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HomeMy WebLinkAbout03-0124ANITA MARIE SPRINGMAN, Plaintiff KEVIN THOMAS SPRINGMAN Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO.- ~ CIVIL TERM 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 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, Pennsylvania 17013 Telephone (717) 249-3166 ANITA MARIE SPRINGMAN, Plaintiff KEVIN THOMAS SPRINGMAN Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE ; : NO.- /& t~ 200..~ CIVIL TERM COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE TO TIlE IIONORABLE, TIlE JUDGES OF THE SAID COURT: AND NOW, comes Anita Marie Springman, Plaintiff, by and through her counsel, Gregory Barton Abeln, Esquire, who files this Complaint in Divorce and in support thereof avers as follows: 5. 6. 7. Plaintiff is Anita Marie Springman, who currently resides and has resided at 846 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania, since 1995. Defendant is Kevin Thomas Springman, who currently resides and has resided at 846 W. Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania, since 1995. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. The plaintiff and defendant were married on July 19, 1992 in Durham, North Carolina_ There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. Neither the Plaintiff nor the Defendant desire to engage in counseling. After ninety days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to divorce. 10. Plaintiff has been advised that the Defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety days have elapsed from the date of the filing of this Complaint, Plaintiff respectfully requests this Honorable Court to enter a decree of divorce pursuant to §3301(c) of the Divorce Code, 23 Pa. C.S.A. §3301(c). Respectfully submitted, ABELN LAW OFFICES Gregory Barton Abeln, Esquire Attorney for Plaintiff 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 VERIFICATION ! verify that the statements made in this Complaint are true and correct. I tmderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Anita Springm~'~/~r ~'"'"~-'~' -- ANITA MARIE SPRINGMAN, Plaintiff Vo KEVIN THOMAS SPRINGMAN Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION'- LAW : IN DIVORCE · NO.- CIVIL TErn AFFIDAVIT OF SERVICE AND NOW, this 8th day of January, 2003, comes Gregory Barton Abeln, Esquire, Attorney for Plaintiff, Anita Made Springman, and states that he mailed a certified and true copy of a Complaint in Divorce to the Defendant, Kevin Thomas Springman, at his address of 846 W. Foxcroft Drive, Camp Hill, PA 17011, by certified mail, restricted delivery, return receipt requested. 2003. A copy of said receipt is attached hereto indicating service was made on January Gregory Barton Abeln, Esquire Attorney for Plaintiff ABELN LAW OFFICES 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 Swom and subscribed Before me this Day of ,2003 NOTARY PUBLIC · 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. Ariicle Addressed to: If YES, enter deliveq 3. Sewice Type ::]~Certified Mail [::]Express Mail [] Registered ['3 Retum Receipt for Merchandise [] Insured Mail [-3 C.O.D. 4. Restricted Deliver? (Extra Fee) ~Yes 2. ArticleNumber(Copyfromservicelabel)._.j~ ~ ~ 0 000 ? PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 Ii !! 111 I I ,.; ~ , ANITA MARIE SPRINGMAN, Plaintiff KEV1N THOMAS SPRINGMAN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO.- 03-124 CIVIL TERM AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divome under Section 3301(c) of the Divome Code was filed on January 17, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREiN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S. §4904 RELATiNG TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: nita Marie Springman ~ (] ANITA MARIE SPRINGMAN, Plaintiff : IN THE COUP.'[' OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 1N DIVORCE KEV1N THOMAS SPRINGMAN Defendant NO.- 03-124 CIVIL TERM AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A 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 January 17, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 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. 5. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Anita Marie Springman ANITA MARIE SPRINGMAN, Plaintiff KEV1N THOMAS SPR1NGMAN Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 1N DIVORCE NO.- 03-124 CIVIL TERM AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF TItE DIVORCE CODE 1. A Complaint in Divome under Section 3301(c) of the Divorce Code was filed on January 17, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. 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. 5. I understand that I will not be divomed 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ANITA MARIE SPRINGMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW IN DIVORCE KEVIN THOMAS SPRINGMAN Defendant : NO.- 03-124 CIVIL TERM AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE IJNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 17, 2003. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 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. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF Pa.C.S. §4904 P&;LATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Kevin Thomas Springman ANITA MARIE SPRINGMAN, Plaintiff KEV1N THOMAS SPRINGMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : NO. 03-124 CIVIL TERM PRAECIPE TO TRANSMIT RECORDS TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: a. irretrievable breakdown under § (3301(c)) 2. Date and manner of service of the complaint: 1/11/03, certified mail, return receipt. COMPLETE EITHER PARAGRAPH (A) OR (B) a. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff: 6/9/03; by defendant 6/9/03. b. Cede: ., Related claims pending: None COMPLETE EITHER (A) OR (B) a. Date mhd m~m:r cf ze.-.':-:: cf ~: net:~ce cf :_nt:rZ!on to il!: 3r::c"-~: to tr .... r~ .... , - -~ra ...................... b. Date plaintiff's Waiver of Notice was filed with the Prothonotary: 6/10/03. Date defendant's Waiver of Notice was filed with the Prothonot : 6/10/03. Gregory Barton Abeln, Esquire Attorney for Plaintiff 37 E. Pomfret Street Carlisle, PA 17013 ANITA MARIE SPRINGMAN VERSUS KE¥IN THOMAS SPRINGMAN iN THE cOUrt OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF .~_ PENNA. N O. 03-124 DECREE iN DIVORCE AND NOW, ~u~. /~ DECREED THAT ANITA MARIE SPRINGMAN KE¥IN THOMAS SPRINGMAN AND , IT IS ORDERED AND , PLAINTIFf, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOL[-OWING CLAIMS WHICH hAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT Yet BEEN ENTERED; PROTHONOTARY