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HomeMy WebLinkAbout02-5384 II Shane R. Anthony, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Aline T. Anthony, Defendant CIVIL ACTIOti- NO. .0,). - .j 3 Kif IN Dl\10RCE NOT ICE T 0 DEFEND 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. A jUdgment may aJso 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 Court House 1 Courthouse Square Carlisle, PA 17013-3387 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 717-249-3166 II Shane R. Anthony, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Aline T. Anthony, Defendant CIVIL ACTION NO. IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 II I Shane R. Anthony, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Aline T. Anthony, Defendant CIVIL ACTION NO. Od.. _ S36'1 IN DIVORCE CONSOLIDATED COMPLAINT IN DIVORCE 1. Plaintiff is Shane R. Anthony, a citizen of PennsYlvania, residing at 7 SUnny Lane, Dillsburg, York County, PennsYlvania. 2. Defendant is Aline T. Anthony, a citizen of PennsYlvania, residing at 1609 Elm Street, New CUmberland, CUmberland County, PennsYlvania. 3. Plaintiff and Defendant are sui iuris and have been bona fide residents of the Commonwealth of PennsYlvania for at least six months immediately preceding the filing of this Complaint. 4 . July The parties are hUsband and wife and were lawfully married on 6, 1999, in York County, PennsYlvania. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. The Plaintiff has been advised of counseling and of the right to request that parties to participate in counseling. the availability of the Court require the " I COUNT I 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. Request for Divorce Due to Irretrievable Breakdown Under 3301 (c) of the Divorce Code 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT II 13. The prior paragraphs of this Complaint are incorporated herein by reference thereto. Request for Divorce Due to Irretrievable Breakdown Under 3301 (d) of the Divorce Code 14. The marriage of the parties is irretrievably broken. 15. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. /I 116 Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the Parties to participate in such cOUnseling. WHEREFORE, if two (2) separation and Plaintiff respectfully requests the pursuant to 3301(d) of the years have elapsed from the date of has filed his affidavit, Plaintiff Court to enter a Decree of Divorce, Divorce Code. Respectfully sUbmitted, DISSINGER and DISSINGER ~~~~~ney ;~:Oi~~iff ~ Supreme Court ID # 85556 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 " I VERIFICATION I, Shane R. Anthony, verify that the statements made in the Divorce Complaint 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. AtZ.~-=- ((, ~ Shane R. Anthony, Plaintiff ~~ - ~ "" (", ~ ~ \l'. {.j ~ ~ 'ib ~ -- ~ o ~ (') ;-:.., ( " '" ~'~" I '.,.' , --,'. , " , '.--- , .~'~' ". ,', - -~ -" -<. II Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE AFFIDAVIT OF MAILING Karen L. Koenigsberg, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, return receipt requested, a true and correct copy of the Plaintiff's Complaint in Divorce in this action to the Defendant at her residence, and that Defendant did receive same as evidenced by the signed receipt dated November 7, 2002 attached hereto as Exhibit "A". Sworn to and subscribed before me this ~ day of llo~b.o...... , 2002. dl~ L .~~ 'Notary Public ' NOTARIAl. SEAL lEJGH ANN SNYDER, NoI8Iy PublIc ~- Pen)' County My Coml1'nl:tn Expna..., 11, _ --~--:----_...---_.~.--.~-~--'--.....----_.....- Q) g ClJ ~ .!!! a. . a> g. 5~~g~ U'Ci)'c>'Q) g.g-;;.s~ . <.!a ~"2ol@ M~Slrltl~ -g.~-o~~ 0- coQ5"g-Q)Q) c.JCl"OE:5~ .,.:-gffi~.sg. S Cl)OQ)"''O~ ~:S~ffiffi1: ~ :t:~co~e ~ ~~:;~:c-; '0 !; g.ta~:5 ~ EE"E:5gg ~ 8~;.tg~5 ~ . . " ~ .g a. 1a "Qj ::; g a: ~ E ci ~ " ' ~;;q wa:o 000 'lii = "::;1l~ ~~~1l M,,'g>ijl . () a: ..E Jl 0,0 ..; g g t~{ ~ ~,~ 1 <:(V)j . f 5 \-\.1)0 <V c<S""'< .:; 0 ~ <C~<. ..-: " .. '5 c '" .<: .. ~ ~ ::; 1 Ii: i ~ .2: Qj 0 a! 13 'C ~ 1;; " a: ... ~ - \., r" 0' .- 'as,) ~~ 1l~ lo "'N m E: .g'f\ m m ~o ~ >- 0 '"5 QO ...., .8'" .- EO .- " CO ~r C') E 0 5 " <( LL N CIl a. EXHIBIT I nAil il i I ~ I 2 r i 1. I" ( ,,"'y.~. , , ~.'=~A-~:~________'''' ~.:::,:, 1:..1 ':-'l r>VP1(J ; 00 $ ~', -0 'c: ~ ~. :t:. ~ -::: ~~ ~ "0 ~p P ):> ~ c+- ~ ct- C- g ~[~ \1) "~ ~ /' -----, "'. ;'.'Y1""" ".:i c z =i m . 0 (J) (J) CD );! ::l a. '-i m CD U> :-! lJ lJ 0 CD U> OJ );! CJl r CD (J) '"0 m ::::!. ;U ;:!. < '< 0 0 m c .... ::l OJ 3 .CD OJ a. a. m CJl CJl OJ ::l a. !::::! lJ + .l>o :;' - ::T iir 0' o X . ;;?liid':!! 