HomeMy WebLinkAbout98-06359
~
.u
,
~
'-
~
~
~
u
.... ,
~
t.
'...
u
~
t
~
r
-
"
.'J
,
~i
~!
~!
~i
~I
!
. I
a...;
~'
.1
~\
GORDON R, DEITERICK, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
VS, ) CIVIL ACTION - LAW
)
) NO, fip "..tr?CIVIL TERM
LAUREEN K, DEITERICK, )
Defendant ) 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 foregoing 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 in 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:
Office of the Prothonotary
1 Courthouse Square
Cumberland County Court House
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, OIVISION 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
ii
Ii GORDON R, DEITERICK,
'I Plaintiff
Ii
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
LAUREEN K, DEITERICK,
Defendant
CIVIL ACTION - LAW
NO, 9r..t-l$?
CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce
proceeding filed in the Court of Common Pleas of Cumberland County, This notice is
to advise you that in accordance with Section 3302(d) of the Divorce Code, you may
request that the court require you and your spouse to attend marriage counseling
prior to a divorce being handed down by the court. A list of professional marriage
counselors is available at the Oomestic Relations Office, 13 North Hanover Street,
Carlisle, Pennsylvania, You are advised that this list is kept as a convenience to you
and you are not bound to choose a counselor from this list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your
spouse,
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling,
II
"
.'
'...
-
i.
Ii
i'
i!
if
;j
,
,
.
I
I
! GORDON R, DEITERICK,
Ii Plaintiff
V5.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
LAUREEN K, DEITERICK,
Defendant
NO, 'i; (. '1 "'1
CIVIL TERM
IN DIVORCE
COMPLAINT IN D.nlQ,BCE
AND NOW comes the above-named Plaintiff, GORDON R, DEITERICK, by his
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff Is GORDON R, DEITERICK, an adult individual who currently
resides at 125 Westover Drive in New CUlnberland, Cumberland County,
Pennsylvania.
2, The Defendant is LAUREEN K, DEITERICK, an adult individual who
currently resides at 125 Westover Drive in New Cumberland, Cumberland County,
Pennsylvania,
3, Both the Plaintiff and Defendant have been bona fide residents of 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 April 3D, 1989 in Camp Hill,
Pennsylvania,
5, There have been no prior actions of divorce or annulment between the
parties,
6, This marriage is irretrievably broken,
GORDON R, DEITERICK,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLANO
COUNTY, PENNSYLVANIA
vs,
CIVIL ACTION. LAW
LAUREEN K, DEITERICK,
Defendant
NO, 98.6359 CIVIL TERM
IN OIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce in this action,
"
"
'.
Ii
)i
"
!.
II
~~,., ~QQJ
Sa . L, Ande l5 :+ I'\~
A ttorney for Plaintiff 1 0<.
Supreme Court 10 17225
525 North 12'h Street
Lemoyne, PA 17043
(717) 761-5361
"
'.
!i
Ii
"
Ii
Ii
I!
I
,
,
I
I
I
,
i
,
II
I.
'I
I
,
I
I
I
II
II
_.. ..,,___,~,~---_'::J.i('-A;"'~;:;'H;~.~>~_~ ;i\
n ...r, -,
~; '-) " ,
- :':::J .:J
'"U,-.: :-) .'i;n
ClJq -<
"'- .'., "~I
-::-0, ,~ ..:.'
(n... co -. .
-<4_ :."_: ~;~
!~L ;:,. ..'-n
~CI ::;.: ~~! ~.')
:tD '2 ;.)i:'1
'c .:.:,
~ '" ~.
:iJ
r" -<
t.
I "..
. '.'
" /
f 'ip
I'
I
"i
"
,
r
'-....'
, ~
~'-l
,"'
I
,
I
\
I
i
I
,
,
'-"'\
lj1i
. I
"
.
SliER I FF' S IWTtJlm . OUT OF COUNTY
C^S~: NO: 1998-063S9 I'
CO~jj.iONWEAL TH OF PE~~j'~~;YI.,V l',j';; /..,:
COUNTY OF CUMBERLi\ND
Q.r:;rTEI,l}CK GC?~DO!i-.J'u______,__..
