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HomeMy WebLinkAbout98-00526 ~ " t .'1 .. ~ -..(' . UJ ~ ~ "I t, I .'? .. Ci\! i ~ I / ( '). l~ - . . :) CJ ...,) ci ~ '" , 0... <::t- . ~ ~~"'!!~!'!' '!'!'''' '!"!'!'" 'l'!" 'I"'. U" ", M..'A."'.... & V'Y"V"'f-r:" . ";''1'"&'' .&11: -a-a" "'" .:..~.l.l.l. .I.V "I" ":":":":- -t- ":-:":- .1.1.V'll(V'IJlI.I.I.f.V'Y~IJlI"I"'I.I.I.t.I.::. :: IN THE COURT OF COMMON PLEAS I , (:.. :i: ~:.. ... .:. , ... .:. OFCUMBERLANDCOUNTY STATE OF ~.~~' 'II h~~- ~ :r ,t..~1;1.~. 't,1 .:;":";t;:~~~~.;..".. ........ ~'..._~. I PENNA. SHERRY LEE EHRISMAN, Plaintiff No. 98 - 526 Civil VERSUS TIM:YI'HY JOHN EHRISMAN, Defendant , , . . . , DECREE IN DIVORCE AND NOW, OAo!tL '2J . IT IS ORDERED AND '71Jo? DECREED THAT Sherry Lee Ehrisman . PLAINTIFF. AND Timothy John Ehrisman . DEFENDANT. . . . , ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . . . 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. ...,.,/.7 .~. 7) J / . . , . A~ An""/} 4 ---r~h ~ P,OT'ONOT^"' J. . .t' ...... . ..tt. ..... .~~.....t...................... . . . . . SHERRY LEE EIIRISMAN. PlaintifT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO 98 - 526 CIVIL TERM TIMOTHY JOHN EHRISMAN, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECOR!) TO THE PROTHONOTARY: Trnnsmit the record, together with the following information to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under &330J(e) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted deliverv. return receipt reauested. delivered on: February 4, 1998. 3. Date of execution of the affidavit of consent required by 3301(e) of the Divorce Code: By PlaintifT: March 28, 2000 By Defendant: October 4, 2003 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in *3301(c) Divorce was filed with the Prothonotary: October 7,2003. *3301(c) Divorce was filed with the Date: 16. I L( a 3 Ja e Adams, Esquire I.D No. 79465 3 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney lor Plaintiff //;11 5-:1 >- ,.... ?:= a; "".1 ('; 1-" ...:: l1JQ 9 :.0""<1:: ~I~:_j ~')7 ll~ oj .'- ".' ::( '.I.f "'" '1),', ::.?~ C}!I.. In Wf\. '''J~ f1! ~c; 1- ':c. ;$; if ., c.~ "llil r:.:; c::: S)u.. IJ. ") ...~ Q ::-.1 0 U \1 n -. l'~\wll~l\rmm\ctlli'inllln.di\' file N~.lfl.lj.'J7.OI .1111111111)' 12,JIJ'jH SHERRY LEE EHRISMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE Plaintiff VB. TIMOTHY JOHN EHRISMAN, NO. 98 - !Cl. {, CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE SHERRY LEE EHRISMAN, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C., respectfully represents: 1. The Plaintiff is Sherry Lee Ehrlsman, who currently resides at 233 Richland Road, Carlisle, Cumberland County, Pennsylvania, where she has resided since November, 1995. 2. The Defendant is Timothy John Ehrisman, who currently resides at R. R. 1, Box 197, I , I McAlisterville, Juniata County, Pennsylvania, where he has resided since at least 1987. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 20, 1994, at Juniata County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. J , , , I I , l I' .~ <:\wl'$l\nllm\ehtl'n,.n.~iv file '~.IM.')7-II1 lilnuillY 1l,1'1;H 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate In marriage counseling, and does not request counseling. 8. Plaintiff requests the Court to enter a decree of divorce. FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: .'-' O)~ J/)III/V~J- Roger M/ Morgenthal, Esquire ID # 17143 11 East High Street Carlisle, PA 17013 (717) 243-5513 Date: ~ I 5 I (c; ~ if 2 I ~ l':\WI1.~I\rmm\ehtiln1un.lJlv file N:IW..~.IJ1.f11 .Il1nUIlJ)' 12,(l)'JH VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. e.s. ~ 4904, relating to unsworn falsification to authorities. /1 de I' . .lJd~ c:- " t:iElx//k.dA..J Sh Lee Ehrisman Date: 1-?.1-'1:r t l, r I":',.' .'" / I'., L 3 J ~ e, s ~ <,,; . .., r-.Vl ~ ..... ... " ;ff ~ (8" '.. ~:; C' 1I1_,; C:.2l (1..;- "--..' C' , 1'1.:' Cl'.. Lql.' ELL' . r~; II.~ C, t.." -.l (n ~ c-., ::; 1'1 -S~ r-, t", r:- ~~] .".; .:. cr, ".) ., " ".' ;J(j ~i~U. , O'J G' ';:' u ".;- ,,' ", .': , :',~?~.a . ,- '':o~ ..~ :;'J ;.t",.. 'In ".\4 ~.b(u '1~(),.. -,. ? u ..... 