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HomeMy WebLinkAbout95-05153 rf) l(J - If) ~ , . .~_.~~~._~_.~~~~--~~-*~~~.~..~.~~:~_.~~-~.~~ $ ._- --'--- - - ~ ~ $ IN THE COURT OF COMMON PLEAS S ~ 8 $ OF CUMBERLAND COUNTY $ ~ ~ e : STATE OF ~!, .. ~ PENNA, : t!I \.;..,.~ ,,'r $ e e e ",l<M'HLEEt:l L. COMP,: e e Plaintiff N (l. .. , J5I9~".5153...,........... e ~ \"'1':-;11.-; ,', ~ ~ ~ ,;, ... I' ~ e ~ ~ t!I ~ $ " ~ ~ ~ '.' RANDY E. COMP, " <;', Defendant e 8 " ... ;;, ... DECREE IN-f- DIVORCEICA AND NOW, ,.,.. AP.J;'H.,., ,k~....." 19. .9.7.., it is ordered and tI~~SPA ~ '- ~ ^ t!I ~ ~ ~ S ~ ~ ~ $ t!I ~ ~ ~ e M ~ ~ ~:Qi-:.i:- :;.:: -:i;*-:';::' .;:. --;w..- ::+;. . ,:'0:.::.;,' .:.;.' -:.;. .:.:. .:.;. .:.:. ':.:. .:.:. .:+:. decreed that ,..., ,l<I\~IlLeE.N. .L.. ~Q~P, . . . , . . . . , , , , , , , , . , , . . . " plaintiff, and, ,. . . . . . , , , .ij.l\NP.~ ,e... .C:Q1:IJ? ., , , . , " . . . , , , . , . . . . . . . .. . , , .. 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; w '" " '" ,:, ~ None ........ ,........... ,.. ... to.......,............ to.,.,....., ..,. to to ....." ,', ~ . ".......,........ to...,....... to.... to... t... ......... ~ ',' $ w ,~ I~ I,:. (~ \I~ ,'. :!o , 'I~ .:+:. .:.;. .:+:. .:.:. .:+:. .:.:. .:+:. .:.:. .:+:. .:+:.' , /<Jed:~ 4-d':'?f"~~. J. ~k ri"'J.,.'Z' d' ,. ....~rnthnl1olnry KATHLEEN L. COMP, IN THE COURT OF COMMON PLEAS OF CUM6ERLAND COUNTY, PENNSYLVANIA NO. 95-5153 CIVIL 19 95 plaintiff vs. RANDY E. COMP, Defendant 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 (strike out section 3301(C) ~XQ<Il9 of the Divorce Code. inapplicable section.) 2. Date and manner of service of the complaint: certified, restricted mail upon Defendant on October 5, 199~ 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: by Defendant (b) (1) Date of execution of the plaintiff's affidavit required by section 3301(d) of the Divorce Code: N/A (2) Date of service of the plaintiff's affidavit upon the Defendant: N/A 4. Related claims pending: none 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d) (1) () of the Divorce Code. (P aint!!f) .~ Griffie, Esquire 200 North Hanover street Carlisle, PA 17013 iT r-. " j::: .. we - ,1.,1" t--' 0' /. r" .....:1: 1"'-1 ,,", ~f :-::'i c 0 (n " , ~.:.. i;'''': --'I' : ('1:' .' u=< Ii,) i~- ,,- !u.. "" lJ. ..... 'j (.) en u KATHLEEN T. COMP, . IN THE COURT OF COMMON PLEAS OF . plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL ACTION - LAW . . RANDY E. COMP, . 1995 - 5153 CIVIL TERM . Defendant . 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 will proceed without you and a decree in divorce or annulment may 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 the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 Fourth Floor Cumberland county Courthouse Carlisle, Pennsylvania 17013 KATHLEEN T. COMP, Plaintitt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1995 - :/IJ',J CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintitt is Kathleen T. Comp, an adult individual v. RANDY E. COMP, Defendant currently residing at 1 Mainsville Road, Shippensburg, Cumberland county, Pennsylvania. Ms. Comp has resided at said address since April 4, 1995. 2. Defendant is Randy E. Comp, an adult individual currently residing at 1229 spring Road, Carlisle, Cumberland County, Pennsylvania. Mr. Comp has resided at said address since June, 1993. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months. 4. Plaintiff and Defendant were married on May 25, 1991 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. Plaintitf has been advised of the availability of counseling and the right to request that the court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintitt and Datendant are citizons of the United states ot America. 9. The parties' marriage is irretrievably broken. 