HomeMy WebLinkAbout03-2156
II
HENRY W. STRONG,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
JAN SUSAN NILSEN-STRONG,
Defendant
NO. 03- ~ /5<C
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
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
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
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
II
HENRY W. STRONG,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 03';U%
JAN SUSAN NILSEN-STRONG,
Defendant
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
Domestic 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
HENRY W. STRONG,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY , PENNSYLVANIA
vs.
CIVil ACTION - lAW
-
NO. oj -2. I~") 6
JAN SUSAN NilSEN-STRONG,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, HENRY W. STRONG, by his attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is HENRY W. STRONG, an adult individual who currently resides
at 1804 Silver Pine Circle in Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is JAN SUSAN NilSEN-STRONG, an adult individual who
currently resides in Cumberland County and whose address, to the best of Plaintiff's
knowledge is P.O. Box 1063 in Carlisle, Pennsylvania 17013.
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 18 July 1996 in Los Vegas,
Nevada.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
II
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
COUNT II - EXCLUSIVE POSSESSION OF RESIDENCE
9. The averments set forth in Paragraphs 1 through 8 above are incorporated
herein by reference.
10. During the marriage the parties acquired, as tenants by the entireties, a
residence at 1804 Silver Pine Circle in Mechanicsburg, Hampden Township, Cumberland
County, Pennsylvania.
11. In February of 2003, Plaintiff learned that Defendant has misappropriated and,
without Plaintiff's consent, knowledge, or permission, improperly removed funds from
Plaintiff's business.
12. After discovering the misappropriation of funds from his business, Plaintiff
subsequently learned that Defendant had taken or destroyed records of the business,
apparently in an attempt to conceal her actions and misappropriations.
13. On or about 26 February 2003, Defendant, without any prior notification to
Plaintiff, left the residence at 1804 Silver Pine Circle in Mechanicsburg and has concealed
her whereabouts and location since that time.
14. A local police department is currently investing Defendant's conduct in
misappropriating funds from Plaintiff's business and Plaintiff believes that Defendant is
aware of that investigation and the possibility of criminal charges being filed against her.
15. Plaintiff resides in the residence at 1804 Silver Pine Circle and keeps many of
the records of his businesses and financial assets and operations in the residence.
16. Plaintiff fears that, if Defendant has access to the residence she will remove
property which belongs to Plaintiff, including business records, or that she will destroy
records in an effort to conceal her conduct up to now.
II
17. To protect his privacy, his property, and his business records, Plaintiff must
have exclusive possession of the residence at 1804 Silver Pine Circle in Mechanicsburg
pending further order of this court.
WHEREFORE, Plaintiff requests this court to enter a decree in divorce pursuant to
the Divorce Code of Pennsylvania and, pending further order of this court, to award
Plaintiff exclusive possession of the residence at 1804 Silver Pine Circle in
Mechanicsburg, Hampden Township, Cumberland County, Pennsylvania, and prohibit the
Defendant from entering the property without Plaintiff's consent.
