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Home My WebLink About01-04463IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF `~ PENNA. ~ ~ DANIELLE R. CONRAD ''"' `'' Plaintiff N O. 01-4463 VERSUS JOSHUA L, CONRAD Defendant DECREE IN DIVORCE AND NOW, ~nyC+-,~~PS lS 2001 IT IS ORDERED AND DECREED THAT DAPdIEI.L~E~2- G9N$~1D , PLAINTIFF, AND JOSHUA L. CONRAD ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; BY THE COURT: C /~ J. ROTHONOTARY .~ y. 1~"r"°~ ~,,~~~,. DANIELLE R. CONRAD, Plaintiff vs. JOSHUA L. CONRAD, Defendant IN THE COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY OF PENNSYLVANIA CIVIL ACTION N0. 01-9463 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. Ground for divorce: Irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: July 27, 2001, by United States Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: By Plaintiff October 15, 2001; by Defendant November 06 2001. 4. Related claims pending: NONE. 5. Date Plaintiff's Waiver of Notice in § 3301 (c) Divorce filed with the Prothonotary: November 07 2001 6. Date Defendant's Waiver of Notice in ~ 3301 (c) Divorce filed with the Prothonotary: November 07 2001 Respectfully submitted, DISSINGER AND DISSINGER Date: `//~~/ _ 6 ren L. Koen gsberg Attorney for Plaintiff Supreme Court ID # 85556 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 cc: Joshua L. Conrad, Defendant ~S C~ DANIELLE R. CONRAD, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. CIVIL ACTION JOSHUA L . CONRAD, NO. p 1- ~/t/(o3 Defendant IN DIVORCE N O T I C E T O D E F E N D 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 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 717-249-3166 DANIELLE R. CONRAD, Plaintiff vs. JOSHUA L. CONRAD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA CIVIL ACTION N0. IN DIVORCE NOTICE OF RYGHT TO COUNSELING You are one of the parties in the above captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Prothonotary DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, t NOV OI-"l~l(7~.J CJU(~ Defendant IN DIVORCE CONSOLIDATED COMPLAINT IN DIVORCE 1. Plaintiff is Danielle R. Conrad, a citizen of Pennsylvania, residing at R R #1, Box 242 C, Liverpool, Juniata County, Pennsylvania, 17045. 2. Defendant is Joshua L. Conrad, a citizen of Pennsylvania, residing at 100-C Elicker Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui~uris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on March 10, 2000, in Perry County, Pennsylvania. 5. The marriage is irretrievably broken. 6. Thexe has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. The 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. COUNT I Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT II Request for Divorce Due to Irretrievable Breakdown Under 3301(d) of the Divorce Code 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. The marriage of the parties is irretrievably broken. 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. I15. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the ;Court to require the parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301 (d) of the Divorce Code. COUNT III Request for Counsel Fees, Costs and Expenses Under 3104, 3323, 3502 (e) and 3702 of the Divorce Code 16. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 17. Plaintiff has employed Karen L. Koenigsberg, Esquire of the law firm of Dissinger and Dissinger to represent her in this matrimonial cause. 18. Plaintiff is unable to pay the necessary counsel fees, costs, and expenses and Defendant is more than able to pay them. WHEREFORE, reserving the right to apply to the Court for temporary counsel fees, costs and expenses, prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. Respectfully submitted, DISSINGER AND DISSINGER Attorney for Plaintiff Supreme Court ID # 85556 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Danielle R. Conrad, verify that the statements made in the Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification. z Danielle Conrad, Plaintiff b DANIELLE R. CONRAD, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. CIVIL ACTION JOSHUA L. CONRAD, N0. 01-4463 Defendant IN DIVORCE AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA ss .. COUNTY OF CUMBERLAND Karen L. Koenigsberg, Esquire, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Plaintiff's Complaint in Divorce in this action to the Defendant at his residence, and that Defendant did receive same as evidenced by the signed receipt dated July 27, 2001, attached hereto as Exhibit "A". Maren L, xognigsne ~s re Attorney for Plain iff 28 North Thirty-second S eet Camp Hill, PA 17011 (717) 975-2840 Sworn to and subscribed before this ,3o'~-day of , 2001. "~C :. ..- s T!Yt3£S~+]a#~d W¢Mas+;rsy35agsinikMk-'Y'+'~ '~<#' .