10. Plaintitt desires a divorce based upon the beliet that oetendant will, ninety days trom the date ot the tiling ot this Complaint, consent to this divorce. WHEREFORE, Plaintitt requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. Section 3301(c). COUNT II INDIGNITIES 11. Paragraphs 1 through 10 are incorporated herein by reterence as it set torth in their tull text. 12. Detendant has committed such indignities upon the person ot the Plaintitt, the innocent injured spouse, as to make her condition intolerable and life burdensome. WHEREFORE, Plaintitt requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. 3301(a)(6) of the Divorce Code of 1980, as amended. COUNT III COUNSEL FEES. COSTS AND EXPENSES 13. Paragraphs 1 through 12 are incorporated herein by reference as it set torth in their full text. 14. Plaintiff is unable to provide for or afford her counsel fees, expenses, and costs during the pendency of this divorce action and through its resolution. 15. Plaintiff is without sufficient property and otherwise unable to financially support herself despite being employed. 16. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for couns.l fees, expenses, and costs as well as alimony and alimony pendente lite for plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay plaintiff's counsel fees, expenses, and costs as well as providing for payment of appropriate alimony and alimony pendente lite to Plaintiff. Respectfully submitted, GRIFFIE , ASSOCIATES I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING COMPLAINT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: q - J 'I. q <;- -d/~ . r;o; ~) t.. -, ~\I! lc , . 4'T}; \".;. ff:: i::...: " . .' J;' . :.-:.1 --. r-.... JlL I ! . , G.: !1 C~ , i:ij L. "- 4- iLt. ,... -.. U G' .,.1 ... In en ~ , _r "-., .- ,,' t~_l . . ,. , , . . , '~ z ~~ ~ ,:.";t:1:'~':t\ -~ ~il'"l'o " ""., ~'2'!l 069 875 668 Receipt for Certified Mall No Insuranco Covoruue PIO\lidcd Do not uso for Inlomotionnl Mail 1500 Revorsol Spring Road PA 17013 $ . /, /0 ,. ~. ~ ~ en LLJ !.cc .~ ~ ~ f I' II dl~tr ~i'i~ ~e I',,,l"'.ll' C..II,t,,,.111'I' SI"Il""llt<i'",,,,' II" fJ,,\\!,,'\I.,jl)j!"""'V ,,'~ "0'11/1' .,...,.".",'. :".......-'""l . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1995-5153 CIVIL TERM IN DIVORCE KATHLEEN T. COMP, plaintiff vs. RANDY E. COMP, AJ'rIDAVI'l' or CORSlnlT 1. A complaint in Divorce under Section 330l(c) of the Divorce Code was filed on September 27, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in tho prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND TH~T FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE I J J h .../'7 (,' I ' fj: en -- f N ~7: .. :J."r - C);) ~ - O.~ c: :,1, r:l:"j \i: (") ~~f/=: u. , d1c; UI ...... ~;.Jrh :.1: ..-:(, 1'.'0... 1- -', ~.~ u. \!) ::; 0 (J\ <..) ~.... \0 .- i.i~ \.f', ;:= 1......., J_< C' .. ~U-. r )"." . ::~~ p,:' ,...\\ .-- '-. '7 ' .' 1 ~; C" - -'. I .' uJ ....+ 1:'1" . (," -,I,) ..' l< io.:... \-" I..!. ,,- r- .J 0 0' () KATHLEEN T, COMP, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW vs. RANDY E. COMP, Defendant NO. 1995.5153 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330Hc,) OF TilE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 veritY 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, Section 4904 relating to unsworn falsification to authorities. DATE: 4/!7 ,/ U:~ It E, CO ~ " ~.;~ In LJ', "- ~ 1I1~ ".; ..... L'l'. ..:1 r' ,:,J .:..,.. '.' c.. ;-;::j q~: C-,I, ~n If) LL\t:1 I . .< iI:! ~< ' C' .- ~1 " .tJ i.: uJ !:).. L... 1', r- _:.J (.) 0' ) ...... rJI it; LJ: i" .. .' lU! t(; '1?i. .... Ft', , ~~ :'=l , I: . c. ] [-.: I l,., 1(1... i l.. r" , Lo. , (J c." KATHLEEN T. COMP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION. LAW vs. RANDY E. COMP, Defendant NO. 1995-5153 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST f:NTRY OF A DIVORCE DECREE UNDER SECTION 330J{c.) OF THE DIVORCE CODE 1. I consent to the entry ora tinal decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or eKpenses if[ 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 tiled with the Prothonotary. I verifY that the statements made in this atlidavit 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 unsworn falsitication to authorities. DATE: c9/7 /7' '7 I .