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Home My WebLink About01-1996 FX . ~ ROBERT GUY STEIGLER, PLAINTIFF : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. , : NO.OI-/99'-cML T~ : CML ACTION . LAW : ACTION FOR DIVORCE BEVERLY ANN STEIGLER, DEFENDANT 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the cOll)Jllaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIDS 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. Court Administrator Fourth Floor Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 --~t " ~"-" ~'""""'" , i .. ~. II 'f ,1-1 1- , - 4 ROBERT GUY STEIGLER, PLAINTIFF : IN THE COURT OlF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA VS. : NO.o/~/9'i'(, CML BEVERLY ANN STEIGLER, DEFENDANT : CML ACTION - LAW : ACTION FOR DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITIllN-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 Office of the Prothonotary, Cumberland County Courthouse, I Courthouse Square, 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. '-".""""!"f"!'lWJm~ I~l "1' . I .,,-- '1 ,- - ~~ ~~" ~." ".,~,"",l=< ROBERT GUY STEIGLER, PLAINTIFF : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. , : NO.6/-J99(, CIVIL BEVERLY ANN STEIGLER, DEFENDANT : CIVIL ACTION - LAW : ACTION FOR DIVORCE COMPLAINT FOR NO-FAULT DIVORCE UNDER SECTION 3301(S) OF THE nlVORCE CODE AND NOW, comes the Plaintiff, ROBERT GUY STEIGLER, by and through his counsel, Susan Kay Candiello, Esquire, and makes the following consolidated cOmplaint in divorce for divorce. 1. Plaintiff is ROBERT GUY STEIGLER, an adult individual, who currently resides at 773 South Humer Street, Enola, Cumberland County, Pennsylvania, 17025, and has resided in Cumberland County for over three (3) years. Previous to living in Cumberland County, the Plaintiff resided in York County for eleven (11) years. 2. Defendant is BEVERLY ANN STEIGLER, an adult individual, who currently resides at 733 South Humer Street, Enola, Cumberland County, Peunsylvania, 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully married on October 5, 1991. 5. There have been no prior actions of divorce or for annulment between the parties except this Complaint filed for divorce. 6. The marriage is irretrievably broken. (f.~~ _,," G n h +1" r r , .. ~"-, 7. Plaintiff has been advised of the availability of counseling and of the right to request that the court require the parties to participate in counseling. Plaintiff has chosen not to engage in, or to request any counseling. 8. Plaintiff was a member of the United States Military Services from June, 1959 through June, 1962; however, Plaintiff does not have any military benefits which are issues in this divorce. Defendant has never been a member of the United States Military Services. 9. Plaintiff and Defendant have no children from their marriage. COUNT I - REOUEST FOR NO-FAULT DIVORCE UNDER SECTION 33011c) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference thereto. 11. ~r ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to the divorce. Plaintiff believes Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date offIling of this Complaint, Plaintiff, ROBERT GUY STEIGLER, respectfully requests the court to enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. COUNT IT -REOUEST FOR EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(3) OF THE DIVORCE CODE 12. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference thereto. '''''''~~ T '''''''"'' . -I~~ I .,. '1 13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff, ROBERT GUY STEIGLER, respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. Respeclfully submitted, LAW FIRM OF SUSAN KAY CANDIELW, P.C. Dated: APril..!i.