VS,
DEITERICK LAtJl<EEN K
R. Thomas Kline , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: DEITERICK LAUREEN K
but was unable to locate
Her
in his bailil>'ick, lie therefore
deputized the sherif f of DAUPHIN County, Pennsylvania,
to serve the within REINST-COMPLAINT/AVAIL COUNSEL
On November 4th, 1999
the attached return from
this office was in receipt of
DAUPHIN County, Pennsylvania,
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Dauphin Co
18,00
9.00
8.00
29,25
~bq.~~ SAMUEL L, ANDES
11/04/1999
So :::;'7IS;/ ~
' }f!/J:W'.v< ~
~~omas Kllne, erlrf
Sworn and subscribed to before me
this 9 CG day of Itflu, ~
19 91 A,D,
~ C, 7?~ W,aLr r
.l:-'roc.honoc.ary I
,.I;;
."
.~ 0
,
t\,j
c;: f.'
U...",,'f'r',j~. C.,:Ht; I
','IEklff'5 uf fleE
.I'i'rct. (UI.'~H (C,III-I-l.:'"
.1.';,;;,,1:':);:( " :"::i'
RECEIVlU
, ~
~
'....
.
GORDON R, DEITERICK,
Plaintiff
IN TI IE COURT OF COMMON PLEAS
('UMBERLAND ('OUNTY, PENNSYLVANIA
v,
NO, 98-6359
LAUREEN K, DE IT ERICK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COUNTER-AFFIDA VIT UNDER li 330Hd) OF THE DIVORCE CODE
I, Check either (a) or (b):
CI (a) I do not oppose tbe entry of a divorce decree,
''Fi (b) I oppose Ihe entry of a divorce decree because:
/' t3( (i) The parlies to this action have not lived separate and apart for a
period of atleasttwo(iye;rs,
CI (ii) The marriage is not irretrievably broken,
2, CI (a) I do nOI 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 be~ore divorce is grallled.
(b) I wisb to claim economic relief wbich may include alimony, division of
property, law er's fees or expenses or other important righls.
I understand that in addition to checking (b) above. I must also file all of my economic claims
with Ihe Prothonotary in writing and serve them on the other palty, If I fail to do so before the date set
forlh on Ihe Notice of Intention 10 Request a Divorce Decree, the divorce deeree may be enlered
without further notice to me, and I shall be unable thereafter 10 file any economic claims delay,
I verify that Ihe statements made in this counter-affidavit are true and correct. I understand that
false statements herein are made subject to Ihe penalties of 18 Pa,C,S, ~ 4904 relating to unsworn
falsification to authorities.
Dated: 1/-15'J2U~
~tvlLb, I' /J),)juwk
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 RELlEF, YOU SHOULD
NOT FILE THIS COUNTER-AFFlDA VIT.
Doc/lII/elll #: /8985i,/
.
n:IHI F/CATE OF SU~vln:
/1,
AND NOW, lhis /(0 day of November, 2lKKl, I. Meliss.. I.. Slickel, Esquire, of Melzger,
Wickersham. Knauss & Erh, P.C.. :Illorney.s lilr I...ureen K, lJeileriek, herehy cenify ilia I I served a
copy of lhe within Coul1ler-Mlid..vil Under 3301(d) lhis d..y by deposiling lhe '..me ill Ihe Uniled
Slales mail, pOSl:'ge prep..id, :ulI..rrishurg, Pennsylv:mia, addressed 10:
Samuel L. Andes, Esquire
525 Nonh Twelfth Slreel
1',0, Box 168
Lemoyne, PA 17043
Respeclfully submilled,
METZGER. WICKERSHAM, KNAUSS & ERB, P,C,
By:
Melissa L. Slickel. Esquire
Allorney ID No,: 85869
321 I Norlh Front Slreel
1',0, Box 5300
Harrisburg, PA 17110
(717) 238-8187
Attorneys for Defendant
/JOCllml!1II #: 18985 i.1
'...
