The URL can be used to link to this page

Home My WebLink About99-03011 0 ? co • t? ? :e, ts. to:• _<? • •:e:* :e; <o:• :? • t?> to> to; •:? • :o: ;?, te> :e: <e> •:e:•' :• <e:• •:?2:';?: ? e;•..e. te:?:o> te•='s<' +,d IN THE COURT OF COMMON PLEAS ` OF CUMBERLAND COUNT`,' STATE OF PENNA. s RENEE M. SEIG, .... . 99-3011 CIVIL TERM ' ••' Pla.in.tif f ................. . i Versus CRAIG E. SEIG C Defendant _- A DECREE IN DIVORCE e'xt 3:5 4/ lo-In AND NOW, ....... °?.... , 19 99 .... it is ordered and ° RENEE M. SEIG plaintiff, ........................................... . . decreed that ... . o and CRAIG E. SE • IG . ......... 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 s been entered; NONE .................................................................... .................................... i ...... r •e•• F Attest: J• lop . Proffionotary ._ ?Al? .._._._ ._.__,..,.___.__......___...-._ ... _.. - te;•.ts> I.C. :.: •:e: a;..'. r,...•:e; :e> -.4. tW. C. a:• :?; 'Arl 1W.- Owl. t?; ., . . 9?>?9r y^?? ?? ?? ??? ?? RENEE M. SEIG, Plaintiff Vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3011 CIVIL TERM CRAIG E. SEIG, Defendant IN DIVORCE 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: Acceptance of Service filed by Defendant's counsel indicating service on 2 June 1999 (Acceptance filed on 9 June 1999) 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 330'1(c) of the Divorce Code: by Plaintiff: 2 September 1999 by Defendant: 2 September 1999 (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 Respondent: - 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: Da gd 2 September 1999 filed contemporaneously herewith Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 2 September 12 Dater i! By - e . Ande Attorney for Plaintiff r N u?9 C7 Z5 Cl- J v L. irl 0 N wry ?a LAJ ?y CQ ? V RENEE M. SEIG, Plaintiff VS. CRAIG E. SEIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99- 30 tj CIVIL TERM IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 in 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, Pennsylvania 17013 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, Pennsylvania 17013 Telephone: (717) 249-3166 RENEE M. SEIG, Plaintiff vs CRAIG E. SEIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 99- 3v CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF O NSE ING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within wenty days of the date on which you receive this notice. Failure to do so will constitute a vaiver of your right to request counseling. 1) ®;;: RENEE M. SEIG, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, 1 PENNSYLVANIA 1 VS. ? CIVIL ACTION - LAW 1 NO. 99- 3611 CIVIL TERM CRAIG E. SEIG, ) Defendant ) IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, RENEE M. SEIG, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is RENEE M. SEIG, an adult individual who currently resides at 149 Brindle Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is CRAIG E. SEIG, an adult individual who currently resides at 149 Brindle Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 8 November 1997 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNTI I 8. The Plaintiff requests this Court to enter a Decree of Divorce. 3 it WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 10. At about the time of the parties' marriage, they agreed that Defendant would sell a residence which he owned prior to the date of marriage and would retain the net proceeds of that sale and that, in consideration therefor, Defendant would waive any claim to the residence owned by Plaintiff at the date of marriage, even after the property was transferred into joint names, and that the full ownership and equity in that property would remain Plaintiff's separate property in the event of the death of either party or a divorce action. 11. The agreement between the parties described in the foregoing paragraph, was oral but Plaintiff relied upon it at the time she transferred her ownership interest in her residence to Defendant's name, thereby creating a constructive trust, or a resulting trust, whereby Plaintiff and Defendant held that property in joint names but for the sole benefit of Plaintiff. WHEREFORE, Plaintiff prays this Honorable Court to divide and distribute the assets of the parties in accordance with their agreement and the trust and other'obligation s which resulted from that agreement and to make equitable distribution of the other marital assets of the parties to the extent appropriate. -C-QUNT III - ALIMONY P NDENTE i ITE 12. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 13. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. 4 WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her I reasonable alimony pendente lite during the pendency of this action. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of IS Pa. C.S. 4904 (unsworn falsification to authorities). DATE: I /019 ?'l U71. ?U <1 REN E M. SEIG Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 5 1 ? c% OI cv! 1) 1L RENEE M. SEIG, Plaintiff VS. CRAIG E. SEIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3011 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 19 May 1999 and was served upon the Defendant on or about 2 June 1999. 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. I 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. Dated: 2 September 1999 ° (ll, I RENEE M. SEIG o- ? M Ct?, y v 4UI,?z; rJ r;J? U y `? 4 ?n Q RENEE M. SEIG, 1 IN THE COURT OF COMMON Plaintiff 1 PLEAS OF CUMBERLAND COUNTY, 1 PENNSYLVANIA ) VS. 1 CIVIL ACTION - LAW ) 1 NO. 99-3011 CIVIL TERM CRAIG E. SEIG, ) Defendant ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 19 May 1999 and was served upon the Defendant on or about 2 June 1999. 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. Dated: 2 September 1999 C CRAIG A. SEIG r. . c? L t„o :5s m.. y o ``cn dG: N ??Z 't t,' d ii1 y?J r' to -.; Is.. CY. . ? cT - U RENEE M. SEIG, ? IN THE COURT OF COMMON Plaintiff ? PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1 VS. ? CIVIL ACTION - LAW 1 NO. 99-3011 CIVIL TERM CRAIG E. SEIG, ) Defendant ? IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301() OF THE DIVORCE CODE 1. I 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 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. Dated: 2 September 1999 ?4 L nff a RENEE M. SEIG } C^. n N ° 9y ?v.. N CL. cr% U RENEE M. SEIG, Plaintiff VS. CRAIG E. SEIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3011 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE EST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I 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 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. Dated: 2 September 1999 CRAIG SEIG w r; c?sY - U 3 UL Co N CL. Lab cn RENEE M. SEIG, ) IN THE COURT OF COMMON Plainliff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) CIVIL ACTION - LAW NO. 99-3011 CIVIL TERM CRAIG E. SEIG, 1 Defendant ) IN DIVORCE ACCEPTANCE OF SERVICE I hereby enter my appearance on behalf of the Defendant, Craig E. Seig in the above matter and acknowledge receipt of a copy of the Complaint and accept service of the Complaint on behalf of my client. G. Date: inard Tint 14 ner, Esquire ' t co v ? u. s ? i V V.. is o rn v