3"U'" fi!. ;:;:oogo Z CDi,U P QCl~ G) "s: ~ ~~. o "'- "U III a: Law Offices of Lee E. Oesterling, LLC 42 East Main Street Mechanicsburg, P A 17055 (717) 790-5400 IN THE COURT OF COMMON PLEAS OF THE 9th JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENNSYLVANIA SHANE R. ANTHONY Plaintiff / Respondent, No, 07-'i1R4 (]VTT TF.RM v, Civil Action - Divorce Request for Counseling ALINE T. ANTHONY Defendant / Petitioner REQUEST FOR COUNSELING PUIRSUANT TO 23 Pa. C.S. ~~3301 and 3302 and Pa. RC.P. 1920.45 Petitioner, Aline T. Anthony, by her attorney, Lee E. Oesterling, Esquire files this petition requesting counseling, and avers: 1. That petitioner is Aline T, Anthony, an individual residing at 1609 Elm Street, New Cumberland, Cumberland County, Pennsylvania, 2. That respondent is Shane R. Anthony, an individual residing at 7 Sunny Lane, Dillsburg York County, Pennsylvania, 3. That a divorce complaint was filed by plaintiff-respondent on November 6, 2002 on the ground[s] of: irretrievable breakdown; 4. That the petitioner-defendant desires to attempt reconciliation under the provisions of The Divorce Code, 23 Pa. C.S. SS 3302 et seq. WHEREFORE, petitioner-defendant requests your Honorable Court to require up to three counseling sessions within 90 days following the filing of the divorce complaint under S 202(b) and Pa. R.C.P. 1920.45(c)(I)].) Respectfully submitted, / / ~. 'i / j. (/) / Lee E. Oester mg, Esquire I Supreme CourtI.D.# 71320 I 42 East Mai Street Mechanicsburg, P A 17055 (717)790-5400 VFRTFWA nON I verify that upon personal knowledge or information and belief that the statements made in this Request for Counselling 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, ~~4 Aline T, Anthony, Defendant Date: J / / ;). 0 10 d.- . 4 .. C2 0 ~ e- N s:- O .-4 ""tltT' r1'1 ::t:-n rnrn n rn-- z~.lJ I ''J.Fr1 Zr; N '-'6 ~:;c: ',2,( r::::C) -u ~~. -ri .-L-n ~c --".. c:~5 z' - .....~ (:~ 1"3 "--rn Pc .. 9 -z '.,.0) ~ ~ J:'" SHANE R. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COill~TY, PENNSYL VANIA v. CIVIL ACTION - LAW ALINE T. ANTHONY, Defendant NO. 02-5384 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of December, 2002, upon consideration of Defendant's Request for Counseling Pursuant To 23 Pa. C.S. ~~330l and 3302 and Pa. R.C.P. 1920.45, a Rule is hereby issued upon Plaintiff to show cause why the reliefrequested should not be granted. RULE RETURNABLE within 10 days of service. BY THE COURT, .. J. V Karen Lynn Koenigsberg, Esq. 28 N. 32nd Street Camp Hill, PA 17011 Attorney for Plaintiff vLee E. Oesterling, Esq. 42 East Main Street Mechanicsburg, P A 17055 Attorney for Defendant ) t~'7:l.l 11~~ J~-94():;>' :rc .. VINV^lA8NN3d JJ.Nno:J cr':l;ilH=J8V1Ino "'Tl .t' wd 6 <IJ: 0" '_.0 ~ -'.v in _ L . },HV1C'L,:!) 3:+t:C- l' vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION ". [Lr- NO, D;t - SJ,"'" L.to~ . l~ IN DIVORCE [ Shane R. Anthony, plaintiff Aline T. Anthony, Defendant NOTICE OF INTENTION ~m REQUEST ENTRY OF S 3301(d) DIVORCE DECREE TO: Aline Anthony, Defendant You have been sued in an action for divorce, You have failed to answer the complaint or file a counter-affidavit to the ~ 3301 (d) affidavit. Therefore, on or after September 11, 2002, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter- affidavit by the above date, the court can enter a final decree in divorce, A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed wi'ch the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief, The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR L~~ER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ON:e:, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WH:e:RE YOU CAN GET LEGAL HELP. Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 " i Shane R, Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CilllBERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant CIVIL ACTION NO. IN DIVORCE COUNTER-AFFIDAVIT UNDER S 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): a, I do not oppose the entry of a divorce decree. b. I oppose the entry of a divorce decree because (Check (i), (ii) or both) : i. The parties to this action have not lived separate and apart for a period of at least two (2) years, ii, The marriage is not irretrievably broken. 2. Check either (a) or (b) a, I do not wish to make any claims for economic relief. 