Loading...
HomeMy WebLinkAbout02-4123KATHI~EEN A. WHITE, PLAINTIFF Vo DONAT.~ R. WHITE, DEFENDANT IN THE COURT OF CO~ON PLEAS CU~ COUNTY, PENNSYLVANL% No. 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator,s Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 KATHLEEN A. WHITE, PLAINTIFF DONALD R. WHITE, DEFENDANT IN THE COURT OF CO~ON PLEAS CLR~BERLAND COUNTY, PENNSYLV~NIA NO. 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 KATHLEEN A. ~HITE, PLAINTIFF Vo DON~T.m R. WHITE, DEFENDANT IN THE COURT OF CO~ON PLEA~ C~A~BERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Kathleen A. White who resides at 211 W. Dauphin Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Donald R. White who resides at 7841 Fishing Creek Valley Road, Harrisburg, Dauphin County, Pennsylvania 17~12. 3. The Plaintiff and Defendant have been a bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 20, 1982 in Towson, Maryland. 5. The parties have been living separate and apart since 1983. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. There were where no children born of this marriage. The Defendant is not a member of the Armed Services availability to request 9. of the United States or any of its Allies. 10. The Plaintiff has been advised of the of counseling and that Plaintiff may have the right that the Court require the parties to participate in counseling. 11. Plaintiff requests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717} 731-1461 VERIFICATION 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. 4904, relating to unsworn falsification to authorities. ~' Kathleen A. White KATHLEENA. WHITE, PLAINTIFF DON~T~ R. WHITE, DEFENDANT : NO. 05- : IN DIVORCE IN THE COURT OF CO~R4ON PLEAS COUNTY, PENNSYLVANIA NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in 1983 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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 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: ~-~-~'~ ~ ~ '~///~ Kathleen A White KATHLEEN A. WHITE, PLAINTIFF Vo DONALD R. WHITE, DEFENDANT IN THE COURT OF CO~ON PT.~.~S C%R~ERL~%~ COUNTY, PENNSYLVANIA NO. 02-4123 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 28, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: / KATHLEEN A. WHITE I~TH~.~-EN ~. WHITE, PLAINTIFF v. DON~?.~ R. WHITE, DEFENDANT IN THE COURT OF CO~ON PLEAS ~ COUNTY, PENNSYLVANIA NO. 02-4123 CIVIL TERM IN DIVO,,CE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A D IVOR_C_~ DEC~.~. UNDER SECTION 3301 (c) OF T~F DIVOP~E CODF 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: KATHLEEN A. WHITE I~THLEEN A. WH'I'TE, PLA'rNT'I'FF DON~?.~ R. WHITE, DEFENDANT IN THE COURT OF COI~ON PLEAS ~ COUNTY, PENNSYLVANIA NO. 02-4123 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 28, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: DON;~T.~ R. WHITE KATHLEEN A. WHITE, PLAINTIFF DON~?.~ R. WHITE, DEFENDANT IN THE COURT OF CO~ON PLEAS Ct%~EP/~%ND COUNTY, PENNSYLVANIA NO. 02-4123 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECR~ _UND._ER SECTION 3301(C) OF THE DIVORCE C0D~ 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 1.2 - ¥'.-' oZ DON~?.n R. WHITE KATHLEEN A. WHITE, : PLAINTIFF : v. : NO. O1-, ql2_~ : DON~?.~ R. WHITE, : IN DIVORCE DEFENDANT : IN THE COURT OF COI~ON PLEAS C~ COUNTY, PENNSYLVANIA ACCEPTANCE OF SERVICE I, Donald R. White, accept service of the Divorce Complaint and acknowledge receipt of Plaintiff's Affidavit under section 3301(d) in the above captioned matter. Dated: ~-/'- ~-- Donald R. White 7841 Fishing Creek Valley Road Harrisburg, PA 17112 DEFENDANT KATHLEEN A. WHITE, PLAINTIFF Vo DONALD R. WHITE, DEFENDANT IN THE COURT OF CO~H~ON PLEAS ~ COUNTY, PENNSYLVANIA NO. 02-4123 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing~ the same in the United States mail on August 29, 2002 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the signed Acceptance of Service attached hereto, the Complaint was received by the Defendant on September 1, 2002. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 KATHLEEN A. WHITE, PLAINTIFF Vo DON~?.n R. WHITE, DEFENDANT IN THE COURT OF COMMON PLEAS C%~EPJ~%~) COUNTY, PENNSYLVANIA NO. 02-4123 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECQRD To the Prothonotary: Transmit the record, together with the following information, to the Court for the 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: On September 1, 2002 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, December 3, 2002; By Defendant, December 4, 2002. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was-filed with the Prothonotary on December 6, 2002. Date Defendant's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on December 6, 2002. Thomas D. Gould, Esquire Attorney For Plaintiff iN THE COURT OF COMMON PLEAS KATHLEEN A. WHITE, Plaintiff VERSUS DONALD R. WHITE, Defendant OF CUMBERLAND COUNTY STATE Of ~~ PEN NA. N o. 02-4123 CIVIL DECree iN DIVORCE AND N OW, ~~~j~___ DECreed That KATHLEEN A. WHITE aND DONALD R. WHITE 2002 , IT IS ORDERED AND , PLAINTIFf, , 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