~~~
Sa I L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 1 7043
(717) 761-5361
II
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VERI FICA TION
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date:
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COMMONWEALTH OF PENNSYLVANIA
DEPOARTMENT OF HEALTH
VITAL RECORDS
03- al5fo (,1.111
COUNTY
CUMBERLAND
RECORD OF
DIVORCE
State File Number
State File Date
HUSBAND
NAME FIRST MIDDLE LAST DATE MONTH DAY YEAR
OF
HENRY W. STRONG BIRTH FEBRUARY 20 1950
RESIDENCE STREET OR R.D. CITI, BORO. OR TWP. COUNTI STATE PLACE (STATE OR FOREIGN COUNTRY)
OF
1804 SILVER PINE CIRCLE MECHANICSBURG CUMBERLAND PA BIRTH INDIANA
NUMBER RACE USUSAL OCCUPATION
OF THIS 2 WHITE BLACK OTHER (SPECIFY)
MARRIAGE xx BUSINESS OPERATOR
WIFE
MAIDEN NAME FIRST MIDDLE LAST DATE MONTH DAY YEAR
OF
JAN SUSAN NILSEN-STRONG BIRTH AUGUST 15 1959
RESIDENCE STREET OR R.D. CITI, BORO. OR TWP. COUNTI STATE PLACE (STATE OR FOREIGN COUNTRY)
OF
P.O. BOX 1013 CARLISLE CUMBERLAND PA BIRTH NIGERIA
NUMBER RACE USUSAL OCCUPATION
OF THIS 2 WHITE BLACK OTHER (SPECIFY)
MARRIAGE xx SALES SUPERVISOR
PLACE OF COUNTI (STATE OR FOREIGN COUNTRY) DATE OF MONTH DAY YEAR
THIS THIS
MARRIAGE LAS VEGAS NEVADA MARRIAGE JULY 18 1996
NUMBER OF NUMBER OF DEPENDENT PLAINTIFF DECREE GRANTED TO
CHILDREN THIS 0 CHILDREN UNDER 18 0 HUSBAND WIFE HUSBAND WIFE
MARRIAGE xx xx
NUMBER OF HUSBAND WIFE SPLIT CUSTODY OTHER (SPECIFY) LEGAL GROUNDS FOR
CHILDREN TO DIVORCE OR ANNULMENT 3301 (D) DIVORCE CODE
CUSTODY OF
DATE OF DECREE MONTH DAY YEAR DATE REPORT SENT MONTH DAY YEAR
TO VITAL RECORDS
SIGNATURE OF TRANSCRIBING CLERK
HENRY W. STRONG
JAN SUSAN NILSEN-STRONG
317-50-3374
169-54-6182
DIVORCE INFORMATION SHEET
PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY
THE STATE EFFECTIVE JANUARY 1,2002. THE PROTHONOTARY IS
REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM.
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE.
DOCKET NUMBER: () 3 ' C;( I ~~
DATE OF MARRIAGE: JULY 18, 1996
"
HENRY W. STRONG,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
JAN SUSAN NILSEN-STRONG,
Defendant
NO.
IN DIVORCE
MOTION FOR HEARING ON REQUEST FOR EXCLUSIVE POSSESSION OF RESIDENCE
AND NOW comes the above-named Plaintiff, by his attorney, and moves the court
as follows:
1. The moving party herein is the Plaintiff. The responding party herein is the
Defendant.
2. Plaintiff has contemporaneously with the filing of this Motion, filed a Complaint
in Divorce seeking, among other things, an award of exclusive possession of the parties'
residence at 1804 Silver Pine Circle in Mechanicsburg, Hampden Township, Cumberland
County, Pennsylvania. Attached to this Motion and marked as Exhibit A is a copy of
Plaintiff's Complaint.
3. Plaintiff requests a hearing on his request for exclusive possession of the
residence to protect himself and his property and business records.
WHEREFORE, Plaintiff moves this court to schedule a hearing on his request for
exclusive possession of the residence at 1804 Silver Pine Circle in Mechanicsburg.
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Sa el L. A'n~
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
"
VERIFICA TION
I verify that the statements made in this Motion are true and correct. I understand
that any false statements in this Motion are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
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Attorney for Plaintiff
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HENRY W. STRONG,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. D3 - 2/%
JAN SUSAN NILSEN-STRONG,
Defendant
IN DIVORCE
ORDER
AND NOW this \~~ day of ~ ' 2003, a hearing
on Plaintiff's Request for Exclusive Possession of the Residence at 1804 Silver Pine Circle
in Mechanicsburg, Pennsylvania, is hereby scheduled, to be held before the undersigned,
in Court Room No. ~ of the Cumberland County Courthouse in Carlisle,
Pennsylvania, commencing at q:oo o'clock ~.m.
on IJ)~ the 1/ f:L day of tlt-,:M.. ' 2003.
