HomeMy WebLinkAbout01-06284
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
MARI'HA A. ULRICH,
Plaintiff
VERSUS
LOUIS A, ULRICH,
Defendant
AND NOW,
DECREED THAT
PENNA.
No.
01-6284
Civil Tenn
DECREE IN
DIVORCE
~ 3: Q.?pM.
,-r-
2003
, IT IS ORDERED AND
A. ULRICH
, PLAiNTIFF,
LOUIS A. ULRICH
, DEFENDANT,
AND
ARE DIVORCED FROM THE BONDS OF MATRiMONY.
THE COURT RETAINS JURiSDICTION OF THE FOLLOWING CLAiMS WHICH HAVE
BEEN RAISED OF RECORD
YET BEEN ENTERED;
IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
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PROTHONOTARY
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MARI'HA A. ULRICH,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
LOUIS A. ULRICH,
Defendant
CIVIL DIVISION
NO.
01-6284 CIVIL TERM
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:
Itl'rttrie)lM~~~J"!ta'Wo\I.IIlii Atltiet~O'f~
3301 (d)(1) of the Divorce Code.
(Strike out inapplicable section).
Complaint In Divorce was served by Certified
2. Date and manner of service of the complaint: MaiL Return Receipt Requested - Restricted
Delivery on November 9. 2001. Amended Complaint In Divorce was served by Certified Mail
RAtllrn RAceipt Reqllested - Restricted Deliverv on Mav 23. 2003.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code:
by plaintiff ; by defendant
(b) (1) Date of execution of the affidavit required by ~3301 (d)
of the Divorce Code: May 13, 2003
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
Date of fi1inq was May 21,2003 and date of service was May 23, 2003
4.
Related claims pending:
None1aims pending
5. Complete either (a) 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: Date of service - June 18, 2003, by regular surface mail , postage
prepaid
(b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary:
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary:
BATURIN & BATURIN
~
By: .
Harry M.BaturinAttorney for Pial tiff .
Date: July 8. 2003
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01.6284 CIVIL TERM C]
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LOUIS A. ULRICH,
Defendant
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NOTTCE OF TNTFNTTON TO REQUEST ENTRY OF DIVORCE IiRCREE'
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CIVIL ACTION - LAW
IN DIVORCE
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TO: Louis A. Ulrich
207 S. Sporting Hill Road
Mechanicsburg, PA 17050
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YOU HAVE RFFN SUFD TN AN ACTTONFOR DTVORCE. Youhavefailedto
answer the Complaint or file a Counteraffidavit to the Plaintiffs Affidavit. Therefore, on or after
July 8, 2003, the Plaintiff can request the Court to enter a Final Decree In Divorce.
If you do not file with the Prothonotary of the Court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the Court can enter a Final Decree
In Divorce. Unless you have already filed with the Court a written claim for economic relief,
you must do so by the above date or the Court may grant the divorce and you will lose forever
the right to ask for economic relief. A Counteraffidavit which you may file with the
Prothonotary of the Court is attached to this Notice,
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
Two Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
Dated; June 18, 2003
BATURIN & BATURIN
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Harry M. B~turin, Esquire
717 N. Second Street
Harrisburg, PA 17102
(717) 234-2427
(Attorney for Plaintiff)
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01.6284 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
LOUIS A. ULRICH,
Defendant
DEFENDANT'S COUNTERAFFIDA VIT
lJNDFR SF.CTlON 3301 (d) OF Tln'. mVORCF, COnl':
1. Check either (a) or (b):
_ (a) I do not oppose the entry of a divorce decree.
_ (b) I oppose the entry of a divorce decree because
(Check (i), (ii), or both:
_ (i) The parties to this action have not lived separate and apart for a period of at
least two years.
_ (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_ (a) I do not wish to make any claims for economic relief. 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.
_ (b) I wish to claim economic relief which may include alimony, division ofproperty,
lawyer's fees or expenses or other important rights.
