Action No. on your request.
Sincerely yours,
~t~j,l1J~-' [f, /tj~,
Pro honotary /.e L
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '*
PEN NA.
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JAYNE D. JOYE
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ANDREW P.
JOYE
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DeCREE IN
DIVORCE
AND NOW, ""~,~"J,~""" 19,~,~", it is ordered and
decreed that ..,.."..'..,.. ~,Jl;~~t:..Q., ,.;JPX~, , .. , ..' , .., , , .. .., plaintiff,
and, .. , , ,.. , .. , , .. , .., .. .. ,Jl;~J;>~~ .. r,... ,.;J9XE;.. , .. , , .. , .. , " defendant,
are divorced from the bonds of matrimony,
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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;
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