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. b. I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party, If I fail to do so before the date set forth on the Notice of Intention to Request " Divorce Decree, the divorce decree may be entered without further delay, I verify that the statements made in this counter-affidavit are true and correct, I understand that false statements herein are made subject to the penalties of HI Pa.C.S. ~ 4904 relating to unsworn falsification to authorities, Date: Al:Lne Anthony, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WIi3H TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOUI,D NOT FILE THIS COUNTER- AFFIDAVIT. II Shane R, Anthony, Plaintiff vs. Aline T. Anthony, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION NO, IN DIVORCE CERTIFICATE OF SERVICE I, Karen L, Koenigsberg, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant/Respondent, Aline Anthony, by First Class United States mail addressed as follows: Date: q{ O/lJL/ Lee E. Oesterling, Esquire 42 East Main Street Mechanicsburg, PA ~055 ~'en L. Koenigsber n ~ '..~ ....., c:.~ c::;. .r- (l) ii"! -(; -; 1:: Co) o -n :.;:' ni::n r--"- r" CJ 1 '_: =;,1 f,'''} n-1 " Shane R. Anthony, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF C~~BERLAND COUNTY PENNSYLVANIA CIVIL ACTION // I L- NO. 0:2 - S- Jpv.y LtC); l. l~ IN DIVORCE I Aline T, Anthony, Defendant AFFIDAVIT OF HAVING LIVED SEPARATE AND APART UNDER SECTION 3301(d) OF THE DIVORCE CODE NOTICE TO THE DEFE:NDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-affidavit within twenty (20) days after this Affidavit has beeDI served on you or the statements will be admitted. Plaintiff's Affidavit under Section 3301(d) of the Divorce Code. I, The parties to this action separated on September 11, 2002, and have continued to live separate and apart for a period of two (2) years. 1. The marriage is irretrievably broken, 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, I verify that the statements made in this Affidavit are true and correct. I understand that false statements penalties of 18 falsification to herein are made subject Pa, C,S. ~4904 relating to authorities. to the unsworn Date: ~ I~ ~~ l ~~~-;;; Shane Anthony, Plaintiff ...., CJ C.=> -"'" (J) rn -0 o " _1 ::;1 rti~n --1 'tT! '.-,---, ':-,-<.~'T ._.-'.'~C) ~-\~ :~i ~-"i;~:'~ t:."; ';) rc:' (.0 vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-5384 CIVIL SHANE R. ANTHONY, Plaintiff ALINE T, ANTHONY, Defendant ORDER OF COURT AND NOW, this \ t ~ day of October, 2004, upon consideration of Plaintiffs praecipe to transmit record, and it appearing that Defendant's Request for Counselling remains pending, and that Plaintiffs Notice ofIntention To File Praecipe To Transmit Record was served simultaneously with or prior to Plaintiffs affidavit under Section 3301(d) ofthe Divorce Code in contravention of Burdick v, Burdid" 41 Cumberland L.J, 64 (1991), a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiencies and file a new praecipe to transmit record, BY THE COURT, .;Karen L, Koenigsberg, Esquire 28 N, 32nd Street Camp Hill, PA 17011 For the Plaintiff > ~ee E, Oesterling, Esquire 42 East Main Street Mechanicsburg, PA 17055 For the Defendant :rlm - 1..0 C'J (~J ',,- '.)- co ,-.-- :,) r..:.::) C:::.:' C~) '-':':J Shane R. Anthony, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant/Respondent CIVIL ACTION NO. 02-5384 IN DIVORCE MOTION AND NOW COMES, Shane R. Anthony, by and through his attorneys Dissinger and Dissinger and requests the court to issue Rule upon Defendant/Respondent to show cause why court ordered counsel ing should proceed and in support of this petition avers as follows: 1. Petitioner is Shane R. Anthony, Plaintiff in the within divorce action. 2. Plaintiff/Petitioner resides at 4910 Bretney Drive, Harrisburg, Dauphin County, Pennsylvania. 3. Defendant/Respondent, Aline T. Anthony, is represented by Lee E. Oesterling, Esquire. 4. Defendant/Respondent counseling. filed a motion requesting marital 5. The parties went to counseling for three (3) sessions although it was not court ordered. 6. The parties have lived separate and apart for an excess of two (2) years and it is Plaintiff/Petitioner's desire to finalize this divorce. 7. Defendant/Respondent's counsel was contacted and asked to withdraw the Petition for Marital Counseling and his response was that because he had no idea where his client was and mail sent to her was being returned, and he had no authority to withdraw the petition seeking marital counseling. 8. Plaintiff/Petitioner does not know Defendant/Respondent's whereabouts, as the last contact they had was at the conclusion of their last marital counseling session in 2003. WHEREFORE, Plaintiff/Petitioner does not believe that his divorce should be held up because Defendant/Respondent has either ~oved or is not accepting mail from her counsel and requests that a Court issue a rule upon her counsel ot record to show cause why the divorce should not be granted and the request for marital counseling be denied. Respectfully Submitted, DISSINGER AND DISSINGER ~ {;( ?A:trc~ _ M~ry'A. Etter Dissinger' d Attorney for Plaintiff/Petitioner Supreme Court ID #27736 28 North 32~ Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Shane R. Anthony, verify that the statements made in the foregoing document 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. ~~ --_.