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HomeMy WebLinkAbout96-00631 \ i i . i i g'1 e_ I ~ I I I I I -7 i c1l' i i ,e i 1 ~ , ~/ f: ~ J r() ~ I ..3 0- 0'/' Z' .~~~~~~~~~*-~~~**~**--~~~~---~~ * IW ~ ~ .......... .... . ~.~~~...................... ................................, ~ * ~ 8.' ...........................,............................. " ~ ~ ~ ~ ~o/.1/~ _ : :.' Ali~.i; ~~~.H~~'i~ t~/,' ;?~~~~{i * : /17' ~ i .. H~~a. HK "'~~"~~la~Y .. ~ .1_______ .' _ _ ____~ : ~ .. -:c. 0>>:' .~ .. ... '.' ... -at. ... .~ ... .. <Co .. -*. <c. .~:. .*. ":':'~" -':':' .>>:. .-:.:. .' ~:. -:.:. -:.:. -:.:. ~ 8 8 ~ * e ~ e 8 8 8 ~ $ e e ~ e 8 8 8 J ~ ~ ~ s * * IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF W PENNA. Versus .................... ~ Ii .1 II II N (). .9..~.::.l?~J....g.I~~.~...:rE;~f19 96 .....HW.IL.LI~fo!..W... . KI~C; I.. .U:!;.,...... H"'H ....... Plaintiff DOREE~...M,..HKl;N.G, Defendant DECREE IN DIVORCE AND NOW, ............ i"........ t~:.... 19 .~~.... it is ordered and decreed that ......... 1'l);I,.~;II\M. '(I... .IUNn,. .lU .. ... . ... .... .., plaintiff, and. . ... .... . .. . .. . . ..l?,?~.~F;~. !'t.... i,<~~.~. .. .. .. .. ... . .. . ... .., 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; r;: ~. . 8 8 8 .. ~ ~ ~ 8 . . 8 ~ . 8 r.. ~ - . . 8 ~ ~ ~ ~ ~ ., ~ .. lC ~. $ ,. . b ;/lI.?~ M. tl?7 ~.,;.dt;6 ;;if /4Y IP !f'Pt, 'T'~ ,;ua'Jdtl ?J dtfI. IN 'I1iE COORT OF CQI1MON PLEAS OF Cll-lBERLANo c:alm'Y, PENNSYLVANIA NO. 1996 631 CIVIL vs. DOREEN M. KING, 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 19lI3Kl(lAJl:1QQ of. the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the ccmp1aint: Served 02/13/96 bv Defendant's attorney accepting same, see "Defendant's Acceptance..." 3. Ccmplete 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 06-03-96 by the defendant 05-25-96 and Waiver of Notice on 05-25-96 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 c.' 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)(l)(i) of the Divorce Code See Waiver of Notice under 3301 (c) executed by Defendant on 05-25. /' /,/ ,/ ____1 /' 1'>'" // ,,,' _,'-';./":' ,.. r/........ ,/ ___ ~;_.., / /".' Attorney for Plaintiff/Defendant William J. King, Jr. 717-232-7300 ~ ,... i':: -,. ;B .. '3~ .:r ::t: :~~ eo.. ~ ,... ....~ ..,l _ ~ I ,J~ - ~ :..1.1 ''"0 '''; l5 \.0 a r;n ., .' WILLIAM W. KING, III, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. No. 96. ft,j/ - CIVIL TERM CIVIL ACTION - LAW IN DIVORCE v. DOREEN M. KING. 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 without you and a decree of divorce or annulment may be entered against you by the court. Ajudgment 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 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 Prothonotory, Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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. COURT ADMINISTRATOR Cumberland County Courthouse - Fourth Floor Carlisle, Pennsylvania 17013 Telephone number; (717) 240-6200 , . WILLIAM W. KING, IIJ, Plaintill' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96- . CIVIL TERM DOREEN M. KING, CIVIL ACTION - LAW IN DIVORCE Dcfcndant NOTICE OF A V AII..ABILlTY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You havc bcen named as the Defcndant in a Complaint in a divorce proceeding tiled in the Court of Common Picas of Cumberland County, Pennsylvania. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Prothonotary's Office, located in the Cumberland County Courthouse, Onc Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your SpDUSC. If you desire to pursue counscling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. .' . . . . WILLIAM W. KING, III, Plaintill' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96- . CIVIL TERM DOREEN M. KING, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301 (el OR Cdl OF TilE DIVORCE CODE I. Plaintiff is William W. King, III who temporarily resides in New Cumberland, Cumberland County, and receives his mail at P.O. Box 385, Lemoyne, Pennsylvnaia 17043. 