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~ IN THE COURT OF COMMON PLEAS :
8 OF CUMBERLAND COUNTY .
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~ STATE OF PENNA. 8
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8 Ile~lln ~. J1<;Cartney, il .
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~ ....Benjamt~ A, . McClIrtney, I 8
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, .. Defendant ,i ,
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8 DECREE IN ~
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. DIVORCE -
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~ AND NOW, ,q,,~p.4ljr.,.. ,~.f~........., 19..')4." it Is ordered and ~
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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. :
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. 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; ~
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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
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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, ....
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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/. )/;/
,
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/1 /,~, ...7 7)(
HELEN L. MCCARTNEY
plaintiff
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