T VERTFYTHAT THF STATE~fFNTS MADE mTffiS COT TNTERAFFIDAVTT ARE
TRUE AND CORRECT TTJNDERSTAND THAT FALSE STATEMENTS HEREm ARE
MADE SImmCT TO THE PENALTIES OF 18 PA C S SECTION 4904 RELATmG TO
HNSWORNFAT STFTCATTONTO AIJTHORTTIES.
DATE:
LOUIS A. ULRICH, Defendant
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DNORCE DECREE
AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED
NOT FILE TIDS COUNTERAFFIDA VIT.
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MARTHA A. ULRICH,
Plaintiff
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LOUIS A. ULRICH,
Defendant
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. () J ~ 1_.JPj CIVIL TERM
CIVIL ACTION - LAW
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 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, Cumberland County, Carlisle, Pennsylvania.
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.
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americanswith 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 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
BATURIN & BATURIN
Dated: October 31,2001
By:
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HARRY M. B TURIN, ESQUIRE
Attorney I.D. No. 83006
717 North Second Street
Harrisburg, PA 17102
(717) 234-2427
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 1)1 - L::U>'f CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
LOUIS A. ULRICH,
Defendant
COMPLAINT UNDER SECTION 3301(C)
OF THE DIVORCE CODE
AND NOW, this 31st day of October, 2001, comes the Plaintiff, MARTHA A.
ULRICH, by and through her attorneys, the Law Offices of BATURIN & BATURIN,
and respectfully represents the following:
1. The Plaintiff is MARTHA A. ULRICH, an adult individual, sui juris, with a
Social Security Number of 183-60-6311, and who currently resides at 35 North Market
Street, Duncannon, Perry County, Pennsylvania 17020.
2. The Defendant is LOUIS A. ULRICH, an adult individual, sui juris, with a
Social Security Number of 178-56-6432, and who currently resides at 207 S. Sporting
Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for at least six (6) months immediately prior to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on January 13,1989, in
Winchester, Virginia.
5. There has been no prior action for divorce or annulment of the marriage
between the parties hereto in this or any other jurisdiction.
6. Plaintiff avers that there is one (1) child born to the parties under eighteen
(18) years of age.
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7. The Plaintiff and Defendant are both citizens of the United States of America.
8. The Defendant is not a member of the Armed Forces of the United States of
America.
9. The Plaintiff avers that the grounds upon which this action is based is that the
marriage is irretrievably broken.
10. Plaintiff has been advised that counseling is available and that the Plaintiff
may have the right to request that the Court require the parties to participate in
counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce
dissolving the marriage between the Plaintiff and Defendant and for such further relief
as the Court may determine equitable and just.
Respectfully submitted,
BATURIN & BATURIN
By:
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HARRY M. ~ATURIN, ESQUIRE
Attorney I.D. No. 83006
717 North Second Street
Harrisburg, PA 17102
(717) 234-2427
Attorney for Plaintiff
Dated: October 31,2001
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VERIFICATION
I VERIFY THAT THE STATEMENTS MADE IN THIS DIVORCE COMPLAINT
ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND
INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
FALSIFICATION TO AUTHORITIES.
DATED: October 30, 2001
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MAIirnA A.ULRICH
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MARTHA A. ULRICH,
Plaintiff
VS.
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
LOUIS A. ULRICH,
Defendant
CIVIL ACTION - LAW
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
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,
Cumberland County, Carlisle, Pennsylvania.
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.
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 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
BATURIN & BATURIN
Dated: May 14, 2003
By:
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HARRY . BATURIN, ESQUIRE
Attorney J.D. No. 83006
717 North Second Street
Harrisburg, PA 17102
(717) 234.2427
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MARTHA A. ULRICH,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 01-6284 Civil Term
LOUIS A. ULRICH,
Defendant
: CIVIL ACTION-LAW
: IN DIVORCE
AMENDED COMPI,AINT
ill
COUNT I
COMPLAINT UNDER SECTION 3301(C)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Martha A. Ulrich, by and through her attomeys, the law
firm ofBATURIN & BATURIN, and files the within Amended Complaint for the purpose of
changing the divorce from a 3301(C) to a 3301(D):
I. The Plaintiff, Martha A. Ulrich, avers that the parties to this action separated on April
23,2001, and have continued to live separate and apart for a period of at least two (2) years.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree In Divorce
dissolving the marriage between the Plaintiff and Defendant under Section 3301(D) of the
Pennsylvania Divorce Code.