2. Defendant is Doreen M. King. who resides at 631 Gates Lane. EnDIs, Cumberland County, Pennsylvania 17025 since April I, 1995. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on September 20. 1994 in Winchester, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 8. 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. 9. PlnintilTrequests the court to enter n decree of divorce. ~ " . . 1 verify that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsifications to authorities. 'If ~(. 41 f(L~,,! fiJ.-- William W. King, III . Plainti~//,. 2' > .;&d~~;C; \ dUnm J. King, Jr.. Es Allomey 1.0. No. 30866 for King & Parnes Allorneys for Plaintiff 17 South Market Square, Suite 310 Harrisburg, Pennsylvania 17101 (717) 232-7300 Date:January, 1-/7.1996 ~ \.~ .'0 ..... 0'\ l- rr; c:: I:: M ~"~ ~~1 =)~.- 0,::: ...(-'j L.1 :.~l -,- ~rc Co. , ~1 ;:. j l . ~. ~- ltl~ In -:.~: ~.:~ I ...._'. if!' c:> ',.'W F: U-! ~. ~L_ u.. . I,l.... .,., ::.> CI 0' w . - c.. ~ \<) \.{:J '-0 '_0 ~) - "" ,~ ~ ~ --. -:s ~O ~ ~ "...... !'Q ~ r-( ~ ........ ~ l"'-' \X) ~.;;:., ~~~ r!. ~. " ,... ~ .....'- ". ..- -~ WILLIAM W. KING, III, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96- 631-CIVIL TERM DOREEN M. KING, CIVIL ACTION. LAW IN DIVORCE Defendant PRAECIPE TO THE PROTHONOTARY: Please enter my appearance as allorney for the Defendant in the captioned matter. Date: 4f3~~ 4;.. S"mPI'.S"11i~ 549 Bridge Street New Cumberland, P A 17070 717-774-1445 ~ ~.I Allorney 1.0. No., ~ '/ 7 >- en '- (,,,, I::: r'" .. ,'. w'.,; M ~ ~..( : ..1 ~~-i gf i,~)(~ fEr '. ~:i 0.. C)" "I ::rl:J IV:":.. '" .1...... ..' "..,. Cl', 0:\ ::.1rh i';': l,_~ :..~U~ '-'- (.1.. \." ~i 0 C) U r-""", ~- ...., .~- '- '." WILLIAM W. KING, III, Plaintifi' Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. No. 96- ft?vq / . CIVIL TERM CIVIL ACTION - LAW IN DIVORCE v. DOREEN M. KING, DEFENDANT'S ACCEPTANCE OF SERVICE BY AUTHORIZED AGENT I hereby accept service of the Complaint in Divorce in this matter on behalf of the Defendant and certify that, as the Defendant's attorney, I am au Dated: ~~~ , e, , i - . I liI\ .... .- . , 0 r-' 1::1 _A. L~ " . .f l: " (.: l~' .~l J I. I' I ." U '- , :_) ..- .-- WILLIAM W. KING, III, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96-631- CIVIL TERM DOREEN M. KING, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF NON MILITARY SERVICE COMMONWEALTH OF PENNSYL VANIA: SS: COUNTY OF DAUPHIN: Doreen M. King, being duly sworn according to law, deposes and says that she is the Defendant in the captioned action; that she is over 21 years of age; that her address is P.O. Box 4795, Harrisburg, PA 17111; that she is not presently in the active military service of the United States of America and is not a member of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and is not an officer of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor engaged in any active military service or duty with any military or naval units covered by the Soldiers and Sailors Relief Act of 1940 and designated therein as military service, and is not enlisted in military service covered by said act, and that the averments herein set forth, insofar as they are within her knowledge, arc correct, and true; and insofar as they are based on information received from others, are true and correct as she verily believes. Affiant understands that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. This Affidavit is made under the provisions of the Soldiers and Sailors Relief Act of 1940 and the amendments thereto. P-A { ~ ~ I.U4<./ m. Doreen M. King - Affiant Date: 5-,)2_"-- ')6 i r- is - .. d; ~~ ~ l:'5 :c rJ ~ a. ~I ~g r- ~ I fi!