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Home My WebLink About96-00919 \ & c 8 c:: . VJ 7 " a c. 8 "< , '. ',,'.... "'- ... ~ J 0- - 0- ~\ ."J ~. :~~~,*,:~;~"~~.~-~.,*-~.,~"~-:~.~;~'~._~,.:~ :~~.~.~~"'~.~~.~.~ ~ ~ ~ :~ :-. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. ~ ~ ~ ~ ~ ~ ~ ~ ~ " ~: ".i ~, ~ THOMAS P. NOONAN ;'\ II. 96-919 CIVIL 96 II) \'t'I':.;Il:; CHRISTINE M. NOONAN ~ ~:: ~ ~. DECREE IN DIVORCE ~ .." "I ,",r ~i ~) ':1 ~; . i ~I ~I '~j '''1 ~I .1 ~l "/ ~ ~ ~ ~I ~! . I '011 ':'1 ~ ~: f '.;..;. AND NOW..,.",. .o.~...~'" J~.,." 19 ,~f",... it is ordered and decreed that" ,1'~9W!$, !?'" .t:lOoN1\t:I""",.,.,.,.......,.,..,. plaintiff. and. , , . , . . . , . . , ,CHRIST.INE, M.. . NOONAN. . , , , , , , . , . , , , . . .. , . '. defendant, are divorced fram 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; NONE. ALL ISSUED SETTLED PURSUANT TO MARRIAGE SETTLEMENT .,.,"".",., ,.. ......... .... .... ....... ", AGREEMENT DATED JUNE 25 ,.1996... , , , . . , . .. , ., . . . . . , . .. . . . . , . , , . . , ,. ,. . ny~t):u/J;L . ^lIe~';: Y:;~ LI?H<:l ~'. i~~ ~.~; /~~7C':.'h~ ~ ..J:sc&, tf4 ~OnOlnry .'i/ .*..*..*".~..~.~..~.~"~".~.,~.*,,*,~..~.~.~.~.~.,~*~. I, :~ i. "il I::. I~ ~ ~ I~ ~ ~ ~ ~ ;,i ~ ~ ~ '.' ~ ~ i~ I~ I~ I~ I.. I~ I'~ I \~ \': I~ )~ ~ ,~ /. ~~ /. I~ I'i/ ('.- I~ l~ I': ;~ !~ /. :iil '~ r".' i'~ /'.' . . ' . - / ....# ~:.~~%o cia/. {~~ ~~~ ~ <'~.~ /k~~ /t 3* 7;~.t- ~/'~ R c6./ t I! . C) , r, ~ .--:i [,: l"J . l "1:1; t..., (1)I:j' :.,., 11 tJ 'j Ef(:' (..- :...) >'11 ~. - Q ::"1J '-" -:in __to , . . . <:/} ~;'{' ;"':'. ~. () ( ~J ,~) til .. " ::-::1 -. (.:J ~; -.; i I i , ! I I I l I i ! f I i. .. \ i . , I it J; t I; , i, \ i , I ,..J ;.J i"' ',- :... \"" -:J ~ \'\; '.""\~ ..... '" .......... -......;. JG::) ~ ~ ,r- -4-. '.;..:. '~ ~,~~ 1..;- '-"":" :'., c I.!..' -I ':;; "" "'ro ..... , , I . I, I , - ~ - ...... "-S L_ L. , .-) '.-', C..t c ~ ~3]~ ~ ~t~ c;~~~ ~!iK ., . ... , .. -. v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. "ifc. q (1 (1L<'~ (.-X)tCI''-. : CIVIL ACTION - LAW THOMAS P. NOONAN Plaintiff CHRISTINE M. NOONAN Defendant NOTICE YOU HAVE SEEN SUED IN COURT. If you wish to defend against the claims set forth In the following pages, you must take prompt action. You are wamed that if you fall 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 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 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, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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 1 COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-2600 D1MH. G. RADCLIFF ATI"URNEY.A r.L\W H04H rRI~IlU: IUMU C,\.\lP fIIlL P.-\ I1UI! 1 THOMAS P. NOONAN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. CHRISTINE M. NOONAN : CIVIL ACTION. LAW Defendant COMPLAINT t i " AND NOW, this ~~ay of kill"". nl^"'119~, comes the Plaintiff, Thomas P. Noonan, by his attorney, DIANE G, RADCLIFF, ESQUIRE, and files this I Complaint In Divorce of which the following is a statement: COUN'T I: DIVORCE 1. The Plaintiff, Thomas P. Noonan, is an adult individual residing at111 Stanford Court, Mechanicsburg, Pennsylvania, since September 1995. 2. The Defendant, Christine M. Noonan, is an adult individual residing at 85 Ashford Drive, Enola, Pennsylvania, since 1983, 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 25, 1982 at Lemoyne, Pennsylvania, ; . . DI,\:-Of. C;, RAJ>CUH ..\ r r 0"':'''. \'-.\ f.J.,\W u... I M'....I)I. aO\1I L.Ht.. HII_L P.-\ 171111 2 5. There have been no prior actions of divorce or annulment between the parties. " 6, Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defenda~t is not a member of the Armed Services of the United States or any of its AI/ies, 8, The Plaintiff avers that the grounds on which the action is based are: (a) That the marriage is irretrievably broken, Or in the alternative, (b) That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage Is irretrievably broken. Or in the alternative, COUNT II: EQUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. DJ.