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Home My WebLink About03-0115DENNIS K. BEECHER, Plaintiff BRENDA L. BEECHER, Defendant : IN THE COURT OF COMMON PLEAS OF · ' CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- /1~,~ 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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, Pennsylvania 17013 (717) 249-3166 DENNIS K. BEECHER, Plaintiff BRENDA L. BEECHER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- Il_,z~ CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Dennis K. Beecher, through his attorney, Thomas S. Diehl, makes the following Complaint in Divome, and, in support thereof, avers as follows: 1. The Plaintiff, Dennis K. Beecher, is an adult individual who currently resides at 20 Holly Estate Drive, Gardners, Cumberland County, Pennsylvania 17324. ~ 2. The Defendant, Brenda L. Beecher, is an adult individual who currently resides at 20 Holly Estate Drive, Gardners, Cumberland County, Pennsylvania 17324. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 23, 2001 in Huntington County, Pennsylvania, as recorded in Cumberland County, Pennsylvania.. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Dennis K. Beecher, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301 (c) or 3301(d) of the Divorce Code. Date: Respectfully submitted, Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX 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. DENNIS K. BEECHER, Plaintiff DENNIS K. BEECHER, Plaintiff BRENDA L. BEECHER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-115 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 23rd day of January 2003, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Dennis K. Beecher, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Brenda L. Beecher, by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on January, 21, 2003. Respectfully submitted, Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - F^X · Pflnt no ttmt we c · Neme) ff YES, enter delivery addmse below: [] No JAN 2 ~ ' · 3.,%_S~vice Type ~ed Mail [] Express Mail ,q.J R~lstered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Re~tcted Dellvm~ (Extra Fee) 7002 0860 0001 5850 6387 Postage $ $0,37 ~.2.S0 E Certifiecl Fee ~l Sent To ~ ' ~ '~ treet, Apt. No.; ........................................................ DENNIS K. BEECHER, Plaintiff BRENDA L. BEECHER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003 - 115 CIVIL TERM : :CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 8, 2003. A complaint in divorce under §3301(c) of the Divorce Code was filed on January 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of 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. § 4909 relating to unswom falsification to authorities. Date: B~I~E~NDA L. ~I~C~/I~R, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 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. § 4909 relating to unswom falsification to authorities. ~ ..... ifRi~,NDA L. (B, BjF~C1/iE'~R, D efen dant JUL 0 1 2003 DENNIS K. BEECH]ER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA L. BEECHER, Defendant : NO. 2003-115 CIVIL TERM : : CIVIL ACTION -- LAW : IN DIVORCE AFFIDAVIT OF CONSENT 8, 2003. A complaint in divorce under §3301(c) of the Divorce Code was filed on January 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of 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. § 4909 relating to unsworn falsification to authorities. Date:-'~/c2 (//O~2 .AX/~.//~~ DENNIS K. BEECHER, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 ifI 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 a copy of the Decree will be sent to me immechately 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. § 4909 relating to unsworn falsification to authorities. DENNIS K. BEECHER, Plaintiff JUL 2 3 2003