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Distribution:
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~muel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12th Street, Lemoyne, Pa 17043
~ Susan Nilsen-Strong (Defendant)
P.O. Box 1063, Carlisle, PA 17013
..--P'; Richard Wagner, Esquire (Attorney for Defendant)
, 2233 North Front Street, Harrisburg, PA 17110
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HENRY W. STRONG,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 03-2156
JAN SUSAN NILSEN-STRONG,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE
I hereby enter my appearance for the Defendant, Jan Susan Nilsen-Strong, in the
above-captioned action. I acknowledge receipt of a true and correct copy of the Complaint
in Divorce and the Plaintiff's Motion for Hearing on Request for Exclusive Possession of
Residence, filed in the above action on behalf of the Defendant.
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P . Rkhar agner
Aftorrrey for Defendant
Supreme Court ID # ,:?~3! i) ~
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
HENRY W. STRONG,
Plaintiff
CIVIL ACTION - LAW
NO. 03-2156
JAN SUSAN NILSEN-STRONG,
Defendant
IN DIVORCE
ORDER
AND NOW this ,..z..- day of _\ ~9 ,2003, upon the
agreement of the parties, we hereby award the Plaintiff, Henry W. Strong, exclusive
possession of the residence at 1804 Silver Pine Circle in Mechanicsburg, Hampden
Township, Cumberland County, Pennsylvania pending further order of this court. The
Defendant Jan Susan Nilsen-Strong shall not enter upon or come to the residence without
the prior written consent of the Plaintiff but the Plaintiff shall cooperate with Defendant to
allow her reasonable access to the property as she may need it for legitimate purposes in
the future.
B~ ~E COU
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Distribution:
~eIL.
des, Esquire (Attorney for Plaintiff)
North 12th Street, Lemoyne, Pa 17043
. Richard Wagner, Esquire (Attorney for Defendant)
2233 North Front Street, Harrisburg, PA 17110
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IN THE COURT OF COM ON
PLEAS OF CUMBERlAN COUNTY,
PENNSYLVANIA
HENRY W. STRONG,
Plaintiff
CIVil ACTION - lAW
NO. 03-2156 CIVIL TER
JAN SUSAN NilSEN-STRONG,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code wa filed on 7
May 2003 and was served upon the Defendant on or about 12 May 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and nin y (90)
days have elapsed from the date of filing of the complaint and the date of servic of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notic of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and under tand that
the Court maintains a list of marriage counselors and that I may request the Cour to require
my spouse and I to participate in counseling and, being so advised, do not reques that the
Court require that my spouse and I participate in counseling prior to the divorce b coming
final.
I verify that the statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 P . C.S.
Section 4904 relating to unsworn falsification to authorities.
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I IN THE COURT OF COM ON
) PLEAS OF CUMBERLAN COUNTY,
) PENNSYLVANIA
)
) CIVIL ACTION - LAW
I
) NO. 03-2156 CIVIL TER
)
) IN DIVORCE
HENRY W. STRONG,
Plaintiff
JAN SUSAN NILSEN-STRONG,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code w filed on 7
May 2003 and was served upon the Defendant on or about 12 May 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and nin ty (90)
days have elapsed from the date of filing of the complaint and the date of servic of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notic of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and under tand that
the Court maintains a list of marriage counselors and that I may request the Cour to require
my spouse and I to participate in counseling and, being so advised, do not reques that the
Court require that my spouse and I participate in counseling prior to the divorce b coming
final.
I verify that the statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 P . C.S.
Section 4904 relating to unsworn falsification to authorities.
11/,:) 1/() t./
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HENRY W. STRONG, ) IN THE COURT OF COM ON
Plaintiff ) PLEAS OF CUMBERLAN COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 03-2156 CIVIL TER
JAN SUSAN NILSEN-STRONG, )
Defendant ) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 c OF THE DIVORCE C DE
1. J consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of prop rty,
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. I u derstand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Sect on 4904
relating to unsworn falsification to authorities.