-, 2001 Susan Kay Can' 0 Esquire Counsel for Pl . ntiff PA l.D. # 6499 5021 East Trindle Road Suite 100 Mechanicsburg PA 17050 (717) 796-1930 .,~ ,,' I-l ~ "I , . /'~ '"'.'1 ) c;'~".jo. VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. DATED: ~Lf/~L .~4~ : ROBERT G STEIGLER r,,,",,, ~ "'~. l'I~~-"'1 II ~'e , , ~"" -~ -~ , -~..- ' ..,'~'.~ ,,< "-"~~, ~"-~,-~ . ",. "O~H .~ _"'~. "' . r- ~ (J ~ ~ ~ r";r ~ ~ ,~ ~ (j .. 1;~ c e, ~ '. ;;-~ 11, ~',,^,! . . , f#::. d , CJ ::-) () 8 a I 0 <I - I ~ I I .'("t ~ .. ~ ~ ~ '-I CV r'<, ~ -....] =:--1 - (';'j -c: -J r" ~'~.... G. :" "1,iIW~ 1~.,~:>g~C;ll~"...., d1.filfIilll:!?'II'" ,,,,,...'\'~ " '~ellJ!!"ll1l!!\~f"~'''~''1'!'''''''.'' oj"'! h~l" -r~W.J'H181"~~~j~ ''i''':"~';l:'''''''''i!i:'!''W!ffYl':t'_;~J,1I';ifi~~'jfll~)if",,;~,,!!.,.f . ROBERT GUY STEIGLER, PLAINTIFF : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : NO. 01-1996 CIVIL BEVERLY ANN STEIGLER, DEFENDANT : CIVIL ACTION . LAW : ACTION FOR DIVORCE AFF:I.DA VIT OF SERVICE CERJ'IEI]&D MAlL COMMONWEALTH OF PENN8YLV ANIA 88: COUNTY OF CUMBERLAND Be it known, that on the 1(0 day of ~ ' 2001, before me, the subscriber, a Notary Public, personally appeared SUSA~ CANDIELLO, who, being duly swom according to law, did depose and state as follows: 1. I am an attomey licensed to practice law in the Commonwealth of Pennsylvania. 2. I represent Robert Guy 8teigler, Plaintiff in the above-captioned matter. 3. On April 9, 2001, a true and correct copy of the Complaint for No-Fault Divorce Under Section 3301(c) of the Divorce Code, was deposited for delivery with the U.S. Postal Service in Mechanicsburg, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested, Article No. 7000 16700003 4925 (J776, and addressed to the Defendant, Beverly Ann Steigler, at 773 South Humer Street, Enola PA 17025. 4. The return receipt card signed by the Defendant, Beverly Steigler, showing a date of service of April 11, 2001, is attached hereto as Exhibit "A". ~ I 1- ':f-.~-~ I, 1', i 5. Service by certified mail meets the requirements of Pa.R.C.P. 404(2) and Pa.R.C.P. 403. SWORN TO AND SUBSCRIBED before me, a Notary Public, this /'l-*' day of ~ , 2001. r..l.~ ~\)b ,-, ~ .I..k"" h-tA N;;-~ Publi~ ,'"'-'-' '\jl\UL-o\ My Commission Expires: Notarial Seal Kimberty A. Hanford, Notary Public MeoI1anlceburg Bora, Cumbertand County My CommIssion expires Apr. 4, 2005 """,",,<;J'~"""""'I~~,""'."~ ,..".." , -, :-~ 1-1- 1-' 'I I I , . . ~" ,....n {.., .... .4'- -:..'" . . e~lete _1, 2, endS, 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 mail piece, X or on the front if space permits. 1. Art1cle Addressed to: D. ~'\'3 A\\~ S~\tk\ '1'l"'3 SoLc\\\ tt\.l..~6 S{-r:ec..t ~l<l. ffll'16 ~5 RESTRICTED DELIVERY 3. Service Type ~erti1ied Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. . 4. Restricted Delivery? (Extra Fee) . . , "ilfes 2., AtIi..,.'C.leN. u.m. b.er(COP.~,,::~_serVl.'ce/ab~. '~.' . ~ '. i "i(>fl~h P&~@m1 3811 , July 1999 Dcmestic Return Receipt .; .: ;1: 102595-99-M-1-789 + EXInBIT "A" , " ~ I' f -~ ." r . lY' ~ I ',~ ~ '~~"~"~"""="",c-,,(,, rr n~_~'!IIlIiIi," ....',-.,. ,'~ ' ',., -,.i,," , f,.' .' .' "" ."",,,,, -'", "'" ,,,,"'^". ,"','?",~"'A__<-<_' " ~ ~I~"'''''~~W ~ . 1-- o ~; ~f1f ~? ~~, r~'~c~ ~~~ C) ~:-::r', J~. ('.: ~ J () ~.t: -,!, ". ~e~ 1::- 0') _~,~, ~~1ill ._~~';;;:,,*,''-'''''!il'l(G.''~';'j,,;;I'.,,' "~,,._<,:,,<, "C'";'-1!'~'r'!'-"~rf'\iJ':l!'l~!!),~!p~':r)j;;W;l#llili'~~~"!Mff!W~~~{~~