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Home My WebLink About99-02999IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TERESA B. ECKARD, Plaintiff No. 99-2999 CIVIL TERM VERSUS NORMAN ECKARD Defendant DECREE IN DIVORCE C:q- p.3 AND NOW, kmr-4? _ 2001 , IT IS ORDERED AND DECREED THAT TERESA B. ECKARD , PLAINTIFF, AND NORMAN ECKARD ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; NONE BY T ATTVfT: CLlJ.IdW -ft. .1,10.OJZO' i. PROTHO TERESA B. ECKARD (174-52-6046) Plaintiff VS. NORMAN ECKARD (561-39-2163) Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2999 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT R COR13 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). 2. Date and manner of service of the Complaint Service by certified mail on or about 1 May 1999. 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: 1-August 2001 by Defendant: 1 Aug 001 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the 4. Related claims pending: None 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: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 1 August 2001, filed contemooraneo Iv herewith, Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 1 August 001 filed contemporaneously herewith. Date: ZWl By Sam a L. Andes Attorney for Plaintiff 1 j TERESA B. ECKARD, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSY/LVANA VS. NO. 14y` NORMAN ECKARD, IN DIVORCE Defendant CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Notice and Complaint are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money. or property or other rights important to you. 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 COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 TERESA B, ECKARD, Plaintiff V. MORGAN ECKARD, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Defendant CIVIL ACTION - EQUITY IN DIVORCE N O T I C I A Le han demandado a usted sn la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. See avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATEMENTE. SI NO TIENNE DO O SI NO TTP.NTT: DT. nlwTV+n.. ENCUENTRA ESCRITA ABAJO PAPA AVERIGUAR D0NDE1SE4YPUEDEHCONSEGUIR ARISTENCIA LEGAL. CUMBERLAND COUNTY LEGAL SERVICE Court Administrator Cumberland County Courthouse CARLISLE, PA 17013 (717) 240-6200 TERESA B. ECKARD, Plaintiff VS. NORMAN ECKARD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (?,F a?919 u..t IN DIVORCE CIVIL ACTION - LAW COMPLAINT IN DIVORCE. AND NOW COMES Plaintiff, Teresa B. Eckard, by her attorneys, Purcell, Krug & Haller, and avers as follows: COUNT I DIVORCE PURSUANT TO SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE OF 1980 1. Plaintiff is Teresa B. Eckard, an adult individual who currently resides at 5008 McDonald Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Norman Eckard, an adult individual with a last known address at P.O. Box 462, Lemoyne, Cumberland County, Pennsylvania. 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. Plaintiff and Defendant were married on October 17, 1987. 5. Plaintiff avers that two (2) children were born of this marriage, namely Emily S. Eckard (born 7/20/94) and Sara E. Eckard between the parties. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The marriage is irretrievably broken. 10. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce pursuant to Section 3301(c) or 3301(d) of the Divorce Code. ALTERNATIVE COUNT II DIVORCE PURSUANT TO SECTION 3301 (a)(6) 12. Plaintiff repeats and realleges the averments contained in paragraphs 1 through 11 as if more fully set out at length herein. 13. Plaintiff avers that she is the innocent and injured spouse and that the Defendant has offered such indignities to her as to render her condition intolerable and life burdensome. 2 WHEREFORE, Plaintiff prays this Court to enter a Decree in Divorce pursuant to Section 3301(a)(6) of the Divorce Code of 1980. PURCELL, KRUG & HALLER By y IThole M. St ley, E quire #79866 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 Dated: May 18, 1999 3 I, TER/ErSA M. ECKARD, verify that the statements made in the foregoing CVtim OJ?um?? 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. By: a. o ?GLLI.t p\ TERESA M. ECKARD Dated: 511911`1 CERTIFICATE OF SERVICE I, MARCIA GATES, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that service of the attached COMPLAINT was made upon the following by placing a copy of same in the United States mail, postage prepaid, and as United States mail, Certified/Return Receipt requested and Restricted Delivery at Harrisburg, Dauphin County, Pennsylvania, on May 19, 1999. Norman Eckard P.O. Box 462 Lemoyne, PA 17043 MARCIA E. GATES .W ?1. 1 tv) W a w 44 4J [ J S' Ci V Q P o (o Q) J2? a4 0) W 2 Z Q i Q a U 4 J ?' > m Q Q ? .4 1 V j 4 a W L] G W a N CC 2 J 5 W W Jl 2 A'1 R'. n 7 a W W O U 04 MM IGIIi a04ti 11Y•l?