~ 'Shane R. Anthony, Plaintiff/Petitioner Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant/Respondent, Aline Anthony, by First Class United States mail addressed as follows: Lee E. Oesterling, Esquire 42 East Main Street Mechanicsburg, PA 17055 Date: Ifj;L 'juy ~4~~. Mary A. Etter Dissing~ Q ~ 0 t::::) c::::. ~;: ~ -0 -r , ~"";~: ~ --I rri l~ i:~ c.., ::L::n -.,., ._~- "< t1'lr<- ........... .-1. :~". r '" {Jrn ~~7 )," :1)6 \.D 0(' C~f': .. ; "'~ ~ :1;=n '--::"j-,l ....,....... ~i0 };' ~;l en ()l i1 ;!' ::--1 :.:;J .:::- 55 ... -<; .. II Shane R. Anthony, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant/Respondent CIVIL ACTION NO . 02 - 53 84 IN DIVORCE MOTION AND NOW COMES, Shane R. Anthony, by and through his attorneys Dissinger and Dissinger and requests the court to issue Rule upon Defendant/Respondent to show cause why court ordered counseling should proceed and in support of this petition avers as follows: 1. peti tioner is Shane R. Anthony, Plaintiff in the wi thin divorce action. 2. Plaintiff/Petitioner resides at 4910 Bretney Drive, Harrisburg, Dauphin County, Pennsylvania. 3. Defendant/Respondent, Aline T. Anthony, is represented by Lee E. Oesterling, Esquire. 4. Defendant/Respondent counseling. filed a motion requesting marital 5. The parties went to counseling for three (3) sessions although it was not court ordered. 6. The parties have lived separate and apart for an excess of two (2) years and it is Plaintiff/Petitioner's desire to finalize this divorce. II 7. Defendant/Respondent's counsel was contacted and asked to withdraw the Petition for Marital Counseling and his response was that because he had no idea where his client was and mail sent to her was being returned, and he had no authority to withdraw the petition seeking marital counseling. 8. Plaintiff/Petitioner does not know Defendant/Respondent's whereabouts, as the last contact they had was at the conclusion of their last marital counseling session in 2003. WHEREFORE, Plaintiff/Petitioner does not believe that his ivorce should be held up because Defendant/Respondent has either or is not accepting mail from her counsel and requests that a ourt issue a rule upon her counsel OL record to show cause why the ivorce should not be granted and the request for marital counseling e denied. Respectfully Submitted, DISSINGER AND DISSINGER ~~{).?~ Mary . Etter Dlsslnger Attorney for Plaintiff/Petitioner Supreme Court ID #27736 28 North 32~ Street Camp Hill, PA 17011 (717) 975-2840 II VERIFICATION I, Shane R. Anthony, verify that the statements made in the foregoing document 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. ~~~-~ Shane R. Anthony, Plaintiff/Petitioner " Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUfl1BERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant CIVIL ACTION NO . 02 - 53 84 IN DIVORCE CERTIFICATE OF f3ERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant/Respondent, Aline Anthony, by First Class United States mail addressed as follows: Lee E. Oesterling, Esquire 42 East Main Street Mechanicsburg, PA 17055 I :Date: '1;.2 tf/ I Oy I! I ~4~~ Mary A. Etter Dlsslng (") ~ () ""..::> '..... = -n ...r:- .., 1 ~ t~ :;r.: ......, C:J(J- c...-, T:n <= ril;:,,-- ....... dl. t) rn '~'''I N ; -'!- I :JJ? ...<~' ." I.D 0, r"':~ ;.: ,~ {C) 1~ ~_ :0.. :1; :rl :.~.:: <:"-:('5 ( .' ,~3''''' rO'. co -:., -'-..." )::0. ~.. :;J .:::- ~:a ... ..< ,.- "'-..r- (j""- ~...( II o 0 NOV 3 0 2D~ J Shane R. Anthony, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant/Respondent CIVIL ACTION NO . 0:2 - 53 84 IN DIVORCE RULE AND NOW this 274 day of l:)~ Co , 2004, a Rule is issued upon Defendant/Respondent to show cause why the petition for marital counseling should not be denied. Rule returnable ten (10) days after service. By >- 1..0 >- ~ ...:r t:,:; .....-- 1-'- N :: ~,~!: Ll.iP go ""- ) .' ~.I... -,.- u.. (~5~ "-~:l ....j 2;0 ('\oJ a: I ., lJ..J 0.. I -1 <"..:l ,,-- a:!.':! Ll...I ;jAb~ F:: 0 u_ _":r :~i c,~'.~.') 0 c:...-:> (.) C"-..I SHANE R. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. ALINE T. ANTHONY, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE MOTION TO MAKE RULE ABSOLUTE The Motion respectfully represents: 1. On November 29, 2004, Plaintiff filed a Motion asking the court to issue Rule upon Defendant's counsel to Show cause why the divorce in this matter should not be granted and the request for marital counseling be denied. 