~. ~NpER: ~ I also wish to receive the follow- q Complete items t anNor z for atlditionai services. ing services (for aR extra fee): Oomplele items 3, 4a, and 46. o Prim your name and address on fha reverse of this form so that we can return this card ro ycu. 1. ^ Addressee's P.ddress o Attach Mis form to fhe from of the mailpiece, or on the back if space does not n a Z~~IReStdctedDelivery- .~ ~Wfit e 'Re[urn Receipt Requested'an the mailpiece berow the snide number. dThe Retpm Receipt will show to whom the adlde was delivered antl the date EBlivered. ^3. Article Atldressed to: Joshua L. Conrad . 100-C Elicker Road Carlislep~ PA 17013 ^ Registered ®Certified ^ F~rpress Mail ^ Insured ^ Return Receipt for Memhandise ^ COD ~/ fee is paid) r m PS Form 3811, December 1994 tU2595-99&9223 Dornesdc Re' EXHIBIT "A" .~- r~ c m A Y C A ~, .. A M t I A~?4Tx'LJ~WICe9rv~i __ .. DANIELLE R. CONRAD, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. CIVIL ACTION JOSHUA L. CONRAD, NO. 01-4463 Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~ 3301 (c) of the Divorce Code was filed on July 24, 2001 and served on July 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of the 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. §4909 relating to unsworn falsification to authorities. -r Date: ~~~~°~ J hua L. Conrad, Defendant c~ 0 c CA C r, ,_ -_ ~,, . ' L: 1; ~,, ; r;: _- ~c ~_ ;~ ors 2~ ~.~ ~, :loan ttNM~aAWkx=eSart Rf ~-~•'=++ r+°.vi~et~:ab.yru'~~~ntm'M'~~'w~;x.rav.°rfu~mA°Ytavi~3~a,CR~.+~4,' DANIELLE R. CONRAD, Plaintiff vs. JOSHUA L. CONRAD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA CIVIL ACTION N0. 01-4463 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 in Divorce without notice. 2. I understand that I may lose rights concerning alimony, alimony pendente lite, marital property or counsel fees 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. Date: /I` ~ ~ I r Jo,s ua L. Conrad, Defandant c~ 0 cn 0 fo DANIELLE R. CONRAD, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. . CIVIL ACTION JOSHUA L. CONRAD, NO. 01-4463 Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~ 3301(c) of the Divorce Code was filed on July 29, 2001 and served on July 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of the 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. X4904 relating to unsworn falsification to authorities. Date: tyt~~lb~ n 0 4 J 3 r~, ._ . -- -. _~ -, - ~~ _. =>--- - s` - r _r. - ~Ci r C.- ~ n -< -i=' ~ < £s ~a DANIELLE R. CONRAD, Plaintiff vs. JOSHUA L. CONRAD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA CIVIL ACTION N0. 01-4463 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 in Divorce without notice. 2. I understand that I may lose rights concerning alimony, alimony pendente lite, marital property or counsel fees 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. C nielle R. Conrad, Plaintiff v~ ~°= = . O j -__ ,:: -< _ ~-~. _ Vic, •' C `-'~ Q f ~ 1 r/~.J C6 !~$,... - ._ >. 4Th~9 V ~ ; :,., JM:ipe.13&` . '. ir#ie=F'ebgn°~~`ai~4#xq~.e.~We,~.~~w'.itu23p".a^ DANIELLE R. CONRAD, Plaintiff vs. JOSHUA L. CONRAD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA CIVIL ACTION N0. 01-4463 IN DIVORCE SOCIAL SECURITY NUMBER VERIFICATION Danielle R. Conrad - 110-66-2296 Joshua L. Conrad - 194-68-2115 ~ _ _ _ _. _Y~iW _ ~-PW(tM 1354 ~^va...~ "flu:Y ilr'~ma'M.'S1~ -..~.~FfKw.f33Po. .._ .... DANIELLE R. CONRAD, Plaintiff vs. JOSHUA L. CONRAD, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA CIVIL ACTION NO. 01-4463 IN DIVORCE PRAECIPE Please withdraw Count III Request for Counsel Fees, Costs and Expenses from the Consolidated Complaint in Divorce filed July 24, 2001. Respectfully submitted, Date: (/~ ~ ~~ r I DISSINGER & DISSINGER 'Karen L. Koenigsberg,/,~squire ~ Attorney for Plainti ;" Supreme Court ID # 85556 ~, 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 cc: Joshua L. Conrad C~ ~ = : _ -_ ~ , ~~_ ~ _- ~ ~ ~ ~. s -- Vii; _~_. r :yf., .... r l __ . N ^~ ~ -1, t~J L G DANIELLE R. CONRAD, Plaintiff vs. JOSHUA L. CONRAD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA CIVIL ACTION N0. 01-4463 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff, Danielle R. Conrad in the above matter, having been granted a Final Decree in Divorce on the 15th day of November 2001, hereby elects to resume the prior surname of Van Horn and gives this written notice pursuant to the provisions of 54 Pa.C.S.A. X704. DATE : Q ~ Q COMMONWEALTH OF PENNSYLVANIA t ~-ignature o name ein f~s~fe~~~ lP. Y~aN ~loz... ss COUNTY OF ,~ . On the L day of ~(~e~r. 2000, before me, a Notary Public personally appeared Danielle R. Conrad known to me or satisfactorily proven to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. 0 C/~T" Nota Public ~° .m . _ o ~~~ _ t Z ~~~~ , C i '-,~r_ ~ kkk _ ;x :° ~- -, R ~,_:- ~, ~ .p ~ ~°c- ~; - ~ ~ ~'1 = i H ~~.~ 3 ~'s (f6