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Dated:
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II
HENRY W. STRONG,
Plaintiff
IN THE COURT OF COM ON
PLEAS OF CUMBERLAN COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 03-2156 CIVIL TER
JAN SUSAN NILSEN-STRONG,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 c OF THE DIVORCE C DE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of prop rty,
lawyer's fees, or expenses if J 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. J u erstand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Sect on 4904
relating to unsworn falsification to authorities.
1/:;'9/tJ'/
Dated:
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HENRY W. STRONG, ) IN THE COURT OF COMMO
Plaintiff ) PLEAS OF CUMBERLAND C UNTY,
) PENNSYLVANIA
)
vs. ) CIVil ACTION - LAW
)
) NO. 03-2156 CIVIL TERM
JAN SUSAN NilSEN-STRONG, )
Defendant ) IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
I hereby acknowledge receipt of the Complaint in Divorce in this matter in M y of 2003.
I hereby withdraw any claims for economic relief, including alimony, equitable dist ibution,
alimony pendente lite, counsel fees and expenses, or any other economic claims, fi d by me
or on my behalf in the divorce action.
~~
AN SUSAN NILS
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HENRY W. STRONG,
Plaintiff
IN THE COURT OF COM ON
PLEAS OF CUMBERLAND OUNTY.
PENNSYLVANIA
vs.
CIVil ACTION - LAW
NO. 03-2156 CIVil TER
JAN SUSAN NilSEN-STRONG,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record. together with the following information, to the Court for en ry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acce tance of Service filed b Plaintiff's
counsel indicatinQ service on or about 12 Mav 2003.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 33 1
(c) of the Divorce Code: By Plaintiff: 29 November 2004 By Defendant: 29
November 2004
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of t e
Divorce Code: (2) Date of filing and service of the Plaintiff's Affid it
upon the Respondent:
4. Related claims pending:
None.
5. Complete either (al or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is
attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 {cl Divorce was filed
with the Prothonotary: Dated 29 November 2004 and filed contemporaneouslv
herewith. Date Defendant's Waiver of Notice in Section 3301 (cl Divorce was file
with the Prothonotary: Dated 29 November 2004 and filed contemporaneouslv
herewith.
Date: 29 November 2004
By
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IN THE COURT OF COMMON PLEA
OF CUMBERLAND COUNTY
STATE OF
PENNA,
HENRY W. STRONG ,
Plaintiff
No.
2003-L156
VERSUS
JAN SUSAN NIlSEN-STRONG I
Defendant
DECREE IN
DIVORCE
AND NOW,
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IT IS ORDERED AND
?l:,OLA, ,
,
DECREED THAT
HENRY W. STRONG
, PLAINTIFF,
AND
JAN SUSAN NIISEN-STRONG
, DEFENDAN ,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
NOT
YET BEEN ENTERED;
NONE
//
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BY THE coum:
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ATTEST:
PROTHONOT
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
;I e ;Vi? Ji W 5'1l2o /7 if:
(/ Plaintiff
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FileNo.
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IN DIVORCE
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Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff I defendant in the above matter,
[select one by marldng "x"]
_ prior to the entry of a Final Decree in Divorce,
or . L after the entry of a Final Decree in Divorce dated De.-c...f ;loOf
hereby elects to resume the prior surname of NIL.S F A/ , and gives this
written notice avowing his I her intention pursuant to the provisions of 54 P .S. 704.
Date:/t) ,-1 ;;)~O .5-- /o---.[;--/f?-;:f/?'--'
C7 Signature
COMMoNWEtt:'~l~:~SYLV ANIA
COUNTY OF
On the -.lL day of (f)~ t 0-& 1\ )
)
, 200.5 , before me, the Prothonotary or the
notary public, personally appeared the above affiant lmown to me to be the person whose
name is subscribed to the within document and acknowledged that he I she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
"~L ~ ~
Ic~~~;O A :e.7::;:
PROTHONOTARY, NOTARY PUBLIC
CARlISlE CUMBERlAND COUNTY COURT HOUSE
. IlY COMM!SS:ON EXPIRES JANUARY 2,2006
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