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HomeMy WebLinkAbout02-3922RICHARD M. MCBETH, JR. Plaintiff Vo KAREN J. MCBETH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0~- 3q~ ~.~a~_ 1N DIVORCE NOTICE TO DEFEND AND CLA/M 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 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 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. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 RICHARD M. MCBETH, JR. Plaintiff V. KAREN J. MCBETH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02. 39.2 2_. ~..~,~ 1N DIVORCE COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Richard M. McBeth, Jr., who currently resides at 579 E Street, Carlisle, Cumberland County, Pennsylvania, since September, 2001. 2. Defendant is Karen J. McBeth, whose current address is unknown. 3. Both Plalntiffand 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 November 3, 1978 in Mount Holly Springs, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and that Plaintiffmay have the right to request that the court require the parties to participate in counseling. 8. Plaintiffrequests the court to enter a decree of divorce. Harrisburg, PA 17101 (717) 238-3686 Supreme Court I.D. 53729 VERIFICATION I, Anthony T. McBeth, am attorney for the PlaintilTin the captioned action. I am verifying the attached document for the Plaintiffin that he is outside the jurisdiction of this Court. I verify that the facts set forth in the attached document are true and correct to the best of my knowledge, information and belief. I so state subject to the penalties of 18 Pa.C.S. § 4904 (relating to unswom falsification to authorities). R/CHARD M. MCBETH, JR. Plaintiff KAREN J. MCBETH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3922 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE UEST ENTRY OF A DIVORCE _DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry ora 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 mc 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. §4904, relating to unswom falsifications to authorities. Date Karen J. McBeth, Defendant RICHARD M. MCBETH, JR. Plaintiff KAREN J. MCBETH : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02~3922 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 16, 2002. 2. The marriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the complaint. 3. I consem to the entry of a final decree of divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statemems herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date RICHARD M. MCBETH, JR. Plaintiff KAREN J. MCBETH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3922 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE UEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to thc entry ora 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 thc Court and that a copy of the decree will be sent to me immediately al~er 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. §4904, relating to unsworn falsifications to authorities. RICHARD M. MCBETH, JR. Plaintiff KAREN J. MCBETH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3922 CIVIL TERM IN DIVORCE _AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 16, 2002. 2. The marriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed fi.om the date of filing and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice ofintemion to request entry of the divorce. 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. §4904 relating to unswom falsification to authorities. RICHARD M. MCBETH, JR. Plaintiff Vo KAREN J. MCBETH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3922 CIVIL TERM 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 complaint: record). August 26, 2002 via regular mail (substantiated by acceptance of service filed of Code: 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce By Plaintiff: November 29, 2002 By Defendant: November 29, 2002 4. Related claims pending: None. 5. Date of Waiver of Notice was filed with the Prothonotary: By Plaintiff: Contemperaneously filed herewith this filing, projected to be December 16, 2002. By Defendant: December 16, 2002. Contemperaneously filed herewith this filing, projected to be Anthony T. J~I¢l~eth, Esq. Attorney f~ Plaltatiff 407 North F'r,0~nt ~t., First Floor Harrisburg, pA~i°710 ! (717) 238-3686 Supreme Court I.D. # 53729 IN THE COURT OF COMMON PLEAS OF CUMBERLAND STATE OF ~ COUNTY PENNA. RICHARD M. MCBETH, JR. Versus KAREN J. ~CBETH 002-3922 C~ N ....... DECREE IN AND NOW,~...~I.0 .... 20~,~..~..., it is ordered and decreed that RICHARD M. MCBETH, JR, , plaintiff, and ~AREN J. MCBETH 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