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Home My WebLink About99-02843.,,,,,<< ar„ y ?l{i ?}, 'Ait?: ?x J4i ,yk,', ? !,i ? S,.r w:- i9': i. 'a ;. ? ii „.: .:> ;; '-;? ?'(i i i i 0 i i e 6 e R i /s :o ?• s, :e• . •:?: •:?:•'cs??:y ?: ca..:?• •:?> •:?:• t?• :?i :?,•,:?:: °':. W. tc ..V. [?>?'•s•r..•:e;<;te•.:?:•; cs <s• c?>:';? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. i MARK S. PETERS, SR. N u ......... 99-2843. Versus SANDRA K. PETERS DECREE IN DIVORCE AND NOW . ............'tal ....?! • , • _ • , 19. . , it is ordered and decreed that . • ,MARK . S . . . PETERS, SR. plaintiff, ................................ • . . . • and . . . . . . ...SANDRA. K. PETERS ................................. defendant, .. are divorced from the bonds of matrimony. The court retains jurisdiction of the foliowii been raised of record in this action for which a fi been entered; N/A 11y T} Court: A:Icst: rJi •:ri •'A:• ;ti •A;• •:e: :K• :?:• :?:• ;?? :?i {?i 'ii <?} i?7 tt:• SY,<?::?:g claims which have ial order has not yet p ?rot?innol:vy ii i 1#1 W, >;e s s; 0 e i e i i i 8 ?• 99 C'! c? 7e em Y (,1 - u, C, Li b c:, t? w O . y y 00 H z a ? o C m 0 M o O I'M y w F N 10 ml ? >G 7 1 O F. cn . . q f9 N 4 ; C o ?' z n W (A z N H 5 Q U $4 > ry U F O 6 3 F Q z a? w' fOj A y . O M F W . 7 aW QO p z x ' W N orn W ,dl m 1"'1 a rn z° Mark S. Peters, Sr., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 99-2843 CIVIL. TERM Sandra K. Peters, Defendant 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 Section 3301 A of the Divorce Code. 2. Date and manner of service of the Complaint: First Class U.S. Mail, Postage Prepaid and Certified U.S. Mail, Restricted Delivery, Return Receipt No. P125 066 701, mailed on May 12, 1999, and received by defendant on May 17, 1999 at Defendant's last known address: 424 N. Second Street, Wormleysburg, Pennsylvania 17043. 3(b)(1). Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code: May 10, 1999 3(b)(2). Date of filing and service of the plaintiffs affidavit upon the defendant: Filing - May 11, 1999; Service - May 17, 1999. 4. Related claims pending: None Prothonotary July 1, 1999 Page 2 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: First Class U.S. Mail, Postage Prepaid and Certified U.S. Mail, Restricted Delivery, Return Receipt No. 7081 209 631, mailed on June 7, 1999, and received by defendant on June 8, 1999 at Defendant's last known address: 424 N. Second Street, Wormleysburg, Pennsylvania 17043. Respectfully submitted, Balaban and Balaban By: 1., ichael V. Brown, Esquire Attorney I.D. #79984 27 North Front Street P.O. Box 1284 Harrisburg, PA 17108-1284 (717) 234-3282 Attorney for Plaintiff 4 V1?111f1.ILNlti'.MM I'.I'NUI111 Exhibit A Mark S. Peters, Sr., IN THE COURT OF CO Plaintiff CUMBERLAND COUNT Y , 1'ENNSY LVA CIVIL ACTION - LAW V. NO. 99-2843 CIVIL TERM Sandra K. Peters, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF $3301(d) DIVORCE DFCIIER To: Sandra K. Peters You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the §3301(d) affidavit. Therefore, on or after Monday, June 28, 1999, the other parlay can request the Court to enter a final Decree in Divorce. If you do not fi le with the Prothonotary ofthe 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. A Counter-Affidavit which you may file with the Prothonotary of the Court is attached to this notice. 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. The filing ofthe form Counter-Affidavit alone does not protect your economic claims. 