~~I G, RADCLIff .\TrOJl~E"t.A f-L\W 14"" nl~H1.f. Ro>\n <""4P III 11., '\ 111111 3 10. Plaintiff and Defendant have legally acquired property, both real and personal, during their marriage from September 25, 1982 until mid-September 1995, the date of separation, all of which is 'marital property". 11, Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, 'non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property", , 12, Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property of the parties. Respectfully submitted, RA eRoad , , PA 17011 (717) 737-0100 1.0, No. 32112 Attomey for Plaintiff l " 01.-\:'<[ c;, R,UJCurr ArrOR.'''EY.A r.L\W ""..II UJ."'HU.f IUHf) L\....' HILL p.\ 1:011 4 . YERIFlCAnON THOMAS P. NOONAN verities that the statements made in this Complaint are true and correct. THOMAS p, NOONAN understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. dbL~ ,! DIA,~f. c. R,\OCI.IH "rJOR:'Iif.Y.'\ r.tAW 1-4-4" nu:-.uu' .".\1) CUt' Hill. P.\ 171111 --- ' . L4W onu:a Dwont G.'R.ulcJ.m Al'IOMft AY l..\w S44I T_ Roo4 Camp Hm. PA 17011 , - .,'- ,. .' i.:~'_'i W' 00 .......'1 _tI't T!lA" ..,....c..~. I.AT......"""_~_. TN. GIll_MAL ..... OIP 1.~1)MJ: ." Dl"'" ... MOCU.... .' ''1 - ,-~~ i.-;,:,{:i} v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-919 CIVIL TERM THOMAS P. NOONAN, PLAINTIFF CHRISTINE M, NOONAN, DEP'ENDANT CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 20( 1996. 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 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 unsworn falsification to authorities. Dated: L:,.z.S-.9~ THOMAS P. NOONAN, PLAINTIFF v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-919 CIVIL TERM CHRISTINE M. NOONAN, DEFENDANT CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE 1. 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 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 6nd 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. Section 4904 relating to unsworn falsification to authorities. Dated: t,-ZS-9b IlIANE G. RAIlCl.IfF ,\ nnRNF.V.^T-J.AW HHI IRI:'IiJH.f. )lc)..\n CHIP 1fI1-L 1',\ 17011 , f I t \ ! (') _0 0 C U' "I ;;.- ~- R~ -rJ(,:: ~ I!)f.' . ...~ I '," Zt, ') en - N '1 2:- :i~ ..~... J:',~ ;a.;. ,., : n -'-., ~~-. C? :1 .. ..,. : .~ \D , ~ , j"" , "., . , I 1 I .1 i '1 f: " I ':.) , , I . I '-' ,!) r ~ , I "d . i~i - :", :) (i.1 .- " :...:! .:J "', ,. ~ ',. i . 'J , I;, I I v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-919 CIVlL TERM THOMAS P. NOONAN, PLAINTIFF CHRISTINE M. NOONAN, DEFENDANT CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDtR SECTION 33011c\ OF THE DIVORCE CODE 1. 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 l 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. Section 4904 relating to unsworn falsification to authorities. Dated: C) l(j-tffp t?A U~.IU /A<A.JtJrHt tJ L< CHRISTINE M. NOONAN t OIAN.: (;, RAIlCLlH A nnRS[Y.AT.).AW 'WI 11l1~IH.f IUJ,\U (A\tP 11111. " 17011 , :1 j~ c " ',-I LI .~~ -"'J .'0 r,) 1.:.J I :.'1 , " .....,'/ ri)1 L:j -, ~;~' , ..,!; ....""", c.') ., ,:.J ~i:') '-II ;:IJ >\-J )ill ! ~.d .~ 'D THOMAS P. NOONAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 96.919 civil Term CHRISTINE M. NOONAN Defendant CIVIL ACTION . LAW IN DIVORCE ACCEPTAtlCE OF SERVICE I, SAMUEL L. ANDES, ESQUIRE, Attorney for the Defendant in the above captioned divorce action, hereby accept service of the Complaint in Divorce filed February 20, 1996 in the Court of Common pleas of Cumberland County, Pennsylvania. Dated: 2"1 Feb 1'17L ~~Q' Attorney for Defendant DIANE G, RADCLIFF ArroRNEY.AT.lAW J.t..8 TIlI~IlU ROAII C\.'HP lUll., P.' I7UII lQ ;',-'j () . , 1 ~/) ry--: , '1 il~d ~;; -"<;J t....> in :;::J {:J ,:':, ~~ " ';'4 1 1 i :lJ 0:'.''; .. 'i.~ r.>~' :::, '~ rl'f '> ~:J ~ , ,. .. ('0 ~::! -~ -', l I I I I f I f I i I I (, "