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HomeMy WebLinkAbout02-4054 DENISE E. MORRISON, Plaintiff VS. JEFFREY T. MORRISON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. O $t . ¥o~--,/ Civil Term : : ACTION 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 arc warned that if you fail to do so, thc case may proceed without you and a decree of divorce or annulment may be entered against you by thc 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. Where the ground for thc divorce is indignities or irretrievable breakdown of thc marriage, you may request marriage counseling. A list of marriage counselors is available at thc Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 Car/isle, Pa. 17013 (717) 249-3166 DENISE E. MORRISON, Plaintiff VS. JEFFREY T. MORRISON, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. : Civil Term : ACTION 1N DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Denise E. Morrison, a competent adult individual, who resides at 75 Fickes Road, Newvillc, Cumber/and County, Pennsylvania, 1724 I. 2. Defendant is Jeffrey T. Morrison, a competent adult individual, who resides at 158 Stonchouse Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have months immediately previous to thc been residents of thc Commonwealth for at least 6 filing of this Complaint. 4. The Plaintiff and thc Defendant were married on August 13, 1988, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between thc parties. 6. Plaintiff has bccn advised that counseling is available and that plaintiff may have thc right to request that the court require thc parties to Participate in counseling. 7. Plaintiff and Defendant have two children together, name/y, Kaylee Marie Morrison, date of birth, 2/28/88 and Dylan Andrew Morrison, date of birth, 8/4/92. 8. Plaintiff and Defendant arc both citizens of thc United States of America. Nctther Plaintiff or Defendant are a mere bet of thc Armed of any of its allies. Forces of thc United States 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. Date: Respectfully submitted, outh Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAfNTIFF I verify that the statements made in this Complaint are false statements herein are made subject true and correct. I Understand that falsification to authorities, to the penalties of 18 Pa.C.S. §4904 relating to unsworn , amtiff DENISE E. MORRISON, Plaintiff VS. JEFFREY T. MORRISON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . : No. O~;1,-.-- ~0~"-~ CivilTerm : : ACTION IN DIVORCE ACCEPTANCE OF SERVICE PURSUANT TO PA.R.C.P 4 02(B) AND PA.R.C.P. 1920.4 I, Jeffrey T. Morrison, Defendant, have received a certified tree copy of the Complaint and hereby accept service of the Complaint in the above-captioned matter. Je~x~('y/1(. l~orrisoh, f)bfendant DENISE E. MORRISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 02 - 4054 Civil Term JEFFREY T. MORRISON, Defendant ACTION IN DIVORCE. 2002. AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on August 26, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of 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. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities~ Date: ~/~.//,,3 '~ c-.-4~,--~"~',/~ ;;~~'~ Je~e~"~ Morrison, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to 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 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 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 falsification to authorities. Date: .~/2._///~ ~> Jeff'rc~'~. Morrison, Defenda t