HomeMy WebLinkAbout03-1653
LESTER L. NEWHOUSE, II,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 0:3 -I ~S..3
Civil Term
LINDA P. NEWHOUSE,
Defendant
: ACTION 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.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MA Y LOSE THE RIGHT TO CLAIM 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
LESTER L. NEWHOUSE, II,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 1(, S':J
Civil Term
LINDA P. NEWHOUSE,
Defendant
ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Lester L. Newhouse, II, a competent adult individual, who has resided at
164 E. Penn St., Carlisle, Cumberland County, Pennsylvania, since 1999.
2. Defendant is Linda P. Newhouse, a competent adult individual, who has resided at 164
E. Penn St., Carlisle, Cumberland County, Pennsylvania, since 1999.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant'were married on October 11,2001 in Mount Holly,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. 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.
7. Plaintiff and Defendant have no children together.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member ofthe Armed Forces of the United States
of any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
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. S4904 relating to unsworn
falsification to authorities.
~Jf=-
ewhouse, II, Plaintiff
Respectfully submitted,
Date: V, (0 (03
e Adams, Esquire
I. . No. 79465
6 South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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LESTER L. NEWHOUSE, II, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 03 - 1653 Civil Term
LINDA P. NEWHOUSE, : ACTION IN DIVORCE
Defendant
AFFIDAVIT OF SERVICE
AND NOW, this April 21 ,2003, I, Jane Adams, Esquire, hereby certify that
on April 18, 2003, a certified true copy of the NOTICE TO DEFEND and COMPLAINT
IN DIVORCE were served, via certified mail, return receipt requested, addressed to:
Linda P. Newhouse
164 E. Penn St.
Carlisle, Pa. 17013
DEFENDANT
Respectfully Submitted:
Adams, Esquire
. No. 79465
South Pitt Street
arlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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. 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.
. Attacl'Ythis card to the back of the mailpiece,
or on the front if space permits.
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2. Article Number
(Transfer from seNiee label)
PS Form 3811, August 2001
COMPLETE THIS SECTION ON DELIVERY
D Agent
D Addressee
B. Received by ( Printed Name) C. Date oJ Delivery
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D. Is delivery add'ess different from item 1?
If YES, enter delivery address below:
3. Service Type
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D Insured Mail
D Express Mail
D Return Receipt for Merchandise
DC.a.D.
4. Restricted Delivery? (Extra F~
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Domestic Return Receipt
102595-02-M-0835
UNITED STATES POSTAL SERVICE
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First-Class Mail
Postage 8; Fees Paid
USPS
Permit No. G-10
. Sender: Please print your name, address, and ZIP+4 in this box ·
JANE ADAMS
ATTORNEY AT LAW
36 S. PITT STREET
CARLISLE. PA 17013
LESTER L. NEWHOUSE, II,
Plaintiff
IN THE COURT OF COMMON PLE S
CUMBERLAND COUNTY, PENNS LV ANIA
vs.
No. 03 - 1653 Civil Term
LINDA P. NEWHOUSE,
Defendant
ACTION IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this Affidavit, you m st file a counter-
affidavit within twenty days after this affidavit has been served on you or the statements will be
admitted.
AFFIDAVIT OF SEP ARA TION
1. The parties to this action separated in April 2, 2003 and have conti ued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose my rights concerning alimony, divisio of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
I verifY that the statements made in this affidavit are true and correct. understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 elating to unsworn
falsification to authorities.
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Datet1 - J -6..)
Lester L. Newhouse, II, Plaintiff
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LESTER L. NEWHOUSE, II,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 1653 Civil Term
LINDA P. NEWHOUSE,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this May 3, 2005, I, Jane Adams, Esquire, hereby certify that
on April 11, 2005, a certified true copy of the NOTICE OF INTENT TO REQUEST ENTRY OF
DIVORCE DECREE and COUNTER-AFFIDAVIT were served, via certified mail, restricted
delivery, return receipt reouested. addressedto:
Linda Newhouse
164 E. Penn S1.
Carlisle, Pa. 17013
DEFENDANT
SLf\jC;l" '~'-J'" L1 'L. ~L ~ ,
. Complete ~ems 1, 2, and 3. Also complete
~em 4 W Restricted D<lflvery Is deSrred.
. Print YOlJr name and address on the reverse
so that we can retum the card to you.
. Attach this~ 10 the back of the mallplece, .
or on the front W space pennils.
