HomeMy WebLinkAbout95-04506
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~ IN THE COURT OF COMMON PLEAS :
8 OF CUMBERLAND COUNTY 8
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8 ST A TE OF 'r.?!" ,;~ t PENNA. 8
8 8
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8 InlNU: L. WHITE, "
i'\ (I. 4506 qVIk I I) 95 "
8 ~Will 8
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8 JOON W. WHITE, "
IN Dl\lOOCE "
8 "
Defendant "
8 8
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8 DECREE IN :
8 DIVORCE ·
8 8
; AND NOW, .. , .. .. ,.. ,),c,t.\, I~.. ,( r.., 19 .~~~ ... It Is ordered and :
'" decreed Ihat ......' ~~~. ~~, ~,l~~.. .., , , .... .... .. , .... , .. ... plaintiff,
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: :~ed ~I~~~~~~' ~:: ~~~~:~'s' ~'.. ;~a't~;~~~~'," .. .. .. , .. , .. '" defendant, ~
. 8
* The court relalns jurisdiction of the following claims which have 8
, been raised of record In this oct Ion for which a final order has not yet 8
, been entered;
8
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BONNIE L. WHITE,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
95-4506 CIVIL 1995
vs.
JOHN W. WIlITE,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY I
Tranemit 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) )
2ft 3301(d)) (1) of the Divorce Code.
2. Date and manner of service of the complaint: certified Mail/
Restricted Delivery/Return Receipt Requested ( See Attached Exhibit "A" \
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 December 6, 1995
I by defendant December 1. 1995.
(b) (1) Date of execution of the plaintiff's affidavit required by
section 3301(d) of the Divorce Codel
(2) Date of service of the plaintiff'e affidavit upon the
defendant:
4. Related claims pending I N/A
5. Indicate date and manner of sorvice of the notice of intention to
flle praecipe to transmit record, and attach a co.py of said notica under
.eoti d. 3l 01 t d)( 1 ) t I) of tho Of ""e Cod. ,::{;:__/. '
John1iil J ;-. Del' y, --Esquire
Atto{ney forfthe Piaintiff
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cumberland county Court Administrator
One courthouse square
Carlisle, PA 17013
(717) 240-6200
re
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
95- IffJOf, CIVIL TERM
BONNIE L. WHITE,
plaintiff
JOHN W. WHITE,
Defendant
IN 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 caee 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 theee
papers by the plaintiff. You may lose money or yroperty or other
rights important to you, including custody or v sitation of your
children.
When the ground for the divorce is indignities or
irretrievablo breakdown of the marriage, you may request marriage
counseling. A list of marriage couneelors is available in the
Office of the Prothonotary at the Cumberland County Court House,
High and Hanover Street, Carliele, 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 HAY 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.
Attorney for the plaintiff
SAIDIS, GUIDO,
SHUFF ..
MASLAND
26 W. lIIah 5"<<1
Cullll.,P^
BONNIE L. WHITE/
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY/ PENNSYLVANIA
v.
95-
CIVIL TERM
JOHN W. WHITE/
Defendant
IN DIVORCE
CO:P~AI~T UNDER SECTION 330llcl
o 3 0 ldl OF THE DIVORCE CODE
1. plaintiff is Bonnie L. White, who currently resides at
34 N. Baltimore Avenue, No.2, Mt. Holly springs / Cumberland
county/ Pennsylvania 17065.
2. Defendant is John W. White, who currently resides at
P.O. Box 131, Gardners/ cumberland County, pennsylvania 17324.
3. plaintiff and Defendant have been bona fide reeidents
in the Commonwealth for at least six months immediately
previous to the filing of this Complaint.
4. The plaintiff and Defendant were married on
1988 in Mechanicsburg, cumberlllnd County,
February 12/
Pennsylvania.
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 dOBS not desire
the Court to order counseling.
7. The marriage is irretrievably broken.
8AIDIS, GUIDO,
8HUFF Ii
MA8LAND
26 W. Hllh 51'"'
Carll"., PA
Dated I
WHEREFORE, Plaintiff requests Your Honorable Court to
enter a decree in divorce.
Respectfully submitted,
q, n-1t'
Johnn
26 t
Car iele, PA 17013
(717) 243-6222
Attorney for the plaintiff
SAlltIS. GUll)O
, MASI.ANU
26 W, IIl,h Slit"
Carlhlt,I'A
IlOONIE L. WlUTE,
I IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO.
CIVIL 1995
JOlIN W. Wl1l1'E,
Defendant
IN DIVORCE
AFFIDAVI1'
, being duly sworn according to law,
1, Bonnie L. White
depose and eay:
(1) 1 have been advised of the availability of marriage
counselling and understand that I may requeet that the court
require that my spouse and I participate in counselling.
(2) 1 understand that the court maintains a list of
marriage counselors in the prothonotary's Office, which list ie
available to me upon request.
(3) Being so advised, 1 do not request that the court
require that my spouse and 1 participate in counselling prior
to a divorce decree being handed down by the court.
1 understand that falee statements herein are made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Datedl
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, Pla~ntiff
SAIIlI!!, (lVIIlU
a MA!!UNU
26 W, Illlh SII'"
Clrlhlet JlA
i'ER H' 1 CA'rIQtl
I verify that the etatements made in this complaint are
true and correct. \ understand that false statemente berein
are made subject to the penaltiee of 18 Pa. C.s. section 4904,
relating to unsworn faleification to the authorities.
DATED I
8 / d.) / 9, tj
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Ilonnie \.. White,
t JJult
plaintiff
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8AI018,OVUJO,
8HUFF II
MA8LAND
26 W. llI,h 5"<<1
Clllllle,PA
BONNIE L. WHITE,
Plaint if f
I IN TilE COURT OF COMMON PLEAS m'
CUMBERLAND COUNTY, PENNSYLVANIA
95-4506 CIVIL TERM
v.
JOHN W. WHITE,
Defendant
IN DIVORCE
AFFIJAVIT OF CONSENT
(l) A Complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on August 23, 1995.
(2) The marriage of plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
Complaint.
(3) I consent to the entry of a final decree of divorce.
(4) 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.
1 verify that the statements made in this affidavit are true
and correct. 1 understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Da ted I / ;). II, / ?_'J~
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DO )'lZ-<.e. ,/ ItJ/u.b::
Bonnie L. White, Plaintiff
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S"'D1S. GUIDO,
SHUFF "
MASLAND
26 w. tIIlh 51""
Cull"e, ~A
BONNIE L. WHITE,
plaintiff
v.
JOHN W. WHITE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
95-4506 CIVIL TERM
IN DIVORCE
8f11DAVIT OF CONSENT TO DIVORCE
(1) A Complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on August 23, 1995.
(2) Defendant acknowledges that service of the complaint was
made by certified mail on september 1, 1995.
(3) The marriage of plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
complaint.
(4) 1 understand tbat I may lose rights concerning alimony,
division of property, lawyer's fees or expensflS if I do not claim
them before a divorce is granted.
(5) I consent to tho entry of a final decree of divorce.
(6) 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.
(7) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling. Being
so advised, I do not request that the Court require that my
spouse and I participate in counselling prior to a divorce decree
being handed down by the Court.
I verify that tho 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. Section 4904 relating to
nnsworn falsification to authorities.
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