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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
.JILL.. M.. STAR MAN,.
N ( t..99..4484...Civil..Term. 19
Plaint1ff..
Versus
ROBERT C.. STAHLMAN,..JR.,
Defendant
DECREE IN
D I V O R C E aA.A,
AND NOW, ....... M". , dg..... , , x1..2000, it is ordered and
decreed that ................ JILL.M..sTAHLMAN.................. plaintiff,
and ......................... RD0.8 RT c....$TAHIltAN, j.R......... , 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 The t:
Attest: J.
S/v/•v Prothonotary
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
ROBERT C. STAHLMAN, JR., NO. 99-4484 Civil Term
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: Via Certified Mail, Return Receipt
Requested, Restricted Delivery mailed July 26, 1999, and received on August 1, 1999.
3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c)
of the Divorce Code; January 31, 2000 (filed with the Prothonotary on February 3, 2000); by the
Defendant; March 2, 2000 (filed with the Prothonotary on March 17, 2000).
4. Related claims pending: None.
5. Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached, if the decree is to be entered under Section 3301(d)(1)(i) of the
Divorce Code: Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: February 3, 2000.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary:
March 17, 2000.
By
Iichael J. anft' Esquire
Attorney I.D. No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013
(717) 249-5373
Date: March 27, 2000 Attorneys for Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
ROBERT C. STAHLMAN, JR., NO. 99-4484 Civil Tenn
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: Via Certified Mail, Return Receipt
Requested, Restricted Delivery mailed July 26, 1999, and received on August 1, 1999.
3. Date of execution of the Plaintiffs affidavit of consent required by Section 3301 (c)
of the Divorce Code; January 31, 2000; by the Defendant; December 8, 1999.
4. Related claims pending: None.
5. Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached, if the decree is to be entered under Section 3301(d)(1)(i) of the
Divorce Code: Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: February 3, 2000.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary:
February 3, 2000.
By
Michael J. Han squir
Attorney I.D. No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013
(717) 249-5373
Attorneys for Plaintiff
Date: February 4, 2000
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. STAHLMAN, JR.,
Defendant
NO. Y9- UL/ tY (? T«---
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 at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from the list. All necessary
arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you
desire to pursue counseling, you must make your request for counseling within twenty (20) days of
the date on which you receive this notice. Failure to do so will constitute a waiver of your right to
request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, 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
Lawyer Referral
2 Liberty Avenue
Carlisle. PA 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
ROBERT C. STAHLMAN, JR., NO.
Defendant
COMPLAINT IN DIVORCE
AND NOW, this l? day of July, 1999 comes Plaintiff, Jill M. Stahlman, by and through
her attorney, Michael J. Hanft, Esquire, and files the following Complaint in Divorce, and in support
thereof avers as follows:
1. The Plaintiff is Jill M. Stahlman, who currently resides at 501 "B" Street, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The Defendant is Robert C. Stahlman, Jr., who currently resides at 18 Glenwood Avenue,
Oil City, Venango County, Pennsylvania 16301.
3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the
Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the
filing of this Complaint in Divorce.
4. The parties were married on June 25, 1994, in Franklin, Pennsylvania.
5. The marriage is irretrievably broken. The foregoing facts are averred and brought under
Sections 3301(c) or 3301(d) of the Divorce Code of 1980, as amended.
6. Alternatively, Plaintiff avers that the Defendant has offered such indignities to her, the
injured and innocent spouse, as to render her condition intolerable and her life burdensome. The
foregoing facts are averred and brought under Section 3301(a)(6) of the Divorce Code of 1980, as
amended.
7. The 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 requests Your Honorable Court to enter a Decree in Divorce,
divorcing the Plaintiff from the Defendant.
submitted,
KcTiael J. Hanft, Es re ' V
Attorney ID No. 579V
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered by
my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the Complaint in Divorce and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
7)1 . may
Ji . Stahlman
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
ROBERT C. STAHLMAN, JR., NO. 99-4484 CIVIL TERM
Defendant
CERTIFICATE OF SERVICE
?
AND NOW, this 1C?1 day of August, 1999, I, Michael J. Hanft, Esquire, hereby certify that
the following person was served with a True and Correct copy of the Divorce Complaint filed in the
above-referenced matter. The Divorce Complaint was mailed on July 26, 1999, and received on
August 4, 1999 by Defendant signing for a copy of the Divorce Complaint which was mailed in the
United States Mail, Certified Mail--Retum Receipt Requested, Restricted Delivery, Postage Prepaid,
addressed as follows:
Robert C. Stahlman, Jr.
