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HomeMy WebLinkAbout02-3375PAPTLESOATAPEJ;\Gendoc.cm 10584-COMAAde Crca : 03/13/02 0116,39 PM Revived 07/16/02 0128.43 PM 10584.1 CORY JAMES CLIFFORD, Plaintiff V. MICHELLE RENEE CLIFFORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- 3315 CIVILACTION- 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Telephone (717) 249-3166 CORY JAMES CLIFFORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02- 33 `m CIVILACTION- LAW MICHELLE RENEE CLIFFORD, Defendant IN DIVORCE COMPLAINT Plaintiff is Cory James Clifford, who currently resides at 320 Shady Lane, Apt. 5, Enola, Pennsylvania. 2. Defendant is Michelle Renee Clifford, who currently resides at 1154 Redwood Drive, Carlisle, Pennsylvania. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 27, 2001 in Boiling Springs, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. MARTSON DEARDORFF WILLIAMS & OTTO By 1 1WMAv4 Y v Imo. A- - ` Thomas J. Willi Esquire Ten East High t Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: July 16, 2002 VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties F.\ LEMATAFIMB dm,cur\10380-COM.1 73 i ti? 0 lA Q W^ ?W Q 'Vol Z C. -; b 2??-j _e. rln b W ? . L -1 C:J F:\FILES\DATAF[LE\GrndoccarV0584-aH 1 Created: 07/24/02 01:58:07 PM Revised: 07124/02 01:58:16 PM CORY JAMES CLIFFORD, Plaintiff V. MICHELLE RENEE CLIFFORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3375 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND I SS. I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Michelle Renee Clifford at 1154 Redwood Drive, Carlisle, PA on July 17, 2002 by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Michelle Clifford" and dated July 23, 2002. LA_L_ _ VW4_"4_x__ Thomas J. Will s, Esquire Sworn to and subscribed before me this 24' day of July, 2002. n C27-Notany Public NOTARIAL SEAL TRICIA D. ECKENROAD, Notary Public Carlisle Boro., Cumberland County M Com i n rT rn r, 9 W ¦ Complete iterne 1, 2, end 3. Also complete kern 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the beck of the mailplece, or on the front If apace perks. 1. Article Addressed to: Ms. Michelle Clifford 1154 Redwood Drive Carlisle, PA 17013 17 1 rte ved PAnte ru Date of Delivery i 7 -L3-oz D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yea 2. Article Number 7001-25100000 3069 7007 (rrens/erhnrn service /shag PS For 3811, August 2001 Domestic Return Receipt 102595-o1-M-Ml r- 0 0 r- rr 0 M 0 C3, fa 0 C3 ? TOW Poetsee A FNS rru sutra Ms. Michelle Clifford r-l Street, Apt. No.; 0 or Po BoxNo.1154 Redwood Drive ---- ---- - --- C3 •ciry state,-ira+4 Carlisle, PA 17013 F.\FILES\DATAFILE\G,n"a ,,hi,e\GEND C03\10504-1 canI Created. 07/24/0201 5807 PM Revised. 06/09/0402.36. 21 PM CORY JAMES CLIFFORD, Plaintiff V. MICHELLE RENEE CLIFFORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 02-3375 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 16, 2002. I acknowledge receiving a true and correct copy of the Divorce Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on July 23, 2002. 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 of divorce. 4. 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301 (d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 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. 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 and waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. A Date: ' (/ V I_ ??!P!I 1711 U // 11 Michelle R. Clifford, y) y w INOTA v 4 RIAL SEAL NpTA JACQUELINE M. WORLEY, Notary Public Carlisle, Cumberland County My Commission Expires Jan. 10, 2005 N nor, ? z `? CORY JAMES CLIFFORD, Plaintiff V. MICHELLE RENEE CLIFFORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3375 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 16, 2002. 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 of divorce. 4. 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301 (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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 grunted. 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 and waiver are true and correct. I understand that false statements herein are made subject to, the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date: JO// / 4 Cory ifford, aintiff , Notary L Can. 1?0 Zpp6 CpI lo/oLl Ak; N 0 0 c o r -? r c 5c l c" N ern F FILES%DATA PILE\GcreraMrchive6G[NDOCOP 10584-I.praI Created 07/24/02 01 58.07 PM Revised' I9,W04094917AM CORY JAMES CLIFFORD, Plaintiff V. MICHELLE RENEE CLIFFORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3375 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Sent certified mail, restricted delivery on July 17, 2002, received by Defendant on July 23, 2002. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; June 10, 2004; by the Defendant; June 1 C1, 2004. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 11, 2004. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 11, 2004. MARTSON DEARDORFF WILLIAMS & OTTO Thomas J. Willi s, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341. Attorneys for Plaintiff Date: August 16, 2004 GJ r} Ciro IN THE COURT OF COMMON PLEAS CORY JAMES CLIFFORD No. 02-3375 VERSUS MICHELLE RENEE CLIFFORD DECREE IN DIVORCE AND NOW, S; q ; -'r/ 0 s'p , IT IS ORDERED AND DECREED THAT CORY TAMF4 CTTFFORT) PLAINTIFF, AND MICHELLE RENEE CLIFFORD 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; OTARY OFCUMBERLAND COUNTY STATE OF PENNA. 1 00: .8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ted Plaintiff Vs File No. J _ MoYLIC Lt4rc e/? ed IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or 1C after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of QU???z t 0 , and gives this written notice avowing his / her intention p ant to the provisions of 54 P.S. 704. Date: L ignature 00iiij ? C Signature of name being resui-nw COMMONWE LTH OF PENNSYLVANIA ) COUNTY OF On the ,3`4day of , 200_', before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANI Notary Public NOT?IRIAL SEAL DARCIE A. NEIL, Notary Public Boro of Carlisle, Cumberland County My commission Exoires Nov. 24, 2009 4 TFc- P _ARY 2009 Al G -35 Pit 2: 01 ?? ?l/ ao l?fh 2?C? aa??NC?