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 Lawyer Referral Services Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 12espectfully submitted, Balaban and Balab n 13y: lichael V. Brown, Esquire PA I.D. 1179984 27 Norh Front Street 11. O. Box 1284 I larrisburg, PA 17108-1284 (717) 234-3282 Attorney for Plaintiff Ml c DD N CF,R'1'IFICA'1'1,', OF SERVICE, 1, Michael V. Brown, 13squire, do hereby state that a true and correct copy of the NOTICE OF INTENTION TO REQUEST ENTRY OF 43301(d) DIVORCE DECREE and DEFENDANT'S COUNTER-AFFIDAVIT were, today, served upon the Defendant in the abovc. captioned action, in the manner stated below: The foregoing was served by mailing same to the Defendant at the Defendant's last known address of 424 North Second Street, Wonnleysburg, Pennsylvania 17043. Mailing was accomplished via regular United States Mail and Certified United States Mail, Return Receipt Requested. I understand that any false statements are subject to the penalties contained at 18 Pa. C.S. 44904, relating to unsworn falsification to authorities. Dated: 01 13y: Michae V. Brown C.\bGe\clvutc\t.lmc\Givonr um. Mark S. Peters, Sr., Plaintiff V. Sandra K. Peters, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2843 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Michael V. Brown, Esquire, do hereby state that a true and correct copy of the PRAECIPE TO TRANSMIT RECORD was served this day upon the Defendant in the above-captioned action, Sandra K. Peters, as stated below: VIA First Class U.S. Mail, postage prepaid to the Defendant at the Defendant's last known address, 424 N. Second Street, Wormleysburg, Pennsylvania 17043. I understand that any false statements are subject to the penalties contained at 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. -?/ Dated:July 1, 1949 _ Michael N. Brown Ci. JIMI CIALNI S SRI C r.N7'2.XVC Mark S. Peters, Sr., Plaintiff V. Sandra K. Peters, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 49 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 Courthouse, 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. 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. Cum Cumbc d County Lawyer Referral Ser¢ices rt Administrato berlan ntyCourthouse Carlisle; 1,A'17013 (717) 240-6200 Mark S. Peters, Sr., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2?V3 Sandra K. Peters, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Mark S. Peters, Sr., by his attorney, Michael V. Brown, Esquire, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Mark S. Peters, Sr., is an adult individual who resides at 504 Herman Avenue, Apartment B, Lemoyne, PA 17043, Cumberland County, Pennsylvania. 2. The Defendant, Sandra K. Peters, is an adult individual who resides at 424 North 2nd Street, Wormleysburg, PA 17043, Cumberland County, Pennsylvania. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the tiling of this Complaint. 2 4. The Plaintiff and Defendant were married on December 16, 1972, in Wormelysburg, Cumberland County, Pennsylvania, as is more fully shown by the copy of the certified Record of Marriage from the Clerk of Orphans Court Division for the Court of Common Pleas of Dauphin County, Pennsylvania attached hereto as "Exhibit A" 5. The Plaintiff and Defendant are both citizens of the United States of America. 6. There have been no prior actions in divorce between the parties. 7. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. 8. Plaintiffavers that there are no children of the parties under the age ofeighteen (18). 9. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 10. The cause of action under which Plaintiff is proceeding is Section 3301(d) of the Divorce Code. The marriage of the parties is irretrievably broken. The Plaintiff and Defendant have been separated, lived separate and apart, for more than two (2) years. WHEREFORE, the PlainlilTprays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. Respectfully submitted, BALABAN AND BALABAN Date: May 10, 1999 By:.. ?rZ? ??Jf `,-----. i ichM ael , Brown PA I.D. #79984 27 North Front Street P. O. Box 1284 Harrisburg, PA 17108-1284 (717) 234-3282 Attorney for Plaintiff G:AB&BVCLIENT SA881ACG VIL'".f1OC 4 Exhibit A ,marring C?Erfifir tte License No. "-108 (DUPLICATE) I _ REV' RIMARD W. SWARTZ herobv certity that on the _ 16TH and SEPERTY--TWO MARK STEM