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HomeMy WebLinkAbout95-06432 in" \tM Mf... ;\,l.'i :fillt,. $~_.r:-'---o',_ &,;t.. . In, :7".. . ~ .'.... · ... 'M. ... · · ... - ... ... 'M' - 'M. ... ... ... ... .'.':'*=-::"'".- .'.":15 . ._~----~_._-_.~~----~,- ~ I' t ~ . IN THE COURT OF COMMON PLEAS . . . . OF CUMBERLAND COUNTY . 8 : .. * . , . : STATE OF ,.... PENNA. ! . . . . . 95-6432' . Denise E. Littles. Plaintiff N no,........".,,,,,,, "."".....",.. It) :: . . . V,'I"II' .. . . . Nathanial D. Littles. Defendant _ . ,. ~ ~ . . · DECREE IN ! : DIVORCE i ) AND NOW, . . ~~. .'1. . . . . . . . . . . , .. 19.98... 0 It Is ordered ond t , decreed that.. . .~~~~l! .~'. .~~~~~l!~'. .. . . . . . . .... . . ... . o' . . . ..... plaintiff, . . and. .. . .. . .. .. . . ~f'~!1!l!1~f'~. P~. ~~~~.l~!l', . . .. .. .. .. . . .. .. .. . .. .. defendant, , .. are divorced from the bonds of matrimony. ij . " . The court retains jurisdiction of the following c10lms which have 8 . been raised of record In this action for which a final order has not yet : . been entered: . .. 1 \ l!I · . . . . '-.10\1:1..(>. . . , , . , , . . . , . . . . . . , . . ' , . , , . . . . . . . . . , . . , .. , , , . . , . . , , . . .. , . . , . , . . : .........,.".."..,..,.,....:;/..,',..,...,."."...,. , 1/: , lIy ~(;1l.t.l. .J * : Alle'lI . 0 d~ J. ~ ~ ~~~:j~ ~ ( (, ~ Prothonotary : -..-..-.. - . ......,....... - -.... -.. . .~.;., - -. - - - j .. - . . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6432 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DENISE E. LITTLES plaintiff NATHANIAL D. LITTLES, Defendant ...aOI.. TO T.....KIT .aCORD To the Prothonotary 1 Transmit the record, together with the following information, to the Court for entry of a divorce decreel 1. Ground for divorce 1 irretrievable breakdown under S (3301(c) 3391(11) (1)) of the Divorce Code. (strike out inapp1ioable section). 2. Date and manner of service of the complaintl November 9. 1995 by certified mail. return receipt reauested. Affidavit Qt Service filed on November 16. 1995. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by 5 3301(c) of the Divorce Codel by plaintiff March 25. 1998/ by defendant on March 12. 1998. (b)(l) Date of execution of the affidavit required by S3301(d) of the Divorce Codel HLA-I (2) Date of filing and service of the plaintiff'S affidavit upon the respondent I tllA-. 4. Related claims pendingl None \ DENISE LITTLES, 1 IN THE COURT OF COMMON PLEAS OF Plaintiff 1 CUMBERLAND COUNTY, PENNSYLVANIA : NO. 9t - 1../13;)" e 0/ '7f1z,,) v. I .llJI : NATHANIEL LITTLES, 1 CIVIL ACTION - LAW Defendant I IN DIVORCE HOTIC. TO DIIPIIIlD &liD 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 of 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 grounds 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, High and Hanover Streets, Carlisle, Pennsylvania 17103. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 Court Administrator cumberland county Courthouse ~'ourth Floor High and Hanover Streets Carlisle, PA 17103 (717) 240-6200 DENISE LITTLES, Plaintiff v. 1 1 : : : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 9t. G,I/'JJ... G~Jll ~'L'''1 CIVIL ACTION - LAW IN DIVORCE NATHANIEL LITTLES, Defendant COMPLAIn III DIVOaC. AND NOW, comes the Plaintiff, Denise Littles, by her attorneys, Wix, Wenger' Weidner, and files the within Complaint against the Defendant, averring as followsl COUNT I - UIID.. aa 3301101 AND 33011dl O. Ta. DIVOaC. COD. 1. Plaintiff, Denise Littles, is an adult individual who currently resides at 4940 Simpson Ferry Road, Mechanicsburg, Pennsylvania 17055. 2. Defendant, Nathaniel Littles, is an adult individual who currently has a mailing address of Dauphin County Prison, 501 Mall Road, Harrisburg, Pennsylvania 17111. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months previous to the filing of this complaint. 4. Plaintiff and Defendant were married on August 7, 1991 in Harrisburg, Pennsylvania. 5. The Plaintiff and Defendant are both citizens of the United States of America and are not members of the Armed Forces. 6. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 7. This action is not collusive. 8. Plaintiff has been advised of the availability of counseling and understands that she may have the right to request that the Court require the parties to participate in counseling. 9. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree of divorce pursuant to 5 3301(C) or 5 3301(d) of the Pennsylvania Divorce Code of 1980, as amended (the "Divorce Code"). COUll'l' II - 8IIIPL. IIIDIClMI'l'U8 10. Paragraphs 1 through 9 are incorporated by reference as if set forth in full. 11. Plaintiff avers that in violation of his marriage vows and the laws of the commonwealth of Pennsylvania, the Defendant has over a period of time from the date of the marriage until the present time, offered such indignities to the person of the Plaintiff as to render her condition intolerable and her life burdensome. WHEREFORE, Plaintiff requests this Honorable court to enter a decree for divorce on the grounds of simple indignities pursuant to the Divorce Code. Respectfully submitted, WIX, WENGER , WEIDNER BYI - (rA .Ort!utf).