1. Article AddresaJd to:
t:lAgent
Addressee
c. OateofDe~
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D. Is delivery add.... dlllerent!rom ~em 11 t:l Yes
If YES, enter dellvely address below: t:l No
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Cl1-C'-~,de 'PA 170)3
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3. Service Typa
~ C81t1fled Mall t:l Exp.... Mall
[] Reg_ [] Return ReceIpt far Mito"'''_
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PS Form 3811, Februery 2004
7003 3110 0004 5775 4528
DomestlC Aatum Receipt
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102sss-02-M-1540 i
Jan Adams, Esquire
I. . No. 79465
64 South Pitt Street
Carlisle, Pa. 17013
(7\7) 245-8508
ATTORNEY FOR PLAINTIFF
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LESTER 1. NEWHOUSE, II,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 1653 Civil Term
LINDA P. NEWHOUSE,
Defendant
ACTION IN DIVORCE
NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE
TO:
Linda P. Newhouse
164 E. Penn St.
Carlisle. Pa. 17013
DATE:
April 8. 2005
You have been sued in an action for divorce. You have failed to answer the Complaint or
file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after April 28. 2005,
the Plaintiff can request the Court to enter a final decree in divorce.
. If you do not file with the Prothonotary of the Court an answer with your signature
il notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree
in Divorce. Unless you have already filed with the Court a written claim for economic relief, you
must do so by the above date or the Court may grant the divorce and you lose forever the right to
ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE
PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE.
I
I Unless you have already filed with the court a written claim for economic relief, you must
. do so by the above date or the court may grant the divorce and you will lose forever the right to
ask for economic relief. The filing of your counter-affidavit alone does not protect your
economic claims.
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
32 South Bedford St.
Carlisle, Pa. 17013
(717) 249-3166
,
~ .
.
LESTER L. NEWHOUSE, II,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 1653 Civil Term
LINDA P. NEWHOUSE,
Defendant
ACTION IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 330Hd) of the DIVORCE CODE
1. Check either (a) or (b):
_(a) I do not oppose the entry of a divorce decree.
_(b) I oppose the entry ofa divorce decree because:
(Check (i),(ii), or both:)
_(i) The parties to this action have not lived separate and apart for a period
of at least two years.
_(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
! _(a) I do not wish to make any claims for economic relief. I understand that I may lose
rights concerning alimony, division of property, lawyer's fees, and expenses if! do not claim
them before a divorce is granted.
_(b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees, or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my economic
claims with the Prothonotary in writing and serve them on the other party. If! fail to do so
before the date set forth on the Notice of!ntention to Request Divorce Decree, the divorce decree
may be entered without further notice to me, and I shall be unable thereafter to file any economic
claims.
I verifY that the statements made in this counter-affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904
relating to unsworn falsification to authorities.
Date:
Linda P. Newhouse, Defendant
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish
to make a claim for economic relief, you need not file the counter-affidavit.
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LESTER L. NEWHOUSE, II,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 03 - 1653 Civil Term
LINDA P. NEWHOUSE,
Defendant
ACTION 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:
L Ground for divorce: irretrievable breakdown under &330Hd) of the Divorce Code.
2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted-
deliverv. Delivered on: April 18. 2003.
3. Date of execution of the affidavit required by ~3301(d) of the Divorce Code:
By Plaintiff: April 2, 2005.
Date of filing and service of the plaintiff's affidavit of separation
required by ~3301(d) of the Divorce Code on respondent:
Filed: AprilS. 2005.
Served on Defendant: April II. 2005.
Affidavit of Service filed: Mav 4. 2005.
4. Related claims pending: No claims raised.
5. Date and manner of service of the notice of intention to file praecipe to transmit record, a
copy of which was filed of record with the Prothonotary: Notice of intention was forwarded to Defendant
via certified mail. on Avril II. 2005.
Date' :%/0 5
dams, Esquire
I.D. o. 79465
. Pitt St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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IN THE COURT OF COMMON
PLEAS
OFCUMBERLANDCOUNTY
Lester L. Newhouse, II, Plaintiff
PENNA.
STATE OF
No. 03 - 1653
Civil Term
No.
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VERSUS
Linda P. Newhouse, Defendant
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DECREE IN
DIVORCE
AND NOW,
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. 2!'dd-'> , IT IS ORDERED AND
Lester L. Newhouse
DECREED THAT
, PLAINTIFF,
Linda P. Newhouse
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AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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.
/J.
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