(411YI1 fil(Y CN MOI OJ aWM 1Y011 UY191A TERESA B. ECKARD, ) IN THE COURT OF COMMON PLEAS PLAINTIFF ) OF CUMBERLAND COUNTY, 1 PENNSYLVANIA 1 VS. 1 CIVIL ACTION - LAW 1 1 NO. 99-2999 CIVIL TERM NORMAN ECKARD, ) DEFENDANT 1 IN DIVORCE Affill) IT_Of-CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 19 May 1999 and served upon the Defendant on or about 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. 1 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 Notice of Intention to Request Entry of the Decree. 4. 1 have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming 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 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. %-(- 0 1 Date I -"?ba TE SA B. E KARD TERESA B. ECKARD, PLAINTIFF VS. NORMAN ECKARD, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2999 CIVIL TERM IN DIVORCE AEFJDAYIT_QEJzONSPNI 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 19 May 1999 and served upon the Defendant on or about 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. 1 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 Notice of Intention to Request Entry of the Decree. 4. 1 have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming 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 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 5111 01 Date TERESA B. ECKARD, 1 IN THE COURT OF COMMON PLEAS PLAINTIFF 1 OF CUMBERLAND COUNTY, 1 PENNSYLVANIA 1 VS. 1 CIVIL ACTION - LAW 1 1 NO. 99-2999 CIVIL TERM NORMAN ECKARD, 1 DEFENDANT 1 IN DIVORCE WA IVEFLOEN_011CE OF INTENTLON-10-BE_QUEST-ENIBY-OE A DIVOS-=ECTIEJE UNDER SECTION 3301. (C) OF THE_DIURCJ`CiODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 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. 3. 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. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date S--1- 0 I L? JJ_, I TERESA B. ENARID ?: F. i TERESA B. ECKARD, ) IN THE COURT OF COMMON PLEAS PLAINTIFF ) OF CUMBERLAND COUNTY, 1 PENNSYLVANIA ) VS. ) CIVIL ACTION - LAW 1 1 NO. 99-2999 CIVIL TERM NORMAN ECKARD, ) DEFENDANT 1 IN DIVORCE II WA LV ERJOF-NQILCE D EINIENM-N-T-QREQUESLENIRY-OE A DIVORCE DECREE UND-ER-SECIIQN-33Q1LC1Of-TH -VMCE_=E 1. 1 consent to the entry of a final decree in divorce without notice. 2. 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. 3. 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. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to . unsworn falsification to authorities. 8-I-Of Date RMANECKARD ?? "1: '. • '-,1 ? a _ ?? TERESA B. ECKARD, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND CO., PENNSYLVANIA VS. NO. 99-2999 CIVIL NORMAN ECKARD, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Nichole M. Staley, Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 19th day of May, 1999, I sent, by certified mail, return receipt requested a Complaint in Divorce to the Defendant, Norman Eckard. The Return Receipt Card signed by the Defendant on May 11, 1999 is attached hereto as Exhibit "A". Sworn and subscribed to before me this day of 1999. ota y ahlic NOTARIAL SEAL CHERYL L. DoVERE, Notary Public Cep of Hemsburp, Dauphin County M „ommission Expires Mey 11, 2002 `- 71 117 r .._ 6 Ow 7 L;'-r. I L ?. Y11CL I0 u U l W P4 P4 z 0 w J a J H ' ? . ' . x n P'4 ?D - 0 ?4 -H .J 'y E H 11 W y u N, O Z U Pr ttl N 5 z m D 2 .? 0 W > n 4a w z N I ? W W :A r s x wz ? s Ca H ? n u •wKLLP ab{piap ?p6?J V1 pitap i m SENDER: $ •Co r?p?s items l and/or 2 for additional services. I also wish to receive the k N I • ConTllfale items 3, 4a, and 4b. following SBrvICOS (fOr an 1. • Plint9your name and address on the reverse of this lonn card to you. so that we can return this extra fee): > • Asach this form to Ilia front of the mellpleea, or on the back if space does not 1 ? Addressee's Address I ppanvil. •write n furs Receipt Roqucstod'on the mailplece below the article number. • The Return Recei t will show to whom the l ti d li . 2•XRestricled Delivery Z p ar c e was e denvered. vered and the dale Consult postmaster for fee, I nt ' `0 3. ARicle Addressed to: 4a. Article N umber u V?cuc< NornisnFc Z5'?'jvrS 1(c) d ? E E . O l ?' u u ? - 1 1 1 ( 4b. Service Type g 1 I C L C ' ? Registered I Certified 1s' r? c tiI j t - ? Express Mail ? insured ci i ? Return Receipt for Merchandise ? COD 7, Date gJ.pel rv. : `..Ll Y O t J 0 i 5. Received By: (PrigI Name) 8. Addressee's Address (Only it requested ((?? and too is paid) m I j 6. Signet : (Ad e? a .Agent) ?; I T - X a PS Forrit 3811, December 1994 102695 96 9-0229 Domestic Return Receipt EXHIBIT "All TERESA B. ECKARD, Plaintiff VS. NORMAN ECKARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2999 CIVIL TERM IN DIVORCE TO THE PROTHONOTARY: Please enter my appearance for the Plaintiff in the abovo-captioned matter and withdraw Count II of the complaint seeking a divorce on the grounds of indignities. S'am adds' Attorney for Plaintiff Supremo Court ID 17225 525 North 12"' Street Lemoyne, PA 17043 (717) 761-5361 i ° _J