18 Glenwood Avenue
Oil City, PA 16301
A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by
reference incorporated herein and made a part hereof.
Respectfully submitted,
kk? I /*,
Michael J. Hanft,Esquire'
Attorney ID No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorney for Plaintiff
I
I $ SENDER:
W • ComPIGNO Items 1 and/or2 for additional services I also wish to receive the
.
s COmpleto Items 3, 4a. and 4b.
• Print your name and address on the reverse of this torn so tha
card to following services (for an
t we can return this
extra fee):
j AS
• Attach this form to the front of the mailpiece, or on the hack If space does not t. ? Addressee's Address
ppeermit.
'
N eWdle
Retum Receipt Requested' on the mailpiece below the ankle number. 2.)< Restricted Delivery
• The Return Receipt will show to whom the artkle was d
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delivered. and the dale
Consult postmaster for fee N
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4 3. Article Adtlressed to:
i?er?4 C. S}ahlmariii sr?, .
4a. Article Number
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Return ft Pt for fdetaep dise ? COD
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PS Form 3911
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ecember 1994 102595 98-8-0229 Domestic Return Receipt
Exhibit "A"
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. STAHLMAN, JR.,
Defendant
NO. 99-4484 Civil Term
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
1. A Complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on July
26, 1999.
2.. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 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 unworn
falsification to authorities.
Date: mm. Jpw• 31. two
J' M. Stahlman
Sworn to and subscribed before me this
3151' dayof' A ,t999:DCCZ
Notary Public
Notarial Seal
Denise L. Nye, Notary Public
South Middleton Two, Cumbedano County
My y Commission Expires Feb.: 2001
Member,Penns"I ania Associatonot Notaries
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
V.
ROBERT C, STAHLMAN. JR.,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NO. 99-4484 Civil Term
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE
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. 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. §4904 relating to unswom
falsification to authorities.
Date: mod`/ A/ A &60 LJt (( ?? 1 . aCLZ Gk d maAj
J' M. Stahlman
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
V.
ROBERT C. STAHLMAN, JR.,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NO. 99-4484 Civil Term
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF
26, 1999.
A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 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 unswom
falsification to authorities.
Date: 112 O 9
Sworn to and subscribed before me this
Q1;12day of ()Paj-nkaaq, 1999.
Notary Public
Robert C. Stahlman, Jr.
Notarial Seal
CrenbeL. Up., Venango Coun
rry
My Commission on E
Expires Sept. 16, 2002
r, ve nsYNanta Association of Notaries
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
ROBERT C. STAHLMAN, JR., NO. 99-4484 Civil Term
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER Q 1tC1 OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division ofproperty, 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: /d f g/9 9 ,
Robert C. Stahlman, Jr.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
ROBERT C. STAHLMAN, JR., NO. 99-4484 Civil Term
Defendant
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS.
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July
26, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 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 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 unswom
falsification to authorities. ?1 C I '111
Date: go' 0O W IiJY a.? lr _
Robert C. Stahlman, Jr. Sworn to and subscribed before me this
day of ryjCL?-Coti
oL?CS?? n
Notary Public
r Notarial Seal
T@rri L, dollga. Notary Public
('ran;,err
g I TWr/ . Vananoo Cog
A4V CPirtns;'rxr xp1ma SaPt. 10. 2002
R{wrd.Hr, Pai,n,;y;'vaninasticiation c; nl7fanns
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JILL M. STAHLMAN,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
ROBERT C. STAHLMAN, JR., NO. 99-4484 Civil Term
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER &3301 (C) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights conceming 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: MloQla(xL ? /? l , C,
?0 Kllnwav .
Robert C. Stahlman, Jr.
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JILL M. STAHLMAN IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBERT C. STAHLMAN, JR. : NO. 99-4484 CIVIL TERM
CIVIL ACTION - DIVORCE
AND NOW, this 1,5TH day of FEBRUARY, 2000, it appearing to the Court that
defendants affidavit of consent does not meet the requirements of Pa. Rule of Civil
Procedure 1920.42 (b)(2) in that it was filed more than thirty (30) days after it was
executed, plaintiffs request for the entry of a divorce decree is DENIED without
prejudice. We will reconsider this matter when the above defect has been cured.
Michael J. Hanft, Esquire
For the Plaintiff
By the Court,
Edward E. Guido, J.
COPA'Al
19 - 'In ??
S -00
Robert C. Stahlman, Jr. K5
18 Glenwood Ave.
Oil City, Pa. 16301
i.