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HomeMy WebLinkAbout02-4556Andrew C. Sheely, Esquire 127 S. Market Street P.O. BOX 95 Mechanicsburg, PA 17055 PA ID NO~ 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RICHARD J. MAYBERRY, Plaintiff VS. ROBIN S. MAYBERRY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 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 against you and a decree in 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 with 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. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 Andrew C. Sheely,~E~ire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 P~ ID NO% 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RICHARD J. MAYBERRY, Plaintiff VS. ROBIN S. MAYBERRY, Defendant DIVORCE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 02 - CIVIL TERM : : IN DIVORCE COMPLAINT 1. Plaintiff is RICHARD J. MAYBERRY, an adult individual who currently resides at 181 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is ROBIN S. resides at 181 Ridge Hill Road, Pennsylvania. MAYBERRY, an adult individual who Mechanicsburg, Cumberland County, 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 10, 1992 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. This action is not collusive. 10. The parties separated on or about September 17, 2002. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Date: September~, 2002 Respectfully submitted, Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Meohanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RICHARD J. MAYBERRY, Plaintiff VS. ROBIN S. MAYBERRY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 02 CIVIL TERM : : IN DIVORCE AFFIDAVIT I understand that false the penalties of 18 Pa.C.S.A. falsification to authorities. Richard J. Mayberry, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. statements herein are made subject to Section 4904 relating to unsworn September'S, 2002 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. - Date: September~O, 2002 ~ndrew Co Sheely, Esquire 127 S. Marke% S%reet P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RICHARD J. MAYBERRY, Plaintiff VS. ROBIN S. MAYBERRY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 02 - 4556 CIVIL TERM : : IN DIVORCE ACCEPTANCE OF SERVICE I, Joanne Harrison. Clough, Esquire, hereby accept service of the divorce complaint on behalf of Robin S. Mayberry, Defendant, and further certify that I am authorized to do so in accordance with PA. R.C.P No. 402 (b). I / ~/ J~ e"?I~ar ri s o~IfC~'o ~ ~E~i r e RICHARD J. MAYBERRY, Plaintiff Vo ROBIN S. MAYBERRY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4556 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce filed on September 23, 2003. 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 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. Section 4904 relating to unswom falsification to authorities. RICHARD J. MAYBERRY, Plaintiff v. · NO. 02-4556 : · CIVIL ACTION - LAW ' IN DIVORCE ROBIN S. MAYBERRY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken, (90) days have elapsed from the date of the filing and service of the Complain? 3. I consent to the entry of a final decree of divorce after service o~tice-~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 made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Robin S. Mayberry RICHARD J. MAYBERRY, Plaintiff v. · NO. 02-4556 · CIVIL ACTION - LAW · IN DIVORCE ROBIN S. MAYBERRY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 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 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 made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. '~ICHARD J. MAYBES(/ ~' RICHARD J. MAYBERRY, Plaintiff v. · NO. 02-4556 · CIVIL ACTION - LAW · IN DIVORCE ROBIN S. MAYBERRY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notic~. '~: I understand that I may lose rights concerning alimony, division of~rop-~rty, 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 made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE: ROBIN S. MAYBERRY bt RICHARD J. MAYBERRY, Plaintiff vs. ROBIN S. MAYBERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02 - 4556 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORn TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Acceptance of Service by counsel filed October 25, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on March 5, 2003 and by Defendant on March 5, 2003. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 4. Related claims pending: None. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary. March I~, 2003. Date Defendant's Waiver of Notice in Section 3301 (C) Divorce was filed with the Prothonotary. March /~, 2003. Andre~w C .~S he~el~ E~ire Attorney for Plaintiff iN THE COURT OF COMMON RICHARD J. PLAINTIFF VERSUS ROBIN S. MAYBERRY, DEFENDANT Of CUMBERLAND COUNTY STATE Of ~,~ PENNA. MAYBERRY, PLEAS N o. 02-4556 DECREE iN DIVORCE AND NOW, DECREED THAT RICHARD J. MAYBERRY AND ROBIN S. MAYBERRY ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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 ATTEST: BY T NOTARY