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Home My WebLink About02-3862LUCY S. FOREMAN, Plaintiff ERIC M. FOREMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - 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 in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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· CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 LUCY S. FOREMAN, Plaintiff ERIC M. FOREMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT AND NOW COMES the above-named Plaintiff, by her attorney, William A. Duncan, Esquire, and makes the following Complaim in Divorce: 1. Plaintiff~ Lucy S. Foreman, is an adult individual currently residing at 423 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Eric M. Foreman~ is an adult individual currently residing at 42 Eastwick Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. Both 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 25, 1996 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers, in accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7. Plaintiffhas 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. Defendant herein is not a member of the armed forces of the United States of America. WHEREFORE, Plaintiffprays this Honorable Court enter a decree dissolving the marriage between the parties. Respectfully Submitted, William ADuncan, Esquire Attorney for Plaintiff Duncan & Hartman, P.C. 1 Irvine Row Carlisle, PA 17013 (717)249-7780 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904, relating to unsworn falsification to authorities. LUCY S. FOREMAN, Plaintiff ERIC M. FOREMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, William A. Duncan, Esquire, being duly sworn according to law, do swear that I served a Complaint in Divorce on the Defendant, Eric M. Foreman, by hand delivering a true copy to him at the following address on August ~ ~ 2002. Eric M. Foreman 42 Eastwick Lane Carlisle, PA 17013 William A. Duncan, Esquire Sworn to and subscribed NOTARIAL SEAL Cyr~hla L. Darr, Notary Public MJcldlet0~l Twp,, ~Ountlt of Cumberland LUCY S. FOREMAN, Plaintiff ERIC M. FOREMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. : IN DIVORCE ACCEPTANCE OF SERVICE I, Eric M. Foreman, hereby acknowledge receipt of the Complaint in Divorce hand delivered to me by William A. Duncan, Esquire on August ~ ~ , 2002. ~ i~x ~ IN THE COURT OF COHMON PLEAS OF'Cl. JMBER£,AND- C(JUN' "Y, PENNSYLVANIA CIVII, ACT[O~',I - LAW LUCY S. FOIHg~AN Ve E~IC M. FOREMAN PI~ ~ ntiff D~fendant NO. 2002- 0386Z ACK_ION IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted ~Final Decree in divorce from the boads of matrimony on the lfl day of ~~~.~ , hereby elects to retake and hereafter use her previous name o£ Luc~Anne Surer COMMONWEALTIt OF PENNSYLVANIA : COUNTY OF CUMBERLAND : On the I(~~'x day of ,~.()V~W~Di'~___ , ~",9~(DO/._, before· a Notary Public, personally appeared LOf_~ 5, ~'ff~6i~_ , known to me to be the person whose name is subscribed to the within docu- ment, and acknowledged that she executed the foregoing for the par- pose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. NOTARIAL SEAL Kathy L. Mummert, Notary Public Borough ol Carlisle, Cumberland Co., PA My Commission Expires Aug. 11,2003 No~ Pub l_ic LUCY S. FOREMAN, Plaintiff V. ERIC M. FOREMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. _ D IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaim. 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 ifI 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. sec. 49904 relating to unsworn falsification to authorities. LUCY S. FOREMAN, Plaintiff ERIC M. FOREMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVH. ACTION - LAW NO. ~ va O ~ o.3 £~C,,~9._ IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on 2. The marriage of plaimiffand defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entW ora final decree of divorce. 4. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verifi/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. sec. 49904 relating to unswom falsification to authorities. Date: ////5l/o~... ERIC M. ~ LUCY S. FOREMAN, Plaintiff V. ERIC M. FOREMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW _. : NO. _ o 6, _. : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVIRCE DECREE UNDEP 3301 {C) 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, lawyer's fees or expenses ifI 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.~s c. 49904 relating to unsworn falsification to authorities. Date:////~~ ~/~~/j~ LUCY S. FOREMAN, Plaintiff V. ERIC M. FOREMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. o~E~ ~ ~.~ ~c~(~ g~_ : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 (C) 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, lawyer's fees or expenses ifI 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 49904 relating to unswornDate: ///~z~falsificati°n to authorities, b~.~-,'~ ERI(LM2FO~ LUCY S. FOREMAN, Plaintiff ERIC M. FOREMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002-03862 : : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following info~aiation, 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: by personal service by William A. Duncan, on August 13, 2002. 3. (1) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff November 14, 2002 , by defendant __November 14, 2002 4. Related claims pending: none 5. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 6. Date Defendants Waiver of Notice in 3301{c) Divorce was filed with the Prothonotary: A~y o~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~, PENNA. .... Lucy S. Foreman ......... ........... Plaintiff VeYsus Eric ti. Foreman .... Defendant ...... DECREE IN DIVORCE a,,o,). ,.,'ti. ~ f .ls'l . AND NOW, ~~ I (~ ~1/. it is ordered and decreed that LUC~ S. ]'0~ plaintiff, and ................... ~?.z.c. ?.:. ~o...~,)p1~..' ........................ 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; By Attest: J. Prothonotary