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HomeMy WebLinkAbout07-0272LYDIA K. SCHNEIDER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-,2 72 JEFFREY R. SCHNEIDER, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS el, 0 L -T" You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 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 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 Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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, PA 17013 Telephone: (717) 249-3166 t 00 LYDIA K. SCHNEIDER, Plaintiff vs. JEFFREY R. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. a 7- a 7,2 ? % IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. 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 being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, 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 spouse. If you desire to pursue counseling, 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. i LYDIA K. SCHNEIDER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0 ,7. a '7.2., JEFFREY R. SCHNEIDER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, LYDIA K. SCHNEIDER, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is LYDIA K. SCHNEIDER, an adult individual who currently resides at 85 North 41St Street in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is JEFFREY R. SCHNEIDER, an adult individual whose residence of record is at 4883 Spring Road in Shermansdale, Perry County, Pennsylvania but whose current mailing address is 3 16th Training Squadron Unit 6665, Goodfellow, Texas 76908. 3. Both the Plaintiff and Defendant have been bona fide residents of 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 25 October 2003 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. 1 L. An es Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 _l I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: A K. S IDER a o W l ' C• ff_. N y 0 • T T Y lam! c-n SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE*NO: 2007-00272 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SCHNEIDER LYDIA K VS. SCHNEIDER JEFFREY R R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT SCHNEIDER JEFFREY R , by United States Certified Mail postage prepaid, on the 23rd day of January ,2007 at 1000:00 HOURS, at 316TH TRAINING SOUADRON UNIT 66645 GOODFELLOW, TX 76908 a true and attested copy of the attached COMPLAINT - DIVORCE Together with , The returned receipt card was signed by JEFFREY SCHNEIDER on 01/30/2007 . Additional Comments: Sheriff's Costs: So answ Docketing 18.00 Cert Mail 4.64 R. Thomas Kline Postage .39 Sheriff of Cumberland County Surcharge 10.00 33 . 03V Paid by SAMUEL ANDES on 02/06/2007 . Sworn and Subscribed to before me this day of A.D. D Y r r1 IN _ Q r? m 4y o U ss O gym„' .° ? ?? ? '$ 'a ? D N v N a? v co 7 t6 0 _0$ ? TE 47 ? N c? N °°sVa 0 ? f, r m c ?? ? ?N ? ? o m'•`?T??C ? ? M? s .?C-? ? r ? O ? t7 EEYodo • U ? a. N • r C txt rn t; cn C-) C:> C D V =a rn CD r" n 07 CND r - 70 yo© o - -. orno 0) Cjn ...•""'? r° m "Ft cn sv © Q rri = -n 07 o co j rN L-, f l Jl a 5j2a F 4 -' VS. In the Court of Common Pleas of Cumberland County, Pennsylvania No. Civil. To C v? 2 Prothonotary Attorney for Plaintiff OF Tt ` , No. 20GIT :F t F',`1 E : 0 a ----? _'" --- Tenn, 19 VS. PUAEeIpv Filed V 19 , Atty. LYDIA K. SCHNEIDER, Plaintiff vs. JEFFREY R. SCHNEIDER, Defendant PRAECIPE TO THE PROTHONOTARY: Please reinstate the complaint in the above matter. XMay 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. `07 Org" 07- a?a SamueTt. AnddW Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 'R? W 'k, LYDIA K. SCHNEIDER, Plaintiff ) VS. ) JEFFREY R. SCHNEIDER, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-272 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Divorce complaint in this matter and acknowledge receipt of a copy of the same. Date: 31 January 2007 J9 taLW11 J y R. Sc neider 4883 Spring Road Shermansdale, PA KI LYDIA K. SCHNEIDER, Plaintiff VS. JEFFREY R. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-272 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 17 January 2007 and served within thirty days thereafter.. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. .WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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 cotart and that a copy of the decree will be sent to me immediately after it is fled 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. C1 Z a o 7 /? Dated: 4hEYR.. SCHNEIDER -T-1 Z "' f p 6 V "Fa'J 5 iM?+M ? i Y ~ ri LYDIA K. SCHNEIDER, Plaintiff VS. JEFFREY R. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-272 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 17 January 2007 and served within thirty days thereafter.. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVE& OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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 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. 9- 2 o -o-7 Dated: LYD K. SCHNEIDER ?: c.? ? ^ ?'t l ??ti S ? ? ? j ' ? ? ,y y T `?? ??y? rp ' ?' .? LYDIA K. SCHNEIDER, Plaintiff ) vs. ) JEFFREY R. SCHNEIDER, ) Defendant ) PRAECIPE TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 07 •la,721 NO. 07-W Please withdraw all economic claims previously raised in this matter by the Plaintiff, Lydia K. Schneider. 20 September 2007 Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 P.O. Box 168 Lemoyne, Pa 17043 (717) 761-5361 tv F ) E I L n r rl Cil LYDIA K. SCHNEIDER, Plaintiff VS. JEFFREY R. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1 CIVIL ACTION - LAW NO. 07-272 CIVIL TERM IN DIVORCE 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. Ground for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: Acceptance of Service filed contemporaneously herewith indicating service upon Defendant of 31 January 2007. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: 20 September 2007 by Defendant: 20 September 2007 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 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: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 20 September 2007 filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 20 September 2007, filed contemporaneously herewith. Date: 9 17-01 07 By Samuel L. Andes Attorney for Plaintiff CT> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LYDIA K. SCHNEIDER, -? No. 07-272 Plaintiff VERSUS JEFFREY R. SCHNEIDER, Defendant DECREE IN DIVORCE 2007 AND NOW, .??I±?Or?- ZJ IT IS ORDERED AND LYDIA K. SCHNEIDER DECREED THAT JEFFREY R. SCHNEIDER AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , 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 PROTHONOTARY 019,10V f E--fl 4c Ot