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HomeMy WebLinkAbout02-3867 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002- .g 12(~'7 CIVILTERM : CIVIL ACTION - LAW : 1N DIVORCE NOTICE 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 manSage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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. Curnbefland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date: S ~ {o' 0 2-' By: SAIDIS, SHUFF, FLOWER & LINDSAY Johnn~_ ope~ ,y Esq~ire/ Supretfie Court ID #53147 26 West High Street Carlisle, PA 17013 (717) 243 -6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002 - 3 £{- '7 CIVIL TERM : CIVIL ACTION - LAW : 1N DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Kimberly R. West, who currently resides at 579 Guilford Avenue, Apt. #1, Charnbersburg PA 17201, Franklin County, Pennsylvania. 2. Defendant is La Traverick S. Jones, who currently resides at 220 Hartzel Drive, Fayetteville PA 17222, Franklin County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 12, 2000 in Winchester, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. By: Date: Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY s~ph~e' Count ID #531~ 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA AFFIDAVIT I, Kimberly R. West, being duly swom according to law, depose and say: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court rnaintains a list of mm'riage counselors in the Protbonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated: SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA VERIFICATION I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Dated: Ki/.mb~rly ~' Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA CERTIFICATE OF SERVICE Onthis [4dT¥~ayof \~/,/~002, I, JohnnaKopecky, herebyccrtifythatIserveda true and correct copy of the foregoing DIVORCE COMPLAINT via United States Mail, certified, restricted delivery, return receipt requested, postage prepaid, addressed as follows: La Traverick S. Jones 220 Hartzel Drive Fayetteville PA 17222 SAIDIS, SHUFF, FLOWER & L1NDSAY By: Suprerfie Court'I.D. #53147 26 West High Street Carlisle PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATrORN~YS*AT*LAW 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3867 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filled on August 14, 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 in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: SAIDIS SHUFF, FLOWER & LINDSAY AI'I'ORNEYS*AT.LAW 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3867 Civil Term CIVIL ACTION . LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 14, 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 in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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 2. ] ~ 02-- SAIDIS SHUFF, FLOWER & LINDSAY A'ITORI~YS*AT,LAW 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3867 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODF 1. I consent to the entry of a final Decree of Divorce without notice. 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. 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification 1!o authorities. ~ / Kimberly ,West,~iai'nl ?ff Date: SAIDIS SHUFF, FLOWER & LINDSAY ATfOP, NEY$*AT*LAW 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3867 CIVIL ACTION - LAW IN DIVORCE _.WAIVER OF NOTICE OF INTENTION TO REQUEST _ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODF I consent to the entry of a final Decree of Divorce without notice. I understand that I may lose dghts concerning alimony, division of property, lawyer's 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 rne immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. '~ ndant SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3867 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE MANNER OF SERVICE · Complete items 1, 2, and 3. Aisc complete item 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 back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 2. Article Number (TransCer from service label) PS Form 3811, August 2001 D. Is delivery address different from item 17 Yes If YES, enter delivery address below: I"'1 No it.fi'Certified Mail [] Registered [] Insured Mail ~et ureSs Mail rn Receipt for Merchandise [] C.O.D. 4. Restricted Delivery? (Extra Fee) DomeeticReturn Receipt SAIDIS SHUFF, FLOWER & LINDSAY ATIDRN~YS.AT*LAW 26 W. High Street Carlisle, PA Kimberly R. West, Plaintiff La Traverick S. Jones, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-3867 CIVIL TERM : 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) 330!(d)(-I-) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Via certified, return receipt, restricted delivery August 21, 2002 (attached) 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff 12/3/02; by the Defendant 12/1/02 (b) (1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs affidavit upon the Defendant: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 12/6/02 Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 12/6/02 Respectfully submitted, SAIDIS, SHUFF'_, FLOW.ER & LINDSAY ~],J~d/say ~ingri~Vlacla¢, Esquire Sul~reme Court ID #87954 26 W. High Street Carlisle PA 17013 Phone: 717.243.6222 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ST/~ TE Of PENNA. Kimberly R. West, Plaintiff VERSUS La Traverick S. Jones, Defendant No. 2002-3867 Civil Term DECREE IN AND NOW, DIVORCE , IT IS ORDERED AND DECREED THAT Kimberly R. West , PLAINTIFF, AND La Traverick S. Jones , 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; None.