2. A Rule To Show Cause was issued on December 2, 2004, returnable ten (10) days from date of service. 3. As of January 12, 2005, Defendant has not responded to the rule to show cause. 4. The parties have lived separate and apart for an excess of two (2) years and Plaintiff desires to finalize the divorce. 5. Plaintiff voluntarily attended counseling with Defendant after she filed her Petition for Marital Counseling, therefore, the Petition for Counseling was never heard and a Court Order was not issued. 6. Counsel for Defendant will not file a Praecipe with the Prothonotary withdrawing his request for counseling so that the court can proceed with finalizing the divorce. 7. Plaintiff filed his Affidavit of Having Lived Separate and I Apart on September 14, 2004, and it was served on Defendant I September 17, 2004. 8. Plaintiff filed his Praecipe to Transmit the Record accompanied by the Notice of Intention to file Praecipe to Transmit the Record on October 7, 2004. 9. No other issues are pending in the divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to deny Defendant's Petition for Counseling and proceed with processing the final Divorce Decree. Respectfully submitted, DISSINGER AND DISSINGER -'\.... a, en L. Koeni sberg Counsel for Plaintiff Supreme Court ID #85556 28 North 32~ Street Camp Hill, PA 17011 (717) 975-2840 p VERIFICATION I, Karen L. Koenigsberg, verify that the foregoing facts are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C. S. ~4 904, relating to unsworn falsification to authorities. SHANE R. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. ALINE T. ANTHONY, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE CERTIFICATE OF SERVICE I, Karen L. Koenigsberg, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Lee E. Oesterling, Esquire, attorney for Defendant, by depositing same ln the United States Mail, postage prepaid, addressed as follows: Lee E. Oesterling, Esquire 42 East Main Street Mechanicsburg, PA 17055 Date: !---j t --- 05 () ,- \. ..-. ~~~ C:::1 U' (-- ~.'- C'!:J -\") 0) - (.)1 II Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs, Aline T. Anthony, Defendant CIVIL ACTION NO, 02-5384 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: 3301(d) of the Divorce Code, Irretrievable breakdown under ~ 2. Date and manner of service of the Complaint: November 7, 2002, by United States Certified Mail, Restricted Delivery. 3. (1) Date of execution of the Affidavit of Having Lived Separate and Apart required by ~ 3301 (d) of the Divorce Code: September 14, 2004; (2) Date of filing and service of the Plaintiff's Affidavit upon the Defendant: September 17, 2004, 4. Related claims pending: None. 5, Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: September 15, 2004, by US Mail to Defendants attorney, Lee E. Oesterling. Respectfully submitted, DISSINGER AND DISSINGER / d Date: /-']/-Os, 1/.71. (0 a en L, Koenigs rg Attorney for Plaintiff 28 N. 32nd Street Camp Hill, PA 17011 717-975-2840 cc: Shane R, Anthony Lee E, Oesterling, Esquire Shane R, Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T, Anthony, Defendant CIVIL ACTION NO, O.:l. -S-JJ>1 IN DIVORCE r ,..., ,-.:.;:. 0 ('~-- C::~) -, i .., f:~ ;-11 -' "~) l-:J .. . . - r-: r'.) ----- t>.) '. NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: Aline Anthony, Defendant You have been sued in an action for divorce, You have failed to answer the complaint or file a counter-affidavit to the 3 3301 (d) affidavit. Therefore, on or after September 11, 2002, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter. affidavit by the above date, the court can enter a final decree in divorce, A counter-affidavit which you may file with the prothonotary of the court is attached to this notice, Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the Light to Jsk [or CCUll(jli\ic: relief. Thc~ filing of the; form counter-affidavit alone does not protect your economic claims, 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. Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Shane R, Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs, Aline T, Anthony, Defendant CIVIL ACTION NO, IN DIVORCE COUNTER-AFFIDAVIT UNDER ~ 3301(d) OF THE DIVORCE CODE 1, Check either (a) or (b): a. I do not oppose the entry of a divorce decree, b. I oppose the entry of a divorce decree because (Check (i), (ii) or both) : i. The parties to this action have not lived separate and apart for a period of at least two (2) years, ii, The marriage is not irretrievably broken, 2, Check either (a) or (b) a, I do not wish to make any claims for economic relief, I understand that I may lose rights concerning alimony, cli\/i;::;ioll c:[ propC:Lt'{ I l:':-i.il/i'C::::- r ~J =cc_s 0::: c:.:.:pcnflC'S :i:: I do not claim them before a divorce is granted, b, I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party, If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay, I verify that the statements made in this counter-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: Aline Anthony, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER- AFFIDAVIT. Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs, Aline T. Anthony, Defendant CIVIL ACTION NO, IN DIVORCE CERTIFICATE OF SERVICE I, Karen L, Koenigsberg, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant/Respondent, Aline Anthony, by First Class United States mail addressed as follows: Date: q It< /0 1 I 1 Lee E, Oesterling, Esquire 42 East Main Str et . Mechanicsburg, PA 17055 f; ....., <;;'~.:;; (.',:.;> C",,~I (' ,.J -1) '-- :2':)'00 ;J:.': w -"'1:)" -",. C,) C.) N - SHANE R, ANTHONY, Plaintiff v, ALINE T, ANTHONY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 02-5384 CIVIL TERM ORDER OF COURT AND NOW, this 25th day of January, 2005, upon consideration of Plaintiff's Motion To Make Rule Absolute, the motion is granted, the Rule issued on December 2, 2004, is made absolute, and Defendant's petition for further marital counseling is denied. JWren Lynn Koenigsberg, Esq, v28 N, 32nd Street Camp Hill, P A 17011 Attorney for Plaintiff ? ~e E, Oesterling, Esq, 42 East Main Street Mechanicsburg, PA 17055 Attorney for Defendant :rc BY THE COURT, b~ ~ OJ - 21.t,-05 "1"'" 'lZ :f; III ;;-i(,i 07 ...,~ "'l ' 'J,' ':~! C"~i ~'.... I J '.i I .I'<.'U i,d'fLU>':'J,.; :.CJSd :3Hl 38\:j:~o-(]:njj ~!('l ....-' " o JAN 1 9 2005 rf\ r SHANE R. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENJifSYLVANIA vs. ALINE T, ANTHONY, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE ORDER AND NOW this , 2005, it is hereby day of ORDERED that Plaintiff's Motion to Make Rule Absolute is granted and Defendant's Petition for Marital Counseling is denied. This court I will issue a final divorce decree upon satisfaction that the appropriate documents have been filed with the Prothonotary. BY THE COURT: J, " SHANE R. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs, ALINE T. ANTHONY, Defendant CIVIL ACTION NO, 02-5384 IN DIVORCE MOTION TO MAKE RULE ABSOLUTE The Motion respectfully represents: 1, On November 29, 2004, Plaintiff filed a Motion asking the court to issue Rule upon Defendant's counsel to Show cause why the divorce in this matter should not be granted and the request for marital counseling be denied. 2. A Rule To Show Cause was issued on December 2,2004, returnable ten (10) days from date of service. 3, As of January 12, 2005, Defendant has not responded to the rule to show cause, 4. The parties have lived separate and apart for an excess of two (2) years and Plaintiff desires to finalize the divorce, 5. Plaintiff voluntarily attended counseling with Defendant after she filed her Petition for Marital Counseling, therefore, the Petition for Counseling was never heard and a Court Order was not issued, 6, Counsel for Defendant will not file a Praecipe with the Prothonotary withdrawing his request for counseling so that the court can proceed with finalizing the divorce, II ,I 7. Plaintiff filed Apart on September 14, September 17, 2004. his Affidavit of Having Lived Separate and 2004, and it was served on Defendant 8, Plaintiff filed his Praecipe to Transmit the Record accompanied by the Notice of Intention to file Praecipe to Transmit the Record on October 7, 2004. 9, No other issues are pending in the divorce. WHEREFORE, Plaintiff respectful~y requests this Honorable Court to deny Defendant's Petition for Counseling and proceed with processing the final Divorce Decree, Respectfully submitted, DISSINGER AND DISSINGER / ~,/ / 'X J~A... .' --' a' en :L, Koeni sberg Counsel for Plaintiff Supreme Court ID #85556 28 North 320d Street Camp Hill, PA 17011 (717) 975-2840 II VERIFICATION I, Karen L. Koenigsberg, verify that the foregoing facts are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa, C. S. !;4904, relating to unsworn falsification to authorities, " / ., cic " SHANE R, ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. ALINE T. ANTHONY, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE CERTIFICATE OF SERVICE I, Karen L. Koenigsberg, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Lee E. Oesterling, Esquire, attorney for Defendant, by depositing same in the United States Mail, postage prepacid, addressed as follows: Lee E, Oesterling, Esquire 42 East Main Street Mechanicsburg, PA 17055 Date: I/"}</ /"uS ~. ~0' -- f~ .. ~ ) ,1\ ",,-" c' ;") c.,.) .