0"'. .... ~;:, ,j' ., 'c'")..;...., ,,-<:. v--, ~l:)\~.. <0 6(.1' u.l(.o. ~\.tJ lJ._ J.., '-' ,.... o C:l :'C .C>-. r-- , t; c::> c'"l o '1;117 9J " file #5465.97-01 VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98.526 CIVIL TERM IN DIVORCE SHERRY LEE EHRISMAN, Plaintiff TIMOTHY JOHN EHRISMAN, Defendant AFFIDAVIT OF CONSENT 1. A Complaint In Divorce under ~ 3301(c) of the Divorce Code was filed on January 29, 199B. 2. The marriage of plaintiff and defendanlls Irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree In Divorce after service of notice of Intention to request entry of the Decree. I verify that tho statements made in this Affidavit are true and correct to the best of my knowledge. Information and belief. I understand that false statements herein are made subject to the penalties of 1 B Pa.C.S. 4904 relating to unsworn falsification to"authorities. ! / /) 'J' . " ,/ ''''}(' ; , /", ~ ' .'.' '\,,/ .,It:,f.:(I,". (,('(\,;//;i'{):A..../ 1 Sherry Lee Ehrlsman, Plaintiff " Date: fl'/Mc[, ?.f. 2000 , 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 of 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 Ills filed with the Prothonotary. I verify that the statements made In this Affidavit are true and correct to the best of my knowledge. information and belief. I understand that false statements herein are made subJect to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. \",~:.I. //: /~~1. \' ) V 'Ijl'.r ,II 1. / /r~ cl./ IlI';( I U , sherryJee Ehrisman, Plaintiff ~~s~ IJ ,- ) ~- t~-; L:.;': ;;;~ ~:';~ , 'i .< , , ~.~, ..~.. ...." .. t- .- Z-."! , , ::li : (-J i:n c- .. ',,~.: ..... , ~~ ~,.~ . , ,n'., J --' ~) SHERRY LEE EHRISMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION. DIVORCE~" .-, " ,'J. ., , ~. NO. 98 - 526 CIVIL TE~M ,.-J TIMOTHY JOHN EHRISMAN, ','"\ . .' ":?;l ,.1 , , \ Defendant IN DIVORCE . , I.:.... , . " ,; ).':" '.il ~,' ..< CERTIFICATE OF SERVICE ,} t; day of h [m,;{/U/_, L MORGENTHAL, Esquire, of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C" AND now, this , 1998, I, ROGER M. Attorneys, hereby certify that I served the Defendant, Timothy John Ehrisman, on February 4, 1998, with the Complaint for Divorce by Certified Mail, Return Receipt Requested, Restricted Delivery, Addressee Only, addressed to: Mr. Timothy John Ehrisman R. R. 1, Box 197 McAlisterville, PA 17049 and proof thereof, the signed Return Receipt Card, is attached hereto. FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys for PlaIntiff By Roger M.' orgenthal, Esquire ID # 17143 11 East High Street Carlisle, PA 17013 (717) 243-5513 ;': I ' ~, I I' : , t: , , I I, i ) t 1 ., ! .tf !, i I I , , I i I ", I I I I. ~ .~ ,- I,' I ,Il , , i I j , . l r .. q. 'I.' ,. ~ ' :,'j !l' I I. , ' ,. , i, .1 SHERRY LEE EHRISMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V5. CIVIL ACTION - DIVORCE NO. 98 - 526 CIVIL TERM TIMOTHY JOHN EHRISMAN, Defendant IN DIVORCE PROOF OF SERVICE i eeomp"llt;nw 1 andIOf 2 lor additional Mme... .. 'Competelt.ms 3. "., and "b. I .Ptlnt your name and add,.... on tM "VI,.. ollNt form 10 thai we can retum thl. card t. you. 'Attach thl, form to the front of the malrplece, or on the bad( If tpace dot. not p.,mlt. t: 'Wrt!.-R.tum R<<>>Ipt Requnted"on the mallplece below the erUd. number. 'Ii IThe Rltum Receipt wiD Ihow 10 whom the 8I11cl, WI' delivered and the datI Ii dIllvorld. I 3. Article Addressed to: Mr. Tinothy John Ehrisman R. R. 1, Box 197 MclUisterville, PA 17049 i J XI Certified I o Insured f sa 0 COD ~ .0 ! ! l [' if c:\wp~l~rmm\eli~sman.div file #5465-97-01 January 13,1998 SHERRY LEE EHRISMAN, VS. TIMOTHY JOHN EHRISMAN, Plaintiff : .- ., .. Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 98 - ~J-/-- CIVIL TERM IN DIVORCE NOTICE 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, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 ASSOCIA'rlON 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Plaintiff Date: By.' Roger M. Morgenthal, Esquire ID # 17143 11 East High Street Carlisle, PA 17013 (717) 243-5513 c:\wp51\rmm\ehrisman.div file #5465-97-01 January 12,1998 SHERRY LEE EHRISMAN, VS. TIMOTHY JOHN EHRISMAN, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 98- ~'~-/-,, CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCF SHERRY LEE EHRISMAN, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C., respectfully represents: 1. The Plaintiff is Sherry Lee Ehrisman, who currently resides at 233 Richland Road, Carlisle, Cumberland County, Pennsylvania, where she has resided since November, 1995. 2. The Defendant is Timothy John Ehrisman, who currently resides at R. R. 1, Box 197, McAlisterville, Juniata County, Pennsylvania, where he has resided since at least 1987. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to 'Ihe filing of this Complaint. 4. The Plaintiff and Defendant were married on May 20, 1994, at Juniata County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. e:\wpSl\~nm\ehfisman.div file #5465-97-0~ Janua~ 12,19~8 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. 8. Plaintiff requests the Court to enter a decree of divorce. FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Plair3tiff By: Roger M.' Morgenthal, Esquire ID # 17143 11 East High Street Carlisle, PA 17013 (717) 243-5513 c:\wp51¥mm\ehfisman.div file #5465-974}1 Janua~ 12,1998 · · VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. Lee Ehrisman Date: SHERRY LEE EHRISMAN, VS. TIMOTHY JOHN EHRISMAN, CERTIFICATE OF SERVICF ~ -- ~ AND now, this ~ ~ day of ['~.r.~.¢¢~ 1998, I, ROGER M. MORGENTHAL, Esquire, of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C., Attorneys, hereby certify that I served the Defendant, Timothy John Ehrisman, on February 4, 1998, with the Complaint for Divorce by Certified Mail, Return Receipt Requested, Restricted Delivery, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNT~, PENNSYLVANIA : CIVIL ACTION - DIVORCE~ : NO. 98- 526 ~IVlL TE~ Defendant : IN DIVORCE Addressee Only, addressed to: Mr. Timothy John Ehrisman R. R. 1, Box 197 McAlisterville, PA 17049 and proof thereof, the signed Return Receipt Card, is attached hereto. FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys for Plaintiff By g . g hal, Esquire ID # 17143 11 East High Street Carlisle, PA 17013 (717) ;!43-5513 SHERRY LEE EHRISMAN, VS. TIMOTHY JOHN EHRISMAN, Pla ntiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - DIVORCE NO. 98- 526 CIVIL TERM IN DIVORCE PROOF OF SERVICE file #5465-97-01 SHERRY LEE EHRISMAN, Plaintiff VS. TIMOTHY JOHN EHRISMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98.526 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 29, 1998. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to.,,authorities. · ,:/'Sherry Lee Ehrisman, Plaintiff Date: WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §33011c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning allimony, 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ' Sherry~.C'ee Ehrisman, P~aintiff SHERRY LEE EHRISMAN, Plaintiff V. TIMOTHY JOHN EHRISMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO 98 - 526 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 29, 1998. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed fi.om the date of the 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 also understand that false statements herein are made Subject to the penalties of 18 Pa.C.S. 4904, relatirtg to unswom falsification to authorities. Timothy JolffFEhrisman, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER .~3301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 consent to ento, ora final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ill 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. 1 understand that false statements herein are made subject to th* penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date:/O "/-/~ O'"~ Timothy Joh~ Ehrisman, Defendant SHERRY LEE EHRISMAN, Plaintiff V. TIMOTHY JOHN EHRISMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO 98 - 526 CIVIL TERM : : IN DIVORCE PRAECIPE TO TRANSMIT RECORn · 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 ~301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified maik restricted deliver~, retuln receipt requested, delivered on: February 4, 1998. 3. Date of execution of the affidavit ofconsem required by 3301(c) of the Divorce Code: By Plaintiff: March 28,2000 By Defendant: October 4, 2003 4. Related claims pending:.None 5. Date D efendant s Waiver of Not~ce in §3301(c) Divorce was filed with the Prothonotary: October 7, 2003. Date Plainti~] Waiver §3301 (c) Divorce was filed with the Prothonotary: q !"~,t-~'!(~:~) of Noticein , Esquire 65 eet 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOIJNTY STATE OF PENNA. SHERRY LEE EHRISMAN, Plaintiff VERSUS TIMOTHY JOHN ~HRISMAN, Defendant N o. 98 - 526 Civil AND NOW, DECREED THAT AND DECREE IN DIVORCE Sherry Lee Ehrisman Timothy John Ehrisman ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , 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 o BY TH C IrT: ATTEST: j. P OTHONOTAR