Respectfully submitted,
BATURIN & BATURIN
By:
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Hany M. Ba . n, Esqu re
Attomey LD. 83006
717 North Second Street
Harrisburg, PA 17102
(717) 234-2427
Attorney For Plaintiff
Date: May 14, 2003
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MARTHA A. ULRICH,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 01-6284 Civil Term
LOUIS A. ULRICH,
Defendant
: CIVIL ACTION-LAW
: IN DIVORCE
VERTFICATION
I verify that the statements made in this Amended 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: May 13, 2003
~A.qRj~
(SEAL)
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MARTHA A. ULRICH,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01-6284 Civil Term
LOUIS A. ULRICH,
Defendant
: CIVIL ACTION-LAW
: IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counteraffidavit within twenty (20) days after this affidavit has been served on you or
the statements will be admitted.
Plaintiff's Affidavit Under Section 3301(d)
Of The Divorce Code
1. The parties to this action separated on April 23, 2001, and have
continued to live separately and apart for a period of at least two (2) years.
2. The marriage is irretrievably broken.
3. 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.
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: May 13, 2003
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A. ULRICH
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
LOUIS A. ULRICH,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTTFTCATE OF SERVICE
I, Harry M. Baturin, Esquire, of the law fIrm ofBaturin & Baturin, attorney for the
Plaintiff in the above captioned matter, do hereby certifY that on November 7, 2001, I deposited
in the Uuited States Mail, at the Uuited States Post OffIce, an article of CertifIed Mail, Return
Receipt Requested, marked "Restricted Delivery", a certifIed copy of the Complaint in Divorce
and Notice to Defend and Claim Rights attached thereto, bearing Article No. 7000 0520 0023
01249483 to: Louis A. Ulrich, 207 S. Sporting Hill Road, Mechanicsburg, PA 17050.
The said article of CertifIed Mail, as shown by the Postal Return Receipt Card was
received by the Defendant herein on November 9, 2001, and according to same, was signed by
him, to wit: Louis A. Ulrich, which card is attached hereto and marked as Exhibit "A", along
with the deposit slip dated November 7, 2001, for said article of CertifIed Mail aforementioned.
BATURIN & BATURIN
By:
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Harry M. Baturin, Esquire
Attorney 1.D. 83006
717 North Second Street
Harrisburg, P A 171 02
(717) 234-2427
(Attomey for Plaintiff)
Dated: November 13, 2001
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Louis A. Ulr':i!ch
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4. Restricted Delivery? (t;?ctra Fee)
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2. Article ~ lqopy frp{l1, se,rv/q~ /a/p'!/), " .
7000'0520'00~3i012~ '~4a3j
PS Form 3$11. July 1989 Domesllc Return Receipt
102595-99-M-1789
EXHIBIT "A"
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
LOUIS A. ULRICH,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTTFICA TE OF SERVICE
I, Harry M. Baturin, Esquire, of the law firm ofBaturin & Baturin, attomey for the
Plaintiffin the above captioned matter, do hereby certif'y that on May 21,2003, I deposited in the
United States Mail, at the United States Post Office, Harrisburg, Pennsylvania, an article of
Certified Mail, Return Receipt Requested, marked "Restricted Delivery", a certified copy of the
Amended Complaint in Divorce and Notice to Defend and Claim Rights along with Notice To
Defendant/Plaintiffs Affidavit Under Section 3301(d) of the Divorce Code attached thereto,
bearing Article No. 7000 0520 0023 0126 3526, addressed to: Louis A. Ulrich, 207 S. Sporting
Hill Road, Mechanicsburg, P A 17050.