PBTEBS day of DECBMM one thousand nine hundred _, at WOR114I 55BIM, PINNSMVAHIA and SANDRA KAY FISCM wore by me united in marriage, in accordance with License issued by the Clerk of Orphan's Court Division of the Court of Common Pleas of Dauphin County, Pennsylvania, numbered Q-9-108 certified from the records APRIL 19, __1999 9a-uj8 • /q? Clerk of the Orphans' Court Division REP. RICEASD W. SWAR Z Minister of the Gospel District Justice or Magistrate i? VERIFICATION I verify that the statements made in this 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. BY 2.1 -5c Mark S. Peters; ?. plaintiff Date: s G:\ba \nl ienna\nRMS\,o I.lnc. vM 5 F.; G= c:: t ;? L : - ;? Li cm cn L' 0 2 v V y a N a a w ¢ m o q F p . Q W O E y] ? ? ?,s 00 w ^W .? C A ? M/y ?FY N N m U U .2 rl ty y F ,y H <> to 5 5!! 0 ,6Z .tl y F O zW? n r 7 W p W CI H < z H Q 6i h w ado V U9 w P R. a p W % u W U . Y. £ O aN p H w co v C w N x {4 a 7 + C - ?. fn Mark S. Peters, Sr., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 49^ o? ?u Lluc Sandra K. Peters, Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit 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 February 14, 1987, more than twelve (12) years ago, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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. 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.A §4904 relating to unsworn falsification to authorities. Date: d C??d Mark S. Peters, Sr. a: \bLb\c I f enb\t mme\e[t i davit. Wd 2 Will jt. 1:_ ~ Ci G1 rn ? N H W N E ? h O ? O b p w M y Z ? C ? ? w C > w ?N L) u z . M H c i qq r4 -H W co ? z off a c 0 7..,..1 G N G y Q ly ° x r co tt (1) a, ? ? ZF w? `' E P P4 o" a a - o W W v a ? 4 pi o W c a N ° F V1 co H H G m dd m d I H a G m u n1 '-V v •.? F. cn W cn q Marls S. Peters, Sr., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 99-2843 CIVIL TERM Sandra K. Peters, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Michael V. Brown, Esquire, do hereby state that a true and correct copy of the COMPLAINT IN DIVORCE UNDER SECTION 3301(D) OF THE DIVORCE CODE (the "Complaint") and PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE (the "Plaintiff's Affidavit") were served upon the Defendant in the above-captioned action, Sandra K..Peters, in accordance with Rule 1930.4(c) of the Pennsylvania Rules of Civil Procedure, as stated below: The Complaint and Plaintiff's Affidavit were served by mailing same to the Defendant at the Defendant's last known address, 424 N. Second Street, Wormleysburg, Pennsylvania 17043. Mailing was accomplished via regular United States Mail and Certified United States Mail, Restricted Delivery (Article Number: P125 066 701), Return Receipt Requested. The Return Receipt was signed for by Defendant on May 17, 1999. (The original Return Receipt, Article No.: P125 066 701, is made a part hereof and attached as Exhibit "A"). I understand that any false statements are subject to the penalties centaqined at 18 n_ . §4904, relating to unworn falsification to authorities. Dated: May 21, 1999 Michael V. Brown G.43MCI.ILNiSAS I CIA1 SVC ' j • eme i andlor 2 for eddidonef eeMcee. eme 3, 4e, end 4b I also Wish to receive the , eme end addreee u n return tole 7 following services (for an extra fee): 4 A orm to the hot o dcye not Receipt Requgrsd' p "hi Recelpl will show to did0 "U1"bOf 1. Q Addressee's Address 2RBStdcled Deliver t ? _ e d and the date y // j o v 3. Artlde Addressed to. a Article Nu Consult postmaster for fee. ----?_ mber k g a Sa,+dra - Nip-(-s . f?i zs-ohs ?v & cc (J?u ^1._ I 1 ouv.01 4 b. Service Type p Re istered E /? W t ?/ 1'7 04 3 g Certified ? E ress Mall ? Insured Rsturn Receipt for Merchandise ? COD 7. Date of olivery 5. Resolved By; (Print Name) R. Ad re e'ft d r (Only Il requested o 6 Si nal • and fee Is paid) 9 c . g ura dressee o ge) m c- P 11, December 1994 102595 97-B-0179 Domestic Retum Receipt LXHIB1T7?L =;? Fn 11.L l