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HomeMy WebLinkAbout00-03767IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MARK M. HOUSER, PLAINTIFF VERSUS BETTY M. HOUSER, DEFENDANT N O. 2000-3767 CIVIL DEGREE IN DIVORCE AND NOW, ; (Del Lei _l , ZOO 1, IT IS ORDERED AND DECREED THAT AND MARK M. HOUSER BETTY M. HOUSER 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: A J. PROTHONOTARY ?°oi ? ??? ? ??? MARK M. HOUSER, Plaintiff V. BETTY M. HOUSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3767 CIVIL TERM CIVIL ACTION-LAW 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) of the divorce code. 2. Date and manner of service of the complaint: Service upon the Defendant by certified mail-restricted delivery on June 22, 2000. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required under Section 3301(c) of the divorce code: by the plaintiff September 27. 2000 ; by the defendant September 4, 2001 (b) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (d) of the divorce code N/A (2) Date of service of the plaintiffs affidavit upon the defendant N/A 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: N/A (b) Date plaintiffs waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: October 3. 2000 Date defendant's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: September 18, 2001 Michael A. Scherer, Esquire Attorney for the Plaintiff, Mark M. Houser t`v :n - = rte; ry O MARK M. HOUSER, Plaintiff V. BETTY M. HOUSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-37(o7 CIVIL TERM 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 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 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 MARK M. HOUSER, Plaintiff V. BETTY M. HOUSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- 39G 7 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301(C) AND 3301(D) OF THE DIVORCE CODE 1. Plaintiff is Mark M. Houser, an adult individual who currently resides at 41 Carlisle Springs Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Betty M. Houser, an adult individual who currently resides at R.R. 9 Box 50, Lot # 9, Bloomsburg, Columbia County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents 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 July 29, 1999, in Catawissa, Columbia County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire I.D.# 61974 17 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff, Mark M. Houser H I j VERIFICATION I verify that the statements made in this 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 to authorities. Mark M. Houser Date: ?/ /6D MARK M. HOUSER, Plaintiff V. BETTY M. HOUSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3767 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Michael A. Scherer, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card. O'BRIEN, BARIC & SCHERER BY DATE: September 24, 2001 ¦ Complete items 1,-2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦-Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: m • Houser R '. q 130A Lo+ C) 6loomsbu?, r? 1 815 2. A. R(p} e,i,v??jtl.??b?y. ?(Please Print Clearly) B Date of Delivery 1.1 1 Mt.A_ ? - d a - "-4 i C. Signature \j X ? Agent =6 C?tl??Wy ? Addre D. Is delivery address di rent from Rem 1? PT;;_ If YES, enter deliverygddress bel ? No ta?y? /ti;l(?,11a ?d Le l' `? 3. S rvice Type - XCer[ified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes PS F9m1 3811, July.1 N& .. `, - Dp{nestfq Retum Receipt 1025a5-99-M-17ae r , c> c' c-? c- ,,, s °,-,A -_ -cac? -. - n?`= . , x y G .. .,.. fa ? .?. MARK M. HOUSER, Plaintiff V. BETTY M. HOUSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3767 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on June 20, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 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. 5. 1 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. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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: 2 /Ix L i?t) Mark M. Houser C'. ?. a° : n = = : cn ? ., „-, G C? "a P MARK M. HOUSER, Plaintiff V. BETTY M. HOUSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3767 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on June 20, 2000. 2. Defendant acknowledges receipt and accepts service of the Complaint on June 22, 2000. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 1 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. 6. 1 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. 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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: b b (n- &L", -Betty M. Houser M L- MARK M. HOUSER, Plaintiff, vs. BETTY M. HOUSER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 2000-3767 Civil NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above matter hereby elects to resume the prior surname of Betty M. Royer, and gives this written notice pursuant to the provisions of 54 P.S. §704. Date: ?-A I I M Betty M. Fk4ser TO BE KNOWN AS: ItOL 'M, Betty M. yer IL COMMONWEALTH OF PENNSYLVANIA : COUNTY OF COLUMBIA SS On the l 1-14\ day of L- , 2008, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In witness whereof, I have hereunto set my hand and official seal. Notary Public cwmonwab of Penns I"nia NOTARIAL SEAL town off 6 cmMsbu g umbla My Tune 12, 44- T 4 W -