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HomeMy WebLinkAbout94-03076 ~ c ...j a u \oJ E 3"- , -4' ~ € E: '- ~ J ~ t' I ~i t T ) 0-( ". f 'I / ! i I I I i I I I - ._~~~~_~_~~~*~~~**~~r_~~~__~~~~ ~ -'~ -. l' ~ ~ ~ .. ~ IN THE COURT OF COMMON PLEAS : 8 OF CUMBERLAND COUNTY . ~ . ~ ~ ~ . . ~ STATE OF PENNA. 8 ""\:-~. .:r ' . . . 8 8 8 Ile~lln ~. J1<;Cartney, il . u N I). ....~,~.~.3.,~,.?~. ..,.......,...... 19 P,I ....Plaintiff ': ~ 8 V,')',;\I,; 8 ~ ....Benjamt~ A, . McClIrtney, I 8 M 1i :: , .. Defendant ,i , 8 i ( ~ ~' 8 DECREE IN ~ M " . DIVORCE - . , ~ AND NOW, ,q,,~p.4ljr.,.. ,~.f~........., 19..')4." it Is ordered and ~ 8 ~ fi decreed that ,.,.I!,!!~.n"~'.'.,,,\C;<;p,r,t.I!I)Y,...,.,,,,...,.,,,,.,,,,, plaintiff, ~ 8 and .1311,r\j(l\ll,i,l\ .~" .l1<;C,1,t".t.IIOy".,..,.,..".,.".""",."", defendant, ~ ~ are divorced from Ihe bonds of matrimony. : ~ ~ . The courl retains jurisdiction of Ihe following claims which have : 8 been raised of record in Ihls acllon for which a final order has not yet : 8 been enlered; ~ M . a ,..,..,.".."""",."""""",.",."""."""""....""..,..",'. ~ . ~ ~ .. ...................,..............,...........,......." ~ M ' 8 IJv T~'" cnut/l'll : 8 ,I )t\-' I kll-... I ~ AHell: !>(;;'~/I'Ift1' <'~ /(.k~" /.~d$~,.../~ J. !: , &jI' '.bf!' it.< ,.e .x.: /e, ! ~ n. _.._ _ _.._._ ,..':, , . ,L1t;UI~ l'rnlllOl1olnty I ~ ....~ ....~ ... .. . ; . '~.' ........ .~.. ..... .:to;. .:+:. .:.;. .:+:. .:.:. .:+:. .:t:' .:+:. .:+:. .:.:. .:+:. .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. .:+:. a:, ~f - ::r.:: c.... ,~ N ,"'l -~ <-I ... S vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94~5t1b CIVIL TERM HELEN L. MCCARTNEY, Plaintiff BENJAMIN A. MCCARTNEY, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims oet forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may 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, Carlisle, Pennsylvania, 17~13. IF YOU DO NOT rILE A CLAIM rOR ALIMONY, DIVISION or MARITAL PROPERTY, LAWYER'S rEES, OR EXPENSES BErORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. Ir YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELBPHOKB THI OrFICI SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET I,BGAL HELP. Court Administrator Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94 CIVIL TERM HELEN L. MCCARTNEY, Plaintiff BENJAMIN A. MCCARTNEY, Defendant IN DIVORCE COMPLAINT IN DIVORCI COUNT I 1. Plaintiff is Helen L. Mccartney, an adult individual currently residing at 781 Hamilton court, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Benjamin A. McCartney, an adult individual currently residing at 460 Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bona fide residents of the Fairground Avenue, Carlisle, Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 23, 1993, in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right of request that the Court requires the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court requires 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. 10. Plaintiff desires a divorce based upon the belief Defendant will, ninety days from the date of the filing of complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to section 3301(c) of the Divorce Code. that this COUNT II INDIONITII8 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent and injured spouse, as to make her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests yoU": Honorable Court to enter a divorce pursuant to 23 Pa.C.S. section 3301(a). Respectfully submitted, GRIFFIE & ASSOCIATES ~ HELEN L. MCCARTNEY, Plaintift I/S. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94-367(., CIVIL TERM IN DIVORCE BENJAMIN A. MCCARTNEY, Detendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend aqainst the claims set forth in the fOllowing paqes, you must take prompt action. You are warned that it you fail to do so, the case will proceed without you and a decree in divorce or annulment may be entered aqainst you tor 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 indiqnities or irretrievable breakdown of the marriaqe, you may request marriage counselinq. A list of marriage counselors is available in the Office of the Prothonotary at CUmberland County courthouse, CarliSle, Pennsylvania, 17013. Ir YOO DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 01' MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOO HAY LOSE THE RIGHT TO CLAIM ANY or THEM. YOO SHOOLD TAKE THIS PAPER TO YOOR LAWYER AT ONCE. Ir YOO DO NOT on A LAWYER OR CANNOT Al'I'ORD ONE, GO TO OR TELEPHOHl TO OI'I'%CI SET FORTH BELO" TO I'IND OOT WHERE YOO CAN GET LEGAL lUlU. Court Administrator ()~erland County Courthouse TRUE COPY FROM REC ;Wisle, Pennsylvania 17013 In Test\mOIIywher80I,1 here liMO set my (717) 240-6200 and the seal of said Court al carlisle, Pa, Th~ o'h,.19~ D)a., Prot~ . , HELEN L. MCCARTNEY, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 94-3D?~ CIVIL TERM vs. . . BENJAMIN A. MCCARTNEY, Defendant : IN DIVORCE . . COMPLAINT IN DIVORCB COUNT I 1. Plaintiff is H~len L. Mccartney, an adult individual currently residing at 781 Hamilton Court, carlisle, CUmberland County, Pennsylvania. 2. Defendant is Benjamin A. Mccartney, an adult individual Fairground Avenue, carlisle, currently residing at 460 cumberland County, pennsylvania. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of pennsylvania and have been so for at least six months immediately previous to the fi1inq of this Complaint. 4. Plaintiff and Defendant were married on November 23, 1993, in cumberland County, pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the united states Armed Forces or its Allies. 7. Plaintiff ,has been advised of the availability of counseling and the right of request that the Court requires the parties to participate in counselinq. Knowinq this, plaintiff does not desire that the Court requires the partie. to participate in counseling. 1 ~ . I i ~ O"l ,. ~ . ...l.~, , ::c ,. ., a.. ::r --....., III (Y) l""- t- I., '"~ .... = ~,.A . ' HELEN L. MCCARTNEY, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BENJAMIN A. MCCARTNEY/ Defendant NO. 94-3076 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSBNT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 8, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: Ii, It,! " ,..< I, .... .. '..: I ',/,.,-/:".-....4"! . BENJAMIN MCCARTNEY, Defendant . ..' . . , HELEN L. MCCARTNEY . IN THE COURT OF COMMON PLEAS OF . P1aintirt . CUMBERLAND COUNTY, PENNSYLVANIA . . . V8. I CIVIL ACTION - LAW . . BENJAMIN A. MCCARTNEY NO. 94-3076 CIVIL TERM Defendant . IN DIVORCE . AWWIDAVIT OW COHSBHT 1. A Complaint in Divorce under section 3301(0) of the Divorce Code was tiled on June 8, 1994. 2. The marriage of Plaintitf and Defendant i8 irretrievably broken and ninety (90) days have elapsed from the date of the tiling of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability ot marriage counseling, that I may request that the Court require that my 8pou8e and I participate in counseling, and that the Court maintains a list of marriage counselors in the Prothonotary' 8 Office, which list is available to me upon request. Being 80 advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: /(,. 1/. )/;/ , il / l/'. /1 /,~, ...7 7)( HELEN L. MCCARTNEY plaintiff ! j ~ c- o. ~ ~-\ '>- ~u (; 11; l.'.: -'" , ,- , .r lUP - - I (.Ji.' ... I"':, ".. ,., :.J Or:" :. t ,__ ,...! (2' I'J L. I" i [", c::. J(;] L L.J '~ ~.l. r.- w_ ,. f.' '"j U 0\ U j~ J ~ -'. l 't', 'I' ", I