=- T~tton, 1.0. 165853 508 North Second street P.O. Box 845 HarriSburg, PA 17108-0845 (717) 234-4182 DATE 1 November 8, 1995 C.\TAH\DDcumont\llttl...Com V.RIrIC"'l'IOH I, Denise Littles, Plaintiff in the foregoing Complaint, have read the foregoing Complaint and hereby affirm and verify that it is true and correct to the best of my personal knowledge, information and belief. I verify that all of the statements made in the foregoing are true and correct and that false statements made therein may subject me to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. ,))--D w.:~. f Denise Littles " -' ~' lnl.\ \. DATE 1 November nil, 1995 DENISE LITTLEB, I IN THE COURT OF COMMON PLEAS OF Plaintiff 1 CUMBERLAND COUNTY, PENNSYLVANIA I v. 1 NO. I NATHANIEL LITTLES, I CIVIL ACTION - LAW Defendant 1 IN DIVORCE C..TIWIC&T. OW a..VIOI I hereby certify that the foregoing Complaint was sent by certified mail this day to the followingl Nathaniel Littles Dauphin county prison 501 Mall Road Harrisburg, PA 17111 Respectfully Submitted, WIX, WENGER . WEIDNER BY~--1...,,-\ Q'zI~ Thomas A. Hutton 1.0.165853 508 North Second Street P.O. Box 845 Harrisburg, PA 17108-0845 (717) 234-4182 DATE I November 8, 1995 DENISE E. LITTLES Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6432 CIVIL TERM v. NATHANIAL D. LITTLES, Defendant CIVIL ACTION - LAW IN DIVORCE KOTIel TO DlrBKDAMT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. arrIDAVIT UMnIR .leTIOK 3301(41 or THe DIVORCI CODI 1. The parties to this action separated on October 7, 1995 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 propsrty, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statemsnts 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.A. 54904, relating to unsworn falsification to authorities. DATE I ~~~~ [nf~ Denise E. Littles, Plaintiff tl\wp51\.Jd\document.'llttl...Z.ff DENISE E. LITTLES I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 95-6432 CIVIL TERM I NATHANIEL L. LITTLES, I CIVIL ACTION - LAW Defendant I IN DIVORCE ArrIDAVIT or COM.IIT 1. A Complaint in Divorce under section 3301(C) of the Divorce Code was filed on November 9, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce. I verify that the statements made in this Affidavit are true and correct. I understand that false 6tatements herein are made subject to the penalties of 18 Pa.C.S.A. 54904, relating to unsworn falsification to authorities. DATE I March~, 1998 , ~ en ~ - .. 5.]; ..:r (..k. J~ :r;: l.J:-;'I' "". 'l- ~ r'_);:.i (- fi! -~, - - :.>!I~ u. r';I J~_ ,,,. ~ IF o' ,nra ..c njtl.. ,., :t: ':,;. t5 m =.:; u DENISE E. LITTLES, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 95-6432 CIVIL TERM I NATHANIEL L. LITTLES, I CIVIL ACTION - LAW Defendant I IN DIVORCE WAIVIR or KOTIel or IMTIMTIOK TO RIOUIIT IMTRY or A DIVORel DICRII UKDIR .leTIOH 3301(CI or Tal DIVORel eODI 1. I consent to the 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 olaim 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 deoree 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 oorreot. I understand that false statements herein are made subjeot to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsifications to authorities. Oatedl March ~) , 1998 ~~ 01 "- f:; .. ...- ~ ::~..- 1-) ..C~ 2c':' :;c: (7 ,):-;: ;~. U- f"';'" C' "~ .,' .,' G"~ '" .... M ..,,:', rb,l n-: ,lilt:; ri= Hi, ~H 0.. x: 15 CXl a 0' . . I CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6432 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE I v. NATHANIAL L. LITTLES, Defendant arrIDAVIT or CO.'IMT 1. A Complaint in Divorce under section 3301(0) of the Divoroe Code was filed on November 9/ 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in 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.A. 54904/ relating to unsworn falsification to authorities. DATE I March ~, 1998 ~ en '- I" - ,:' ~~B .. . i.... ,., . - ~) \ -, ::'C ;,J:," r ",: j ;!. "'"" -,.l.:.'~ c. .~'G) f- e" '.:~ <-. . 11: 1'\" ,;j(;J (, ::;.: L:jU. " .- a 13 ~ DENISE E. LITTLES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6432 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE v, NATHANIEL L, LITTLES, Defendant WAIVIR or MOTICI or IMTIMTIOH TO .IOUI.T aMTRY or A DIvoaCI DICRII UMDIR .IOTIOM 3301(0) or THO DIVORCI CODI 1. I consent to the 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 olaim 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. 54904 relating to unsworn falsifications to authorities. II'] "I I. 'J ,. . " ~ ./}I, . /11/1, '" .'.,. 'i . ) NATIlANtEL L. LI Lts, Defendant Datedl March /2-, 1998 CI\SJD\DOCUMEN1.,lITllE'.WAIVER ~"'. - C) .. S,& us 1 r.~ ~ ~ · Ul .... C'oI (.) \~~i\ ~ ~ \ Ii' ,~ I>> ~ ,. co ~; .~ ""n r,n, ,:;:c~ f(hc. ~L ~. .,~, ,~,. '..n )'~t" o-.!;t :CJ -. ill !?, ~ :) ~d :11;.g t..l -J~ "TI ::~~ :3: (~ (j f.' ,;;! i~ :;q o ....