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HomeMy WebLinkAbout03-2010ROBERT E. YEAGER, Plaintiff Vo THERESA LYNN YEAGER, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO. - O,O tO 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, High and Hanover Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ROBERT E. YEAGER, Plaintiff Vo THERESA LYNN YEAGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. - CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) _OF THE DIVORCE CODE o o o Plaintiff is Robert E. Yeager, who currently resides at 1111 Yverdon Dr. Apt A-3 Camp Hill, PA, Cumberland County and has lived in Pennsylvania since birth. Defendant is Theresa Lynn Yeager, who currently resides at 155 Salem Church Rd. Lot #17, Mechanicsburg, PA, Cumberland County, and moved to Pennsylvania as an infant. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. The parties were married on November 16, 2002, in Mechanicsburg, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: Respectfully submitted, ROMINGER & BAYLEY Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court ID # 81924 (717) 241-6070 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. Date: Rob~ager, Plaint-iff ROBERT E. YEAGER, Plaintiff THERESA LYNN YEAGER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO: 03-2010 : : IN DIVORCE AFFIDAVIT OF CONSENY I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 29, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. § 4904, relating to unswom falsification to authorities. Date: Robert/F~: r/Plaintiff ROBERT E. YEAGER, Plaintiff V. THERESA LYNN YEAGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW · NO: 03-2010 : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 29, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. § 4904, relating to unsworn falsification to authorities. Date: eresa Lynn Yeager/Defendant ROBERT E. YEAGER, Plaintiff THERESA LYNN YEAGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO: 03-2010 : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER {} 3301(0 OF TIlE 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 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 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !i4904, relating to unswom falsification to authorities. Date: Plaintiff ROBERT E. YEAGER, Plaintiff V. THERESA LYNN YEAGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW · NO: 03-2010 · IN DIVORCE 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 it ds 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. §4904, relating to unsworn falsification to authorities. Date: · Complete items 1,2, and 3. Also complete ~ 4 if Restricted Detivery is desired. · Pdnt your name and addre~s on the reverse so that we can return the can:l to you. · Attach this card to the back of the mailpiece, or on the f~ont if space permits. Return Receipt for Mercham:~t~e ROBERT E. YEAGER, Plaintiff THERESA LYNN YEAGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO: 03-2010 : : 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: 1. Grounds for divome: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified May 3, 2003. 3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce Code: by the Plaintiff November 10, 2003; by the Defendant November 12, 2003. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 14, 2003. Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: November 14, 2003. ,2003 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Cot~ ID No. 81924 IN THE COURT OF STATE OF Robert E. Yeager Plaintiff VERSUS Theresa L. Yeager Defendant COIVI MON OF CUMBERLAND COUNTY ~ ~ ~ PENNA. PLEAS O03-2010 Civil Law DECREE IN DIVORCE DECREED THAT Roh~_rf F,. V~gpT , PLAINTIFF, AND Theresa L. Yeaqer , 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 f~~~~ROTHON OTARY