~~~ 7- lJ1 1'-= ::::> ~~ -, ~ \.0 a C1\ WILLIAM W. KING, III. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96-631- CIVIL TERM DOREEN M. KING, CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 5, 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 ofa final decree in divorce after service of notice of intention to request ~ntry 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. ~4904, , relating to unsworn falsifications to authorities. , .,' 1_. Date: I;, - 3 - 9 C. 11~ /1/, {~-, - William W. King, III Plaintiff i r- ~ - f ., 3~ .::r :C ':.:J a.. >: J~ ~ r- 3w I W - :"l~ ~ :5 }J ..., ~ ~ <.D C'\ WILLIAM W. KING, III, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96-631. CIVIL TERM DOREEN M. KING, Defendant CIVIL ACTION. LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330J(c) OF THE DIVORCE CODE I. 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 verilY 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 un~worrifalsification to authorities. Date: r;, - 3 -96 ~~ I/.~' (@/ William W, King, III Yuj Defendant ~ .... ~i .. .:z I~ :r:: c... 'i r- ~i I -w ~. ffi i:o 5 co .. ;;; l!J \t) :j en U WILLIAM W. KING, III, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96-631- CIVIL TERM DOREEN M. KING, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 5, 1996. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3.1 consent to the entry ofa final decree in divorce after service of notice of intention to request entry of the decree. f , . ' I verilY 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 falsifications to authorities. Date: 5/~.5i'l b '&"UM} t/?1, kt/~:r Doreen M. King Defendant ~ ,... !g - ~8 .. ..:r 81 ~ ,:: 9~ ; ,.... <"Vl I .:J~ ~ f5~ h.l "-) fj ~ \0 0\ ~ WILLIAM W. KING, III, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. v. No. 96.631- CIVIL TERM DOREEN M. KING, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330){c) OF THE DIVORCE CODE; I. 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 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 falsifica!ion to authorities. !.. Date: 5. ~ 5- ?(, ;/'yM..,,,! t.;rJ, kt~(I- Doreen M. Kmg {/ Defendant . 0 ~ f-. 1;; I~ .. ~~ ..:r n :r:: 0 rr: 0- ~~ 8 ,... ~ I - fG~ =.: ~ C~ l5 \.0 S C1'\ U IN THE COURT OF COMMON PLEAS O~' CUMBERLAND COUNTlr, PENNSlr[,VANIA . CIVIL ACTION - LAW NO. 96-631 CIVIL 19 : WILLIAM W. KING, III . . Plaintiff : : JICl'ICN IN DIVORCE v. : . , . . DOREEN M. KING . Defendant . . NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of ma trimony on the i ? day of .J 11 (\P 19 q (,:.. hereby elects to retake and hereafter use her previous name of DOREEN MARIE MARKS 1\fM.~i1A^-f~,.~.to./)ig (Sionature - rmrricd n;.~ll.! I ,;!Jl.J,'C/ltJ l7J1a )U~ (;71tl:4_hd (Signature - to be IwC'Nll as) COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND . ss. On the ~ day of J).u1'::y . 19 fl1e.., before, a Notary Public. personally appeare~ I),.,,,,,,,,,, /11.)\... M~. Imown to me to be the person whose name is subscribed to the within docu- ment, and acknowledged that she executed the foregoing for the pur- pose therein contained. IN WITNESS WHEREOF. I have hereunto set my hand and Notarial Seal. t8kC" ;J Ju.'1. d) . r Public Notartal Seal ShIrley P. Sundy. NOIaty PubI1c ....~~~,~rD.1181lp/1Jn County -,_........., ElipireiJune 28. fllll9 ,.....,. u '.:"0 1... .. '- tJ') .- ff, C': ;1: n !~~ ~j:;: - '::? IE" -. )~r: 3,f; u... }~ (;-. :n .fU) Er!~ , J ;;-= '.-..... -, 'jrn - -L. ~;; ,,~n.; 1- -~"" It. '''' '.5 (.) 0'\ l>