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Home My WebLink About94-07129 ----------------_._.y---------~ ~ - !~ ~ . ~ ~ ~ IN THE COURT OF COMMON PLEAS ~ g OF CUMBERLAND COUNTY ~ ~ ' @ ~ .~ ~ 8 STATE OF ~~ PENNA. ~ 8 ~ ~ SHIRLEY A. FOSTER, 8 $ >> II N ~ lil Plaintiff O. ...9A.::71,:;,!,9" ..,~lV.U. 1994 .' :: ~ ~ Verslls ~ ~ WILLIAM J. FOSTER, >>>>>> II ~ ~ Defendant :i ~ 8 r.. ~ ~ ~ ~.; lj :",' l!l .~ " ~ ;,; ~ ~ ~ ~ ;;; ~ $ 8 ~ ~ $ ~ /; ~ ~ ~ 8 ~ ~ M .' DECREE IN DIVORCE AND NOW,..,....,... -:::-!~...~ ~.~,.... 19. .~~... it is ordered and decreed that .,..,..... .~~~~.l.~:(. ('.... . ~?s.~~~.. . .. . . . . . . . . . . . . ., plaintiff, and. . ... .. .. ........... \-1~.~H!l!1l..-!!. f.q~~~~......... ...... ... 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; ,;, ~ $ M.' lil 8,. ...,......,...,..".",."".,.,.,.,.....,.....,......... '. ~ ~ ~ : D y T e ~ :IlL ; ".' Alle.l ~pL~fla L' t.k4e.% A"~'(~4 J. * :;' ? is ~ ' ';Q9'-'.'': ~ -J;;/k ~Z' ~ ~ / I/' ,:rr.olhonolary ::: ~. <<0. _ oQIC. -lC' _ -lC' oQIC. oQIC. .:c.~i"'::.~::;::-.:.::-.:.:: ':.:. ::.;. ',:+::-:~.:.',~:: ::.;"::.::-.~" .:.::::.:.' .:.::.:~; " ~ .. .. . . . . .. .. . . . . .. 1;19. .~l!l~1l!f!. p~.T\(H,pg . .. . . . . . , . .. . .. . . . . . . . . . . . . . .. . . . . . , ~ SHIRLEY A. FOSTER, IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiff . . vs. 94 - 7129 CIVIL TERM . WILLIAM J. FOSTER, . LAW - DIVORCE Defendant . . 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) X33D~~ of the Divorce Code. (strike out inapplicable section. ) 2. Date and manner of service of the complaint: 12/21/94- service upon counsel for the defendant via U.S. mail, first-c1as~. 3. Complete either paragraph (a) or (b). (a) Date of Elxecution of the affidavit of consent required by Section 3301(C) of the Divorce Code: by the plaintiff: April 14, 1995 by the defendant: April 10, 1995 (b) (1) Date of execution of the plaintiff's affidavit required by section 3301 (d) of the Divorce Code: ; (2) Date of execution of the plaintiff's affidavit upon the defendant: 4. Related claims pending: no claims nendin /!/ft( ;,.. Attorney for (Plaint ff) ~ Murrel R. Walters, III, Esq. SHIRLEY A. FOSTER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : 94- CIVIL TERM WILLIAM J. FOSTER, LAW - DIVORCE Defendant COMPLAINT The plaintiff by her attorney, MURREL R. WALTERS, III, ESQUIRE, brings this action in divorce for a Decree of Divorce from the bonds of matrimony and respectfully represents: 1. The plaintiff is SHIRLEY A. FOSTER, an adult individual, who currently resides at 4 Kingswood Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The defendant is WILLIAM J. FOSTER, an adult individual, who currently resides at 4726 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. plaintiff and defendant are both bOlla fide residents of the Commonwealth of Pennsylvania and have been for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on June 9, 1989 in Carlisle, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The plaintiff avers that the marriage is irretrievably broken. SHIRLEY A. FOSTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 94 - 7129 CIVIL TERM WILLIAM J. FOSTER, LAW - DIVORCE Defendant AF~IDAVIT O~ CONSENT 1. A Complaint in Divorce under S 3301(C) of the Divorce Code was filed on December 21, 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 5. I have been advised of the availability of marriage counseling and I understand that I may request that the court require that my spouse and I participate in counseling. 6. I understand that the court maintains a list of marriage counselors at its Domestic Relations Office, which list is available to me upon request. 7. Being so advised, I do not request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 8. I acknowledge that my attorney, Judith A. Calkin, Esquire, accepted service of that Complaint on my behalf on 12/27/94. I, WILLIAM J. FOSTER, verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsification to authorities. Date: April 10. 1995 '.1/ ;/~:-.~"\ O. ,~~ WILLIAM J/ FOSTER SHIRLEY A. FOSTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94 - 7129 CIVIL TERM WILLIAM J. FOSTER Defendant LAW - DIVORCE ELECTION TO RETAKE MAIDEN NAME NOTICE IS HEREBY GIVEN this '1 '7 day of ILI,t '( 1995, that a Final Decree in Divorce from the bonds of matrimony having been granted on the 10th day of May , 1995, the plaintiff, SHIRLEY A. FOSTER, hereby elects to retake and hereafter use her former name of SHIRLEY A. MILLER, and gives this written notice avowing her intention to do so in accordance with section 702 of the Act of April 2, 1980, P.L. 63, 23 Pa.C.B.A. S 702. ait~lt.~o~~<- TO BE KNOWN AS: ~ ~;;:I./;;j /J;U / h ~ SHIRLEY A. !'LLER AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : On the ;:;;71,'( day of I ))ct.~-l' , 1995, before me a Notary public, personally appeared SHIttt.EY A. FOSTER, hereinafter to be known as SHIRLEY A. MILLER, known to me to be the person whose name is subscribed to the within document, and acknowledge that she executed the foregoing for the purpose therein stated. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ..Do)~ )) I, .I';:{/J:IL Notary public . Nctarifil Sam 1).100 M, ~IIlI1, No~'lIy PtbIlc Mecll<ll1l<%bllg 0010, Cumoer!,m Coonty My r:omr'll':i~1Ol181p:(fi Junu ~12, 1m