The said article of Certified Mail, as shown by the Postal Return Receipt Card, was
received by the Defendant herein on May 23, 2003, and according to same, was signed by him,
to wit: Louis Ulrich, which card is attached hereto and marked as Exhibit" A", along with the
deposit slip dated May 21, 2003, for said article of Certified Mail aforementioned.
BATURIN & BATURIN
By H~~~
Attomey LD. 83006
717 North Second Street
Harrisburg, P A 17102
(717) 234-2427
(Attorney for Plaintiff)
Dated: May 27,2003
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u.s. postar Service
CERTIFIED MAIL RECEIPT .
(Domestic Mail Only; No Insurance Coverage Provided)
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nECHAHICSBURG PA 17050
Posl,g, $ $0.60.60
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Certlfled Fee
rn Return Receipt Fee
f1J (Endorsement Required)
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CJ
Restricted Delivery Fea
(Endorsement Required)
Total Postage & Fees $
CJ
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LI1 eclplent's Name (PIBsse PrInt Clearly) (To be completed by maller)
CJ Louis A. Ulrich
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-.-Print your name and address on the reverse
!:=-s_o that we can return the card to you.
~ttach this card to the back of the rraiJpJece,
:-br on the fro_nt if space permits.. __
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~~lcle Addressed to:
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Mr Louis A. Ulrich
C-- 207 S. Sporting Bill Road
. Mechanicsburg, PA 17050
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::: PS Form 38f1. August 2001
700~ .052g 0023 0126 3526
DOrT!estic Return Receipt
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01.6284 CIVIL TERM
LOUIS A. ULRICH,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTTFTCATE OF SERVTCE
I, Harry M. Baturin, Esquire, of the law firm of Baturin & Baturin, attorney for the
Plaintiff in the above captioned matter, do hereby certify that on June lOS, 2003. I deposited in the
United States Mail, Harrisburg, Pennsylvania, by regular surface mail, an article of mail, a
clocked-in copy of the Notice of Intention To RequestEntry of Divorce Decree along with
Defendant's Counteraffidavit Under Section 3301(d) ofthe Divorce Code attached thereto,
addressed to: Louis A. Ulrich, 207 S. Sporting Hill Road, Mechanicsburg, P A 17050.
BATURIN & BATURIN
By: ~~ (Y). ~
H~unn, Esqwre
Attorney LD. 83006
717 North Second Street
Harrisburg, P A 17102
(717) 234-2427
(Attorney for Plaintiff)
Dated: June n, 2003
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
LOUIS A. ULRICH,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTTCR OF INTRNTION TO RRQlJRST RNTRY OF DIVORCR DRCRRR
TO: Louis A. Ulrich
207 S. Sporting Hill Road
Mechanicsburg, P A 17050
YOU HA VE BEEN SUED TN AN ACTION FOR DIVORCE. You have failed to
answer the Complaint or file a Counteraffidavit to the Plaintiffs Affidavit. Therefore, on or after
July 3, 2003, the Plaintiff can request the Court to enter a Final Decree In Divorce.
If you do not file with the Prothonotary of the Court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the Court can enter a Final Decree
In Divorce. Unless you have already filed with the Court a written claim for economic relief,
you must do so by the above date or the Court may grant the divorce and you will lose forever
the right to ask for economic relief. A Counteraffidavit which you may file with the
Prothonotary of the Court is attached to this Notice.
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
Two Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
Dated: June 12,2003
BATURlN & BATURIN
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Harry M. aturin, Esquire
717 N. Second Street
Harrisburg, PA 17102
(717) 234-2427
(Attorney for Plaintiff)
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
LOUIS A. ULRICH,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S COUNTERAFFIDA VIT
UNDRR SRCTTON 3301(d) OF THR DTVORCR COllR
1. Check either (a) or (b):
_ (a) I do not oppose the entry of a divorce decree.
_ (b) I oppose the entry of a divorce decree because
(Check (i), (ii), or both:
_ (i) The parties to this action have not lived separate and apart for a period of at
least two years.
_ (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_ (a) I do not wish to make any claims for economic relief. I understand that I may lose
rights concerning alimony, division of property, lawyer's fees or expenses if! do
not claim them before a divorce is granted.