CEIU'IFICATI; OF SERVICE
AND NOW, this 1St" day of Novcmbcr, 2(XJO, I. Mclissa 1.. Sliekcl, Esquire, of MClzgcr,
Wickcrsham, Knauss & Erb, P.C.. aUorneys for Laurccn K. Dcilcrick, hercby ccnify Ihat I scrved a
copy of thc wilhin Praecipc this day by dcpositing Ihc samc in Ihc Uniled Slatcs mail, poslagc prcpaid,
at Harrisburg, Pennsylvania, addrcsscd 10:
Arlhur K. Oils, Esquire
1017 Norlh Front Street
Harrisburg,PA 17102
Samuel L. Andes, Esquirc
525 North Twclflh Strcct
1',0, Box 168
Lemoync,PA 17043
Respectfully submitted,
METZGER, WICKERSHAM, KNAUSS & ERB, P,C,
By:
VWi()IJJ rI Jtfihl
Melissa L. Stickel, Esquire
Attorney ID No,: 85869
3211 North Front Street
P,O, Box 5300
Harrisburg, PA 17110
(7 I 7) 238.8 I 87
Attorneys for Defendant
Document #: /89lf(Jl./
"'
[
II
!i
['
.'
Ji
"
d
GORDON R, DEITERICK,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLANO
COUNTY, PENNSYLVANIA
:1
i!
II
.:
Ii
:!
q
Ii
Ii
'1
I.
Ii
II
II
II
!I
I
vs,
CIVIL ACTION. LAW
NO. ga.6359 CIVIL TERM
LAUREEN K, DEITERICK,
Defendant
IN DIVORCE
AFFIDAVIT" OF SERVICE BY _CERTIFIED_MAIL
AMY M, HARKINS, being duly sworn according to law. deposes and says as follows:
1, That she is an employee of Samuel L, Andes, attorney for the Plaintiff herein,
2, That on 3 November 2000, she delivered to the U.S, Postal Service in Lemoyne,
Pennsylvania, as certified mail (Receipt No,7099 3400 0006 0356 2875) return receipt
requested, addressed to the Oefendant herein, a true and correct copy of the Affidavit of
Consent and Waiver of Notice.
3, Said return receipt card is attached hereto as Exhibit A showing a date of
delivery to the Defendant on 4 November 2000,
~'~R~Luw
Sworn to and subscribed
before me this 2 I 5<- day
of NOI/EtI1D~ , 2000,
10;/.- au~,jdL
NotaryPublic,
I,
NOIARlAl SEAL
lE~NovENHRENFElO, NOrARY PUBLIC
E BORO., CUMBERLAND CO
MY COMMISSION EXPIRES AUG. J7, 2004
-....;.......
L
i
!J
;:
I'
I!
vs,
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
GORDON R. DEITERlCK,
Plaintiff
'I
!,
,
!,
'1
;!
II
I
I
!
CIVIL ACTION - LAW
NO, 98-6359 CIVIL TERM
LAUREEN K. DEITERlCK,
Defendant
IN DIVORCE
PLAINTIFF'S OBJECTION TO DEFENDANT'S INTERROGATORIES
I
\ objects to Defendant's Interrogatories in this matter for the following matters:
I 1. No economic claims have been raised in this case to date and, as a result, formal
\' discovery requesting financial information about the assets and incomes of the parties is not
permitted by the Rules of Court,
I 2, The Interrogatories exceed forty in number, including the primary questions and
sub-parts, in violation of the local Rules of Cumberland County which limit Interrogatories to
forty or less in number,
AND NOW comes the above-named Plaintiff, by his attorney, Samuel L, Andes. and
3, The Interrogatories are unnecessarily detailed and burdensome. For example,
Interrogatory 12 would require Plaintiff to (list all tangible personal property) he owns and
provide a description and estimated value of such value and Interrogatory 31 would require
Plaintiff to list separately various categories of tangible personal property and provide
elaborate and unnecessary information about them.
WHEREFORE, Plaintiff objects to the Interrogatories filed by Defendant in this matter
and asks this court to excuse him from answering the same,
--~~~
s2:( Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
Ii
Ii
"
"
,,{'
,
ii
I'
11
.'
Ii
i!
CERTIFICATE OF SERVICE
:j
"
II
'I
I hereby certify that I served an original of the foregoing Objection to
"
I'
, Defendant's Interrogatories upon counsel for the Defendant herein by regular mail,
postage prepaid, addressed as follows:
I'
II
II
Melissa L, Van Eck, Esquire
3211 North Front Street
P,O. Box 5300
Harrisburg, PA 17110-0300
il
II
II
I
Date:
I
,I
II
I
I
12 March 2002
s~
Attorney for Plaintiff