- \,..\\ - " JAN 1 \l LU\l"?rf' SHANE R, ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. ALINE T, ANTHONY, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE ORDER AND NOW this day of , 2005, it is hereby ORDERED that Plaintiff's Motion to Make Rule Absolute is granted and Defendant's Petition for Marital Counseling is denied, This court will issue a final divorce decree upon satisfaction that the appropriate documents have been filed with the Prothonotary. BY THE COURT: J. II JAN 1 9 2005 yf SHANE R. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. ALINE T, ANTHONY, Defendant CIVIL ACTION NO. 02-5384 IN GIVORCE ORDER AND NOW this day of , 2005, it is hereby Absolute is granted and ORDERED that Plaintiff's Motion to Make Rule Defendant's Petition for Marital Counseling is denied, This court will issue a final divorce decree upon satisfaction that the appropriate documents have been filed with the Prothonotary, BY THE COURT: J. SHANE R. ANTHONY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW ALINE T, ANTHONY, Defendant NO, 02-5384 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of February, 2005, upon consideration of Plaintiffs most recent praecipe to transmit record, filed January 31, 2005, and it appearing from the praecipe that Plaintiff has still not complied with the holding in Burdick v. Burdick, 41 Cumberland L.J, 64 (1991), that the Notice of Intention To File Praecipe To Transmit Record may not be served less than 20 days after service of Plaintiffs affidavit under Section 3301(d) of the Divorce Code, a divorce decree will not be entered at this time without prejudice to the parties' rights to correct the deficiency and file a new praecipe to transmit record, BY THE COURT, ~en Lynn Koenigsberg, Esq, 28 N. 32nd Street Camp Hill, PA 17011 Attorney for Plaintiff ) ~E, Oesterling, Esq, 42 East Main Street Mechanicsburg, PA 17055 Attorney for Defendant ~ 02-/f) -O~5 :rc r ~) \./ '-' '" ; i,.__ (~ ~~ "1--1 .,", a. ----- 'I shane R, Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs, Aline T, Anthony, Defendant CIVIL ACTION NO, 02-5384 IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF II 3301(d) DIVORCE DECREE TO: Aline Anthony, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the !l 3301 (d) affidavit, Therefore, on or after March 11, 2005, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce, A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims, 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. Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 " Shane R. Anthony, Plaintiff IN TEE COURT OF COMMON PLEAS OF ClMBERLAND COUNTY PENNSYLVANIA vs, line T. Anthony, Defendant CIVIL ACTION NO. 02-5384 IN DIVORCE COUNTER-AFFIDAVIT UNDER !l 3301i[d) OF THE DIVORCE CODE 1, Check either (a) or (b): a, I do not oppose the entry of a divorce decree. b. I oppose the entry of a divorce decree because (Check (i), (ii) or both) : i. The parties to this action have not lived separate and apart for a period of at least two (2) years, ii, The marriage is not irretrievably broken. Check either (a) or (b) a. I do not wish to make any claims for economic relief. 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. b, I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights, I understand that in addition to checking (b) above, I must Iso file all of my economic claims with the prothonotary in writing nd serve them on the other party. If I fail to do so before the II date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct, I understand that false statements herein are made subject to the penalties of lEI Pa,C.S. ~ 4904 relating to unsworn falsification to authorities, Date: Aline Anthony, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF. YOU SHOULD NOT FILE THIS COtmTER-AFFIDAVIT. II Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION NO. 02-5384 IN DIVORCE Aline T, Anthony, Defendant CERTIFICATE OF SERVICE I, Karen L. Koenigsberg, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant/Respondent, Aline Anthony, and upon Defendant by First Class United States mail addressed as follows: Lee E. Oesterling, Esquire 42 East Main Street Mechanicsburg, PA 17055 Aline Anthony 1609 Elm Street Cumberland, PA 17070 New 1 xc- ate: . -I j- u,) " , iIJ.' ' ," i{ 'oJ. ~-- ren II , !, ! Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T, Anthony, Defendant CIVIL ACTION NO. 02-5384 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: 3301(d) of the Divorce Code. Irretrievable breakdown under 1l 2, Date and manner of service of the Complaint: November 7, 2002, by United States Certified Mail, Restricted Delivery. 