_ (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
T VRRIFY THAT THR STATEMENTS MADE TNTHTS COTJNTERAFFTDAVTT ARE
TRlJE AND CORRECT TTJNDERSTAND THAT FALSE STATEMENTS HERETN ARE
MADE SlJB.TECTTO THR PENALTTRS OF III PA C.S. SECTTON 4904 RELATTNGTO
IJNSWORN FALSIFTCATTON TO AIJTHORTTTES.
DATE:
LOUIS A. ULRICH, Defendant
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE
AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED
NOT FILE TillS COUNTERAFFIDA VIT.
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MARTHA A. ULRICH,
Plaintiff
vs.
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
LOUIS A. ULRICH,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTTCR OF INTRNTTON TO RRQIJRST RNTRY OF DIVORCR DRCRRR
TO: Louis A. Ulrich
207 S. Sporting Hill Road
Mechanicsburg, P A 17050
YOU HAVE BEEN SUED TN AN ACTION FOR DIVORCE. You have failed to
answer the Complaint or file a Counteraffidavit to the Plaintiffs Affidavit. Therefore, on or after
July 8, 2003, the Plaintiff can request the Court to enter a Final Decree In Divorce.
If you do not file with the Prothonotary of the Court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the Court can enter a Final Decree
In Divorce. Unless you have already filed with the Court a written claim for economic relief,
you must do so by the above date or the Court may grant the divorce and you will lose forever
the right to ask for economic relief. A Counteraffidavit which you may file with the
Prothonotary of the Court is attached to this Notice.
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
Two Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
Dated: June 18, 2003
BATURlN & BATURlN
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Harry M. Baturin, Esquire
717 N. Second Street
Harrisburg, PA 17102
(717) 234-2427
(Attorney for Plaintiff)
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MARTHA A. ULRICH,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
LOUIS A. ULRICH,
Defendant
DEFENDANT'S COUNTERAFFIDA VIT
UNDER SECTION 3301 (d) OF THE mVORCR CODE
1. Check either (a) or (b):
_ (a) I do not oppose the entry of a divorce decree.
_ (b) I oppose the entry of a divorce decree because
(Check (i), (ii), or both:
_ (i) The parties to this action have not lived separate and apart for a period of at
least two years.
_ (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_ (a) I do not wish to make any claims for economic relief. I understand that I may lose
rights concerning alimony, division of property, lawyer's fees or expenses if! do
not claim them before a divorce is granted.
_ (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
I VRRTFY THAT THE STATEMENTS MADE INTffiS COlJNTERAFFIDAVTT ARE
TRUE AND CORRECT TlJNDERSTAND THAT FALSE STATEMENTS HEREIN ARE
MADE STJBJECT TO THE PENALTIES OF 18 PA C S SECTION 4904 RELATING TO
TJNSWORN FALSTFTCA TION TO AUTHORTTIES.
DATE:
LOUIS A. ULRICH, Defendant
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE
AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED
NOT FILE TIDS COUNTERAFFIDA VIT.
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IN THE COURT OF COMMON PLEAS .
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
li's.
LOUIS A. ULRICH,
Defendant
A FFTnA VTT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was
filed on November 5,2001.
2. The marriage of the 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 in 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. !j4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
DATE: 7-/ -0 ;;
q~~'~ {/t2;,/
OUIS A. ULRICH
(SEAL)
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Plaintiff
VS.
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IN THE 'COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01-6284 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
LOUIS A. ULRICH,
Defendant
W ATVER OF NOTTCR OF TNTRNTION TO RRQURST
F:N1I'RY OF A DTVORCR DRCRRR UNDRR
SECTION 3301 (C) OF THR DTV()RCR CODR
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 and expenses if! 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 ofthe 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 TO THE PENALTIES OF 18 PA.C.S. ~4904 TO UNSWORN FALSIFICATION
TO AUTHORITIES.
DATE: 7-/ -0 ~
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LOUIS A. ULRICH
(SEAL)
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