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HomeMy WebLinkAbout99-04102Fl d4? 'i a ;a3 i 'Yr fid f 'fAF; "v y. i P W.- IN V THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Robert_Weiman N O ....4.1.9.2 ........... ................. 1999 Vc?:;us Carrie Weiman DECREE IN DI VORCE AND NOW, ....-t>c4c. tiL cz . 1. , . , .. , , • 19.1... , it is ordered and decreed that ... Robert Weiman • • ... • • , ... , plaintiff, and Carrie. Weiman 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; ........................................................................... ........ . . .. ................................................... By The o r t: Atte, I • J. V P othonotary ?I"i./Fr •A• •:e7• •A• :ei •m. <?:• <?:• :;?. •:?• <?:• •:e, •:?:: ?:e:•-•Y• ?:e} :?:• •Yi ?:?:• •:?:• •:O:• to>_t?:• <?: :?: ?•s:• t?:? ; 2 s i &T" e&;5v 2?? 4e ??ee." "5??t4/ 2;? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT WEIMAN, Plaintiff V. CARRIE WEIMAN, Defendant CIVIL LAW - DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY- Please 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. The foregoing complaint in divorce was served on July 13. 1999 by U.S. certified mail. 3. The date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code by the plaintiff was November 11. 1999. and by the defendant was November 12. 1999. 4. There are no related claims pending. 5. (a) The plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary on November 17, 1999. (b) The defendant's Waiver on Notice in § 3301(c) Divorce was filed with the Prothonotary on November 17. 1999 . Respectfully Submitte , Chuck Washburn 3540 N. Progress Ave. Suite 209 Harrisburg, PA 17110 (717) 541 4400. NO. 99-4102 rn 0 Ljjt5 " ?4 F- co l.? Cl) ?y O QI2 U a U Chuck E. Washburn Attorney at Law PA ID# 82020 3540 N. Progress Ave. Suite 209 Harrisburg, PA 17110 (717) 541 4400 ROBERT WEIMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. V9-9/0z & -Le V. CARRIE WEIMAN, CIVIL LAW - DIVORCE Defendant COMPLAINT 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 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 the visitation of your children. When the ground for 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 the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17103. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE 1 Courthouse Square Carlisle, PA 17013 TELEPHONE: (717) 240-6200 Chuck E. Washburn Attorney at Law PA [D# 82020 3540 N. Progress Ave. Suite 209 Harrisburg, PA 17110 (717) 5414400 ROBERT WEIMAN, Plaintiff V. CARRIE WEIMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL LAW - DIVORCE COMPLAINT IN DIVORCE Under Section 3301(c) of Divorce Code TO THE HONORABLE JUDGES OF SAID COURT: AND NOW comes the plaintiff, Robert Weiman, by and through his attorney, Chuck Washburn, and file the following Complaint in Divorce, and in support thereof respectfully represents as follows: COUNTI 1. Plaintiff is Robert Weiman, residing at 4532 East Trindle Rd, Apartment 4, Mechanicsburg, Pennsylvania 17055. 2. Defendant is Carrie Weiman, residing at 313 Summit Ave., Apartment 3, Hagerstown, Maryland 21740. 3. Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for a period of six (6) months immediately preceding to the filing of this Petition. Defendant was a bonafide resident of the Commonwealth of Pennsylvania from June 1998 until February 27, 1999 at which time the two separated and the defendant moved to Maryland. 4. This action is properly before this Court as the plaintiff resides in Cumberland County. 5. The parties were married on the 28th of June, 1997, in Washington County, Maryland. 6. There has been an irretrievable breakdown of the marriage relationship of the parties within the meaning of the Pennsylvania Divorce Code, as amended. 7. Plaintiff avers that this action is not collusive. 8. There are no minor children. 9. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 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. WHEREFORE, plaintiff respectfully requests your Honorable Court to enter a Decree in Divorce, divorcing plaintiff, Robert Weiman, and defendant, Came Weiman, absolutely. Respectfully Submitted, Chuck Washburn VERIFICATION I hereby verify that the statements made in the foregoing document 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 unswom falsification to authorities. Dated: 6 Zy k9 G??LL„-? Robert Weiman CERTIFICATE OF SERVICE I certify that I served a true and correct copy of the within Complaint for Divorce by Mailing same by certified mail, postage prepaid all this h day of S. L, 1999, as follows: I Carrie Weiman 313 Summit Ave. Apt. 3 Hagerstown, MD 21740 Date: -7- S q Chuck Washburn 3540 N. Progress Ave. Suite 209 Harrisburg, PA 17110 (717) 541 4400 a n c ILI V 3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT WEIMAN, NO. 0 a Plaintiff V. CARRIE WEIMAN CIVIL ACTION - DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on July 2, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of Complaint. 3. I consent to the entry of final decree of divorce and have waived service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: I1 11 rg9q IY to q). C?d.c ?- Robert Weiman o+ ?- '`_ :: , .. ,. ,_;: cr ... ?_i'.- , ??? ? _ ? _ c'.. _' - . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT WEIMAN, NO. Plaintiff V. CARRIE WEIMAN CIVIL ACTION - DIVORCE Defendant AFFIDAVIT OF CONSENT I . A complaint in divorce under §3301(c) of the Divorce Code was filed on July 2, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of Complaint. 3. I consent to the entry of final decree of divorce and have waived 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 P&C.S. §4904 relating to unswom falsification to authorities. Date: 12 llp ? 9 9 ra vu e w? Carrie Weiman o? - ,; _ c? U IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT WEIMAN, NO, (0 a Plaintiff t v. CARRIE WEIMAN, Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 3301(C) OF THE DIVORCE CODE 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 or expenses if 1 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. §4904 relating to unswom falsification to authorities. Date: It q 19yq ut/ lw. ('f?t, Robert Weiman 7- U? [1:. ?_? _> .-, .??'= ?` C tiJ " n _ .... rl -J ?`, J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROBERT WEIMAN, Plaintiff V. CARRIE WEIMAN, Defendant NO. / - T cri CIVIL ACTION - 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 of divorce without notice. 2. 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. 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. §4904 relating to unswom falsification to authorities. Date: (-L No ? 99 cm4ii t" Carrie Weiman _ O? T' ::? ?_ ?. tJ_ , ?? (?1 - I':J (,I (i ii Chuck Washburn Attorney for Plaintiff ID# 82020 4311 N. 6th Street Harrisburg, PA 17110 ROBERT WEIMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CARRIE WEIMAN, NO. 994102 CIVIL TERM CIVIL LAW - DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa R.C P 1920 4(a)(1)(ii) BEFORE ME, the undersigned authority, personally appeared Chuck Washburn, Attorney for plaintiff, who, after being duly sworn in accordance to law, deposes and states that he caused to be mailed to the defendant, Came Weiman, a true and correct copy of the Complaint, 3301 (c) of the Divorce Code filed at the above number ant term. Said document was mailed to the defendant by certified mail, restricted delivery, return receipt requested, postal number A 348 958 017, to her address located at 313 Summit Ave, Apt. 3, Hagerstown, MD 21740 on July 6, 1999. The defendant received the document July 13, 1999, all of which is evident from the return receipt requested which is attached, incorporated herein by reference and marked Exhibit "A SWORN to and subscribed before me this day of 1998. Notary Public Chuck Washburn 9 B 01911e111e 1 and/or 2 for additional saMCaa. ate Items 3, 4a, and ea. wr name and address an the reverse of INS Ion ad that we u. larm to the front of the mNlpau, or an the back If ps Return Rsc9/pt Rpuaslsd'on ma maaylem balm the snide atom Receipt will snow to whom 610 arlids was delivered an and Lc.CC1 r V-J r- 1Ma/1 313 Surltmlt Atic, j}?t 3 H?yors???n, MO JPYO December 1994 i t s M1 CM 3 CO as n U & E S IT] a i a N w c d m? m o I I z 0 I also wish to receive the foflowinp seMcas (for an cenreturrllNe extrefee): a dote not 1. E3 Addressee's Addis" number. 2. 13 ReaUded Delivery tM data Consult postmaster for fee. 4a. Article Number Z 3yg ?iSp 017 4b. Service Type ? Registered ll;;Id ? Express Mall ? insured ? Relum Receipt for MerdulWae ? COD 7. Date of Delivery JIIL 13 1999 ? 11. 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