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Home My WebLink About96-00218 . ~ J\ ....... , " /' /,., ./ J j 1cJ../7.~ do,;! (~j' /1l'i"J:/ ~ .<>tf ~i-t7<~ 6).17.% YU4.' Mi4'~ ~~. t: :.\ 1 STEPHEN D. DAY IN THE COURT Of' COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL DIVISION - LAW PEGAN L, DAY NO. 96-218 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the rccord, togcther with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: IlTetrievable breakdown under Section 3301(c) of the Divorce Codc. 2, Date and manner of service of the Complaint: The Complaint was mailed by certified, rctum receipt mail to Defendant on January 20, 1996. 3. Datc of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: Plaintiff signed on November .!.i,. 1996; Deti:ndant signed on October 15, 1996; Dcfendant also signed Waiver of Notke of Intention to Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code on October 15, 1996 4. Related claims pending: NONE. D :1- 15 - '14 ATE: JOHN H. ROUJOS, ESQ IRE BROUJ ,GILROY & HOUSTON, P.e. 4 NORTfI HANOVER STREET CARLISLE, PENNSYLVANIA 17013 717/243-4574 OR 7171766-1690 FAX 11717/243-8227 , j' "f; , I. ,. ( II, 1 ' " ., ': STEPHEN D. DAY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL DIVISION. LAW NO. q,-,.) It CIVIL -t9%- T.e~......--- PEGAN L. DAY Derendant IN DIVORCE NOTICE TO DEFEND AND CUlM RIGHTS You have been sued in Court. I f you wish to dc:fc:nd 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 d.-cree of divorce or annulment may be entered against YOII by the Court. A judgment may also be entered against you for any otho:r 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 grounds for divorce is indignities or irretrievablo: breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Oflice at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU 1\1 A Y LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TlIIS 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 CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 717 - 240-6200 STEPHEN D. DA V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVLVANIA Plaintiff v CIVIL DIVISION. LAW PEGAN L. DA V NO. 'it.,. .}/" CIVIL lH6 T" ,.~, Defendant IN DIVORCE COMPLAINT Plaintiff Stephen D. Day by his attorney, Broujos, Gilroy & Houston, P.C., sets forth the following: 1. PlaintitT Stephen D. Day is an adult individual residing at 292 Smith Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2, Delcndant Pegan L. Day is an adult individual residing at 50 Bonnybrook Road, Lot #26, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The parties were married on February 28, 1992, in Cumberland County, Pennsylvania. S. In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 6. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. >- M (:: C. - ~. - ..'.:J ~ ~q ,;.~ ..) .-.. (l . fft-. 0.: (.J;:: ~f. '-'\.u; 1.J:::-, ('..1 ~~~ ~Q '" C' f,"l ::-: . t:..LJ ........:, , '!Uo. LL .n ::i <;.) " U STEPHEN D, DAY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v CIVIL DIVISION. LAW PEGAN L. DAY NO. CIVil. 1996 Defendant IN DIVORCE AFFIDAVIT OF CONSENI 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 17, 1996. 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 tinal decree of divorce afte~ service of notice of intention to request entry of the decree. I veritY 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 DATE: 1\. ''S'. (1l4> STEPHEN D, DA Y, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Piaintiff vs. CIVIL ACfION - LAW NO. 96.21S CIVIL TERM PEOAN L. DAY, Defendant IN DIVORCE AFFIDA VIT OF CONSENT I. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on Janurary 18, 1996. 2. The marriage of plaintiff and defendunt is irretrievably broken und ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a finul decree of divorce after service of notice of intention to request entry of the decree, 4, I understand that I may lose rights concerning ulimony, 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 IS Pa. C.S. section 4904 relating to unswom falsitication to uuthorities. ~ 1 Date: October \5" , 1996 l~r'~~l~ly,,':;1 [:'?"~/~~ 110 and ~ubscribed before n. lethi~;': ~f') day of October, 1996. '., '."" c.' .'. '.' -g., I )~I it'l' e - ,~ . /,., . ,. - .. .." .., ..... - -- '. \.. \V l..~ ' h,. .c.".......,..!'".,..., "{'/ I (,-. .. - Notary Public ~ C'J ~" f. ~J ::) IUl (.1' :'-i: \0'... l,Ct .....1. ...... -'::::! (~~ ' ~: ,~ (J) .-/ I . ., 111'- 0- -'" -. 'Jr,J U..' G "!U- " I' Ln ..J L; U\ 0 " , ' , . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN D. DAY, vs, CIVIL ACTION. LAW NO. 96-218 CIVIL TERM PEGAN L. DA Y, Defl'ndant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER !l 330((c) OF THE DIVORCE CODE 1. I consent to the entry 01 a linal oecree ot divorce wllhoUl nOl1ce. 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 gnulled. 3. I unders1and that I will not be divorced until a divorce decree is entered by the Coun and that a copy of the decree will be sent to me immediately after it is t1Ied 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 IS Pa. C.S. !l4904 relating to unsworn falsification to authorities, DATE: October~. 1996 " >- r.~ j:; w~-:-. l". ll; ~. [I. 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