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HomeMy WebLinkAbout03-3123AMY R. STEINER, Plaintiff FRANCIS W. STEINER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 03- ~/a~ CIVIL TERM : 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 reqnest marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 AMY R. STEINER, Plaintiff FRANCIS W. STEINER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. O3 - -~ I,~.3 CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE NO FAULT Plaintiff is Amy R. Steiner, an adult individual currently residing in New Cumberland, York County, Pennsylvania. Plaintiff is represented by Gfiffie 8: Associates, 200 North Hanover Street, Carlisle, Cumberland County, Pennsylvania. Defendant is Francis W. Steiner, an adult individual currently residing at 2907 Market Street, 3~ Floor, Camp Hill, Cumberland County, Pennsylvania. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on June 2, 1997, in Cumberland County, Pennsylvania. There have been no other prior actions for divorce or annulment between the parties. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. o Plaintiff has been advised of the availability of counseling and the fight to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiffand Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted ,~ttorney for Plaii~ GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I 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 unsworn falsifications to authorities. AI~i~Y K~E1NER, Plaintiff - AMY R. STEINER, Plaintiff FRANCIS W. STEINER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3123 CIVIL TERM IN CUSTODY AFFIDAVIT OF SERVICE AND NOW, this C~day of July, 2003, comes Wendy J. F. Grella, Esquire, counsel of record for Plaintiff, Amy R. Steiner, and states that a true and attested copy of a Complaint in Divorce was forwarded to Defendant, Francis W. Steiner, at 2907 Market Street, 3rd Floor, Camp Hill, PA 17011 by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on July 3, 2003. 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this ~ day ,2003 I KarisaJ'~e'~umbe~d C°U~03 ~ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailplsoe, ,t~ or on the fn:mt if space permits. 18 d~ addrees ditfemnt from item 17 If YES, artier delivery ad~ beE)w: r-i Agent Addressee (Transfer from serv/ce/abe/) PS Form 3841, August 2001 Domestic Return Receipt Certified Mail Express Mall istemd Return Receipt for Merchandise [] Insured Malt E] C.O.D. 4. Restr~-ted Delivef~? (Ex,re Fee) AMY R. STE1NER, Plaintiff FRANCIS W. STEINER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3123 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on July I, 2003, and served on July 3, 2003. 2. The marriage of 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORITIESJ FRANCIS W. STEINER, Defendant AMY R. STEINER, Plaintiff Vo FRANCIS W. STEINER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-3123 CIVILTERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on July 1, 2003, and served on July 3, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaim. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORITIESJ AMY R. STEINER, Plaintiff FRANCIS W. STEINER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3123 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on July 1, 2003, and served on July 3, 2003. 2. The marriage of 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE 1N THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORITIESJ FRANCIS W. STE1NER, Defendant AMY R. STEINER, Plaintiff FRANCIS W. STE1NER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION' - LAW : : NO. 03-3123 CIVILTERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on July 1, 2003, and served on July 3, 2003. 2. The marriage of 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORITIES.J FRANCIS W. STF.1NER, Defendant AMY R. STEINER, Plaintiff FRANCIS W. STE1NER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND' COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03-3123 CIVILTERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ,~3301(c) OF THE DIVORCE CODE, I consent to the entry of a final decree in divorce without notice. 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 THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORITy FCI~NCIS W. S rEINER, Defendant AMY R. STE1NER, Plaintiff FRANCIS W. STEINER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3123 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on July 1, 2003, and served on July 3, 2003. 2. The marriage of 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 of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORITIES. DATE: AMY R. STEINER, Plaintiff FRANCIS W. STE1NER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3123 IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST 1HE ENTRY OF A DIVORCE iDECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 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. 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 THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 10--/0-03 R. ~EINER, Plaintiff AMY R. STEINER, FRANCIS W. STEINi 1. ACom 2003, and served on 2. The days have elapsed fro ai~iff lefendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3123 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT ,laint in Divorce under §3301 (c) of the Divorce Code was filed on July 1, ly 3, 2003. trriage of Plaintiff and Defendant is irretrievably broken and ninety (90) n the date of filing and service of the Complaint. 3. I cons mt to the entry of a final Decree of Divorce after service of notice of intention to request e2 ttry of the decree. I VERIFY T blAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND (',ORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBiECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSII ICATION TO AUTHORITIES. AMY R. S~I~qER, Pi'ain{lf'f' v AMY R. STEINER, FRANCIS W. STEIN] TO THE PROTHONC Transmit the divorce decree: 1. Ground fo~ Irretrk (Strik~ 2. Date and n 3,200 3. Complete ~ (a) Date (b) (1) D (2) 4. Related 5. Complete (a) Dar r~ (b) Da 'laintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW ~R, )efendant NO. 03-3123 IN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD ?ARY: :cord, together with the following information to the court for entry of a ivorce: able breakdown under § 3301 (c) out inapplicable section). nner of service of the Complaint: by certified mail, restricted delivery on July :her paragraph (a) or (b). of execution of the Affidavit of Consent required by §3301 (c) of the Divorce ~de: by Plaintiff: October 10, 2003 by Defendant: October 5, 2003 rte of execution of the affidavit required by §3301 (d) of the Divorce Code: ,ate of filing and service of the plaintiff's affidavit upon the respondent: rims pending: none either (a) or (b). and manner of service of the notice of intention to file Praecipe to Transmil :ord, a copy of which is attached: of plaintiff's Waiver of Notice in §3301 (c) Divome was filed with thc )thonotary: October 16, 2003 e defendant's Waiver of Notice in §3301 (c) Divorce was filed with th~ rothonotary: October 13, 2003 Attorney for Plaintiff IN THE AMY R. STEINE] COURT OF COMMON ;TATE Of Plai] :iff VER:;US FRANCIS W. ST~INER, Defeldant OFCUMBERLANDCOUNTY ¢..~~,~ F'ENNA. AND NOW DECREE IN DIVORCE DECREED THAT Amy R. Steiner Fz ~ncis W. Steiner AND ARE DIVORCED THECOURT BEEN RAISED YEt BEEN ENTE PLEAS NO. 03-3123 CIVIL TERM ROM THE BONDS OF MATRIMONY. ETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE ~ RECORD IN THiS ACTION FOR WHICH A FINAL ORDER HAS NOT ~ED; ATTEST: PROTHONOTARY , PLAINTIFF, , DEFENDANT,