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HomeMy WebLinkAbout07-15311 JOY E. ALLEMAN, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 31 CIVIL TERM BRIAN D. ALLEMAN, Defendant CIVIL ACTION-LAW 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. 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 a JOY E. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - . CIVIL TERM BRIAN D. ALLEMAN, CIVIL ACTION-LAW Defendant DIVORCE COMPLAINT 1. Plaintiff is Joy E. Alleman, an adult individual who currently resides at 456 Hunters Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Brian D. Alleman, an adult individual who currently resides at 456 Hunters Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff and Defendant have been bona fide residents in 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 November 2, 2002 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in Counseling. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER Date: Man?h 29, 1,?? 44 */ Michael A. Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff -1 VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: _ 7 - `. - , 2007 yy r? Q -mot O -n W ''- HIM G n t? JOY E. ALLEMAN, Plaintiff V. BRIAN D. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 1531 CIVIL TERM CIVIL ACTION-LAW ACCEPTANCE OF SERVICE AND NOW, thisday of OnAl-? , 2007, 1, Brian D. Alleman accept srrmlice of the Divorce Comp!eint in the above-captioned rase. r Brian D. Alleman r 6L JOY E. ALLEMAN, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA BRIAN D. ALLEMAN, Defendant NO. 2007-1531 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 C OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 21, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 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. 5. 1 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. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: q- -m r? ? ' .a ..J -? °`-_' ,?-> =r?, _- L? _i t `^3 '?? --=". ? JOY E. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRIAN D. ALLEMAN, Defendant NO. 2007 - 1531 CIVIL TERM CIVIL ACTION-LAW 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. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed an Acceptance of Service form on March 24, 2007. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on July 12, 2007; and Defendant on December 31, 2007. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARIC & SCHERER G. Michabl"Anbherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 r? ? ?_m. ? ? ? 1 ` ? ? ? =. ;_ t : ? ; '"= - r?"? . t 7 _ , ,, .? ? _ '-z# C.:.7 :...!. .. ?"'. JOY E. ALLEMAN, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA BRIAN D. ALLEMAN, Defendant NO. 2007-1531 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT. ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 21, 2007. 2. Defendant acknowledges receipt and accepted service of the Complaint on March 24, 2007. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. 1 consent to the entry of a final decree of divorce without notice. 5. 1 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. 6. 1 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. 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: 1 `3 )-09 ?? ?) - a&,- ? ? Brian D. Alleman .?' ?, z T` ` -°- ;? ?., T ?,? ' =,', C ;_` ?, ..? _ ? _' („w? " ?? ...? ? } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. any F. - ALLEMAN Plaintiff NO. 2007-1531 Civ; i VERSUS BRIAN D. ALLEMAN. DECREE IN AND NOW, I2n- 2-S , DECREED THAT AND BRIAN D. ALLEMAN IT IS ORDERED AND PLAI NTI FF, DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. I THE COURT RETAINS JURISDICTION OF THE FOLLO ING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. BY THE CO ATTEI$T: 1 !/ _ `C J. PROTHONOTARY DIVORCE Y ^ ?S V 1 c k ? s. a "