HomeMy WebLinkAbout99-04639i
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
KRISTINE L. LUTZ
....... ........_............ Plaintiff ....
Versos
RONALD L. LUTZ
Defendant.
No.39-4639.. CIVIL.. TERM
DECREE IN
DIVORCE
AND NOW,... IUo?q,.,,Iv,c1, I•? , , , , . , • 1999.... , it is ordered and
decreed that ...............xR=ST?N.E.L,..WITZ............... plaintiff,
and ...........................RONALq, L...Ly?'Z.............. 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
......................................................................... .
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By The `CC t:
Attest:
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Prothonotary
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KRISTINE L. LUTZ,
Plaintiff
VS.
RONALD L. LUTZ,
Defendant.
N0. 99-4639 CIVIL lax
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court
for entry of a divorce decree:
3301
1. Ground for divorce: irretrievable breakdown under Section (494(c))
3301
WOW of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the complaint: by certified mail,
return receipt requested, deliver to addressee only on August 12, 1999
3. (Complete either paragraph (a) or (b) .)
(a) Date of execution of the affidavit of consent required by Section
.301
-ZH(c) of the Divorce Code: by the plaintiff NovPmhPr 4. 1999
by defendant November 4, 1999
(b) (1) Date of execution of the plaintiff's affidavit required by
3301 '
Section 291(d) of the Divorce Code: ;
(2) Date of service of the plaintiff's affidavit upon the defendant:
4. Related claims pending: Nor p
5. Indicate date and manner of service of the notice of intention to file
33C1
praecipe to transmit record, and attach a copy of said notice under section 29i
(d)(1)(1) of the Divorce Code.
James D. Flower, Jr.
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KRISTINE L. LUTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - DIVORCE
NO. 99 - 4j/ , 7 CIVIL TERM
RONALD L. LUTZ,
Defendant. IN DIVORCE
NOTICE
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 in the
Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania,
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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
(717) 249-3166
FLOWER, FLOWER & LINDSAY
Attorneys for the Plaintiff
fames u. i-iower, ir.,
ID # 27742
11 East High Street
Carlisle, PA 17013
(717) 243-5513
KRISTINE L. LUTZ IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - DIVORCE
RONALD L. LUTZ, NO. 99 - HG 39 CIVIL TERM
Defendant, IN DIVORCE
COMPLAINT
KRISTINE L. LUTZ, Plaintiff, by her attorneys, FLOWER, FLOWER & LINDSAY,
respectfully represents:
1. The Plaintiff is KRISTINE L. LUTZ, who currently resides at 884 Hawthorne
Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055, since September of 1988.
2. The Defendant is RONALD L. LUTZ, who currently resides at 884 Hawthorne
Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055, since September of 1988.
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on October 19, 1985, in New
Cumberland, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties in this or in any other jurisdiction.
2
6. The Plaintiff avers that she is entitled to a divorce on the ground that the
marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of
the Divorce Code.
7. Plaintiff has been advised of the availability of marriage counseling and of the
right to request that the Court require the parties to participate in marriage counseling, and does
not request counseling.
8. Plaintiff requests the Court to enter a decree of divorce.
FLOWER, FLOWER & LINDSAY
Attorneys for the Plaintiff
Date: By
27742
[16-#-
1East High Street
Carlisle, PA 17013
(717) 243-5513
3
VERIFICATION
I, KRISTINE L. LUTZ, hereby verify that the statements made in this Complaint
are true and correct to the best of my knowledge, information and belief. 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.
Stine L. Lutz
Date: 7/,3 ? A 9
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UTZ. IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - DIVORCE
NO. 99 - 4639 CIVIL TERM
RONALD L. LUTZ,
Defendant. IN DIVORCE
CERTIFICATE OF SERVICE
I, JAMES D. FLOWER, JR., Esquire, of the law firm of FLOWER, FLOWER &
LINDSAY, Attorneys, hereby certify that on August 2, 1999, 1 mailed a certified copy of the
Divorce Complaint filed in the above captioned action to Ronald L. Lutz, the Defendant, by United
States Mail, Postage Prepaid, certified return receipt requested, deliver to addressee only, in
Carlisle, Pennsylvania. As evidenced by the signature on the attached certified mail article #Z
013 272 971, said Notice was served on August 12, 1999, on Ronald L. Lutz at 884 Hawthorne
Avenue, Mechanicsburg, Pennsylvania 17055.