3, (1) Date of execution of the Affidavit of Having Lived Separate and Apart required by 1l 3301 (d) of the Divorce Code: September 14, 2004; (2) Date of filing and service of the Plaintiff's Affidavit upon the Defendant: September 17, 2004, 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: February 17, 2005, by US Mail to Defendants attorney, Lee E. Oesterling and to Defendant's last known address, Respectfully submitted, DISSINGER AND DISSINGER Date: 311 <;1 D 5 / 'I '. .' \L../ . I A D f\.L .0. u t'vGwV, ('. ,- .;J ,/ ~en L. Cummi gs 1 Attorney for Plaintiff Supreme Court ID: 85556 28 N. 32nd Street Camp Hill, PA 17011 717-975-2840 cc: Shane R. Anthony Lee E, Oesterling, Esquire 'J ~ Shane R. Anthony, IN THE COURT OF COMMON PLEAS Plaint if f OF CUMBERLAND COUNTY PENNSYLVANIA ~~ " () vs, , -;"1 ,:.-', CIVIL ACTION . ,-, line T, Anthony, NO, 02-5384 ' , Defendant IN DIVORCE - NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE (,.."\ 0: Aline Anthony, Defendant r'."\ f.\ You have been sued in an action for divorce. You have failed to nswer the complaint or file a counter-affidavit to the a 3301 (d) ffidavit, Therefore, on or after March 11, 2005, the other party an request the court to enter a final decree in divorce, If you do not file with the prothonotary of the court an answer ith your signature notarized or verified or a counter-affidavit by he above date, the court can enter a final decree in divorce, A ounter-affidavit which you may file with the prothonotary of the ourt is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court ay grant the divorce and you will lose forever the right to ask for relief. The filing of the form counter-affidavit alone 1 ,~onomic (l no Il I- r......~ n r "'TC"'1'P r:'C-."'-:lc<r: r, c:l:lin::::;. '1"" ,n, ~.,C _C ,C , .,._C ~OU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE ET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 -, Shane R, Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs, line T. Anthony, Defendant CIVIL ACTION NO, 02-5384 IN DIVORCE COUNTER-AFFIDAVIT UNDER ~ 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): a, I do not oppose the entry of a divorce decree, b. I oppose the entry of a divorce decree because (Check (i), (ii) or both) : i. The parties to this action have not lived separate and apart for a period of at least two (2) years, ii, The marriage is not irretrievably broken, Check either (a) or (b) a, I do not wish to make any claims for economic relief, I II understand that I may lose rights concerning alimony, lawyer's fees or expenses if I do I a divorce is granted, I division of property, not claim them before b, I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights, I understand that in addition to checking (b) above, I must la lso file all of my economic claims with the prothonotary in writing nd serve them on the other party, If I fail to do so before the , ) date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are ade subject to the penalties of 18 Pa.C.S. ~ 4904 relating to nsworn falsification to authorities. ate: Aline Anthony, Defendant OTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. >> "1 Shane R. Anthony, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. Aline T. Anthony, Defendant CIVIL ACTION NO, 02-5384 IN DIVORCE CERTIFICATE OF SERVICE I, Karen L. Koenigsberg, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant/Respondent, Aline Anthony, and upon Defendant by First Class United States mail addressed as follows: . 'Lee E, Oesterling, Esquire 42 East Main Street Mechanicsburg, PA 17055 Aline Anthony 1609 Elm Street New Cumberland, PA 17070 Date: .;1 - I ( -0 S it:f.:f.,.,:fi . :+: 'f.:+: 'f. +;+: ;+: Of. :+:;1;:1:';1' Of. . ... :+:'f.'f.+ +:+::+.:+:+ +++:fi :fi;+: :+: :+::f.+:f.:f.+:+::+::fi IN THE COURT OF COMMON PLEAS . . . . . . . . OF CUMBERLAND COUNTY PENNA. . . . . STATE OF Shane R. Anthony, . . . . Plaintiff NO, 02-5384 . . . VERSUS . . . . . . . . . Aline T. Anthony, Defendant . . DECREE IN . . . . . . DIVORCE AND NOW, 1M ~J.A 50 . J I'l",.;", IT IS ORDERED AND . . . DECREED THAT Shane R. Anthony . , . . . . . . . , Aline T. Anthony 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. By THE COURT: ~ ATTE Ta~~_ (~ . . . . . . . . . . . . . . . , . . . . . . ~ ~ ~~ ;f'f.;f ++ ;f + ;f ;f:f';;f+ +;f:t\ ;f'f.'+':f. . ... PROTHONOTARY +~~+: 'to 0Ii:f.'f.'+' , . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . , . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . , . . . . . . , . . . . . . . . , . . . J. . . , . , , . 'f.'f.'f.'f. L~ /" -'7 ~~ j;pl ..$ ~41 rJ??Y'1'--,W' /117 ~~ fJC' ~ ,.,- ~J PfJ oW ft ./ . -..