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HomeMy WebLinkAbout02-3201 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Karen D. Garrett, Plaintiff V. Jeffrey M. Garrett, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002- ~ol ClVILTERM : : CIVIL ACTION - LAW : IN DIVORCE NOTICE 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, 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 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. Date: ~,. Z.~'-iD '~- Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY By: ~ John n~f-//~-e pecJ~, Esq u ir~ SupreCNe Cour~ #531~¢ 26 West High Street~ Carlisle, PA 17013 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Karen D. Garrett, Plaintiff V. Jeffrey M. Garrett, Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 3.lo ! CIVILTERM : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Karen D. Garrett, who currently resides at 15 Annondale Drive, Carlisle PA 17013, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey M. Garrett, who currently resides at 111 S. Walnut Street, Mechanicsburg PA 17013, Cumberland County, Pennsylvania. 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 July 12, 2001 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The mardage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Respectfully submitted, SAIDIS,~~SAY Date: ~- Z~-c~"'L-- BY':hn ~-'/' "~qu""~,JO p~/.~~ ire/ Sup[~,fle Coup(ID #531~7~ 26 West High SJme~c~- Carlisle, PA 17013 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA AFFIDAVIT I, Karen D. Garrett, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and participate in counselling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: I{aren D. Garrett, Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY A'ITOR~N~YS*AT*LAW 26 W. High Street Carlisle, PA VERIFICATION I vedfy that the statements made in this Complaint are true and correct. I understan( that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: K'aren D. Garr~-tt, Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA KAREN D. GARRETT, PLAINTIFF JEFFREY M. GARRETT, DEFENDANT IN THE COURT OF COMMON PLEAS NO. 2002 - CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE On this ff~day o~/~ , 2002, I, Adele Group, hereby certify that I served a tree and correct copy of the foregoing Divorce Complaint via United States Mail, Certified, Restricted Delivery, Return Receipt Requested, postage prepaid, addressed as follows: Jeffrey M. Garrett 111 S. Walnut Street Mechanicsburg PA 17055 SAIDIS, SHUFF, FLOWER & LINDSAY Adele Group SA/DIS SHUFF, FLOWER & LINDSAY A~RNEY$.AT.LAW 26 W. High Street Carlisle, PA Karen D. Garrett, Plaintiff Vo Jeffrey M. Garrett, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3201 CIVIL ACTION - LAW IN DIVORCE · Complete items 1, 2, and 3. AJso complete item 4 if Restricted Delivery is desirsd. · Print. your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 2. Article Number (Transfer from service label) PS Form 381 1, August 2001 If YES, enter [] Agent [] Addressee C. Date of Delivery 17 [] Yes [] Certified Mail ': ', [] Registered {e~urn Receipt for M~andlse [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) {~es Domestic Return Receipt Karen D. Garrett, : Plaintiff : .. v. .. : Jeffrey M. Garrett, : Defendant : .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3201 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 12, 2001. 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 in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA aren D. GarrettTPlaintiff Date: /~ ~ ~ ¥- ~ ~ Karen D. Garrett, Plaintiff Jeffrey M. Garrett, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3201 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST _ENTRY OF A DIVORCE DECREE UNDER _SECTION 3301(c) OF THE DIVORCE CODF I consent to the entry of a final Decree of Divorce without notice. 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification 1:o authorities. SAIDIS SHIJFF, FLOWER & LINDSAY AT~ORNEYSeAT*LAW 26 W. High Street Carlisle, PA t~aren D. Garre~Tlafaintiff Date: / 8 ~ ~ Y- o z___ SAIDIS SHUFF, FLOWER & LINDSAY ATtORNEYS.AT.LAW 26 W. High Street Carlisle, PA Karen D. Garrett, Plaintiff v. : NO. 2002-3201 : : CIVIL ACTION - LAW : IN DIVORCE Jeffrey M. Garrett, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 12, 2001. 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 in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification 11o authorities. SAIDIS SHUFF, FLOWER & LINDSAY ATtORNEYS,AT*LAW 26 W. High Street Carlisle, PA Karen D. Garrett, Plaintiff v. : NO. 2002-3201 : : CIVIL ACTION - LAW : IN DIVORCE Jeffrey M. Garrett, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDE~ SECTION 3301(c) OF THE DIVORCE CODF I consent to the entry of a final Decree of Divorce without notice. 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. SAIDIS SHUFF, FLOWER & LINDSAY 26 gr. High Street Carlisle, PA Karen D. Garrett, Plaintiff V. Jeffrey M. Garrett, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OJF CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-3201 : : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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) 2201(d)(1-) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified, Return Receipt & Restricted Delivery (copy attached) 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff 10-24-02; by the Defendant 11-12-02 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, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 11-13-02 Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 11-13-02 By: Respectfully submitted, SAIDIS~ SHUFF, FLOWER & LINDSAY LA~iddsay Gin~46h M~clay, Esquire Supreme Court ID #87954 26 W. High Street Carlisle PA 17013 Phone: 717.243.6222 Attorney for Plaintiff Karen D. Garrett, Plaintiff VERSUS Jeffrey M. Garrett, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~% PENNA NO. 2002-3201 DECREE IN DIVORCE AND NOW, //~/~ /~'~ , ~'~ , IT IS ORDERED AND DECREED THAT Karen D. Garrett _, PLAINTIFF, AND Jeffrey M. Garrett 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. BY THE COURT: / PROTHONOTAR