FLOWER, FLOWER & LINDSAY
Attorneys for Petitioners
Date: ,1999
c
11 East High Street
._,Carlisle, PA 17013
(717) 243-5513
I.D. #27742
Z 013 272 971
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mail /Sew rauwrsa)
Sent to
Ronald L. Lutz
Street A Number
884 Hawthorne Avenue
Post Otfice, state, 8 ZIP Code
Mechanicsbur PA 170
Postage $ , 5s
Certified Fee V
Special Delivery Fee a - J
Restricted Delivery Fee i - a S
Return Receipt Showing to
Whom 8 Date Dethroned
Reran Recept9o igbWham,
Dam, B Addressee's Address
TOTAL Postage 8 Fees $
Postmark or Date
8/2/99 certified copy
of Divorce Complaint
5
S SENDER: I also wish to receive the
s
i • Complete Items l and/or 2 for additional services.
• Complete hems 3, 4a, and 4b. following services (for 80
B
• Print your name and address on the reverse of this form so that we can return thte extra fee):
card to you.
Atttach this form to the front of the mailpiece, or on the back it space does not
e
1. ? Addressee's Address
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•Wmet'Refum Recelpf Reciussled- on the mailpiece below the article number.
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• The Return Receipt will show to whom the article was delivered and the date n
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3. Article Addressed to:
Ronald L. Lutz
884 Hawthorne Avenue
Mechanicsburg, PA 17055
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3811,
4b. Service Type E
? Registered Gj Certified
? Express Mail p t ? Insured it
? Return Race' 1®h robe ' ?S COD
7. Date of D 9
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8. Addresse ddress ( /,Qa uttered
and lee is `•
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102595.98-8a Domestic Retum Receipt
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KRISTINE L. LUTZ,
Plaintiff,
VS.
RONALD L. LUTZ,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 99 - 4639 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
KRISTINE L. LUTZ, Plaintiff, being duly sworn according to law, deposes and
says:
1. That a Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on August 2, 1999.
2. That my marriage with RONALD L. LUTZ, Defendant, is irretrievably broken.
3. That I consent to the entry of a Decree in Divorce on the grounds that the
marriage is irretrievably broken.
4. That I understand that I may lose rights concerning alimony, division of
property, counseling fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true and correct to the best of
my knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn talsification to authorities.
11-'i '
Date:
UJ _
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KRISTINE L. LUTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - DIVORCE
NO. 99 - 4639 CIVIL TERM
RONALD L. LUTZ,
Defendant. IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER 3301
OF THE DIVORCE CODE
I consent to the entry of a Final Decree of 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 the false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating
to unsworn falsification to authorities.
Kristine L. Lutz, Plain
Date: //- '/- 9 '-/
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KRISTINE L. LUTZ,
Plaintiff,
VS.
RONALD L. LUTZ,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 99 - 4639 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
RONALD L. LUTZ, Defendant, being duly sworn according to law, deposes and
says:
1. That a Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on August 2, 1999.
2. That my marriage with KRISTINE L. LUTZ, Plaintiff, is irretrievably broken.
3. That I consent to the entry of a Decree in Divorce on the grounds that the
marriage is irretrievably broken.
4. That I understand that I may lose rights concerning alimony, division of
property, counseling fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true and correct to the best of
my knowledge, information and belief. 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: 1115 11
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KRISTINE L. LUTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - DIVORCE
NO. 99 - 4639 CIVIL TERM
RONALD L. LUTZ,
Defendant. IN DIVORCE
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. 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 the false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating
to unsworn falsification to authorities.
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