Loading...
HomeMy WebLinkAbout99-04868fir; +? !i'; ,' ?? i i i 0 ^- I I I* IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BRIAN TODD YUFER, ........ __.._ Plaintiff Versus GEORGINA ANN YUFER, Defendant 99-9868 N o ......................... ................. I9 DECREE IN DIVORCE AND NOW, ...????uc•?,?er ZI 19 1..., it is ordered and decreed that ....... ......_7 ................................., plaintiff, GEORG a ANN YUFER and ......................................................... . defendant, are divorced from the bonds of matrimony. e 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; s None. ....................................................................... . .............................. .................... r; i• By The ,C? o u r D ? r Attest J, i Prothonotary Y . Vii. !IW <A. .A. +A:. '. rte. .:£• X :6• <5 • W. {W.• IX. •:6• W. it • •:ti IW. {V, .` W. 144 • •.V1 {Ai %. {*i ;41• .:L• ? :V:• :7 V r i i l:? Gtr ?'w?- ??f /sti?a' ? u?I??.-??y BRIAN TODD YUFER, Plaintiff V. GEORGINA ANN YUFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4868 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail on August 13, 1999. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code. By Plaintiff. November 14, 1999 By Defendant: November 12, 1999 4. Related claims pending: None. 5. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: November 14, 1999 By Defendant: November 12, 1999 ' Robert Y. Mulderi squire Attorney for Plaintiff y L) - _ r :. of ,- - i,l i ? I BRIAN TODD YUFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99- IW6? CIVIL TERM GEORGINA ANN YUFER, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Brian Todd Yufer, an adult individual, currently residing at 1348 Grandview Court, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Georgina Ann Yufer, an adult individual, currently residing at 1256 West Poplar Street, York, York County, Pennsylvania 17404. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on October 4, 1997 in York County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since December 23, 1998 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Date Respectfully Submitted TURD LAW OFFICES Robert J. W6lderig, Esquir 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Date ?/ Brian Todd YufeCX? C: t. ? (-; i_l;l C?? I:? _ ` :L I: ?..? J C.i _' 1 BRIAN TODD YUFER, Plaintiff V. GEORGINA ANN YUFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Brian Todd Yufer, Plaintiff, to proceed in forma pauperis. I, Robert J. Mulderig, Esquire, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's Affidavit showing inability to pay the costs of litigation is attached hereto. Date Respectfully Submitted TURD LAW OFFICES Robert J. I derig, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff BRIAN TODD YUFER, Plaintiff V. GEORGINA ANN YUFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. 1 am the Defendant in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending or appealing the action or proceeding. 2. 1 am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct. a. Name: Brian Todd Yufer Address: 1348 Grandview Court Carlisle, Cumberland County. Pennsylvania Social Security Number: 185-62-6768 b. If you are presently employed, state Employer: Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: July 30. 1999 Salary or wages per month: $400.00 Type of work: Building Silos (g_art-time work) C. Other income within the past twelve months Business or profession: None Other self-employment: None Interest: None Dividends: None Pension and annuities: None Social Security benefits: $474.40 per month Support payments: None Disability payments: None Unemployment compensation and Supplemental benefits: None Workman's compensation: None Public Assistance: None Other: None d. Other contributions to household support Wife/Husband Name: None If your Husband/Wife is employed, state: Employer: Salary or wages per month: Type of work: Contributions from children: e. Property owned Cash: Nc Checking Account: None Savings Account: None Certificates of Deposit: None Real Estate (including home): None Motor vehicle: Make None Year Cost Amount owed Stocks; bonds: None Other: f. Debts and obligations Mortgage: None Rent: $70 oer month Loans: None Monthly Expenses: $275.00 g. Persons dependent upon you for support Wife/Husband Name: None Children, if any: Name: -- None Age: Name: Age: Name: Age: 4. 1 understand that I have a continuing obligation to inform the Court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 1 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 unsworn falsification to authorities. Date Brian Todd Yufp , laintiff BRIAN TODD YUFER, Plaintiff V. GEORGINA ANN YUFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL TERM CIVIL ACTION - LAW 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 in divorce or annulment may 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, PA 17013 (717) 249-3166 ?_. i r, ?? ,. u' ?_? i 1 i ?. ..,? ?' ` - if. ti ,_ .. • ?; c ;:) BRIAN TODD YUFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-4868 CIVIL TERM GEORGINA ANN YUFER, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Divorce Complaint filed in the above captioned case upon Georgina Ann Yufer, by certified mail, return receipt requested on August 13, 1999 addressed to: Georgina Ann Yufer 1256 West Poplar Street York, PA 17404 and did thereafter receive same as evidenced by the attached Post Office receipt card dated August 16, 1999. 1 VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURD LAW OFFICES C Date Robert J. MuldVig, Esquire 32 South Bedford Street Carlisle, PA 17013 (717)245-9688 Attorney for Plaintiff r Divorce Complaint Z 452 476 385 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. n.....a ...e In. Inmmainnal Mall /Sae reverse) 4Mftrgina Ann Yufer 6 west Poplar Street York 41F UGS Poda9e $ ..33 Ceased Fee 1.40 Space] Dalivery Fee Restricted Delivery Fee Rem.Recdpl$W.910 WhonaDale Delivered 1.25 Ream Recap Skaeiy b W%M,, Dde, a Addresses Addren TOTAL Postage a Fees $ 2.98 Possnark or Date August 13, 1999 v C C Ca C a e. i U a0 corripwal I VI7M RdW ?. ds9varad. 9. Article I 7 aWa a la additional asMesa. 18180 Wish to too" the 8.49. arld 10. following services (for an and address an tlr rsesres otMN lam es OW w can rerun die utr8 fee):. to the Bore of the mdlplsa. or on the back a span does na 1.0 Addressee's Address . aWp RpuesNd'mdr =1111-11-09 e.bwm.alna. nanees 2. D ReMrkted Delivery w Ma Wvdtam the adss w.s delivered endm.date CrxlatM postmader for fee. used to: ,` 41L Article NtmWer , '` Z 452 476 385 Georg ina Ann Yufer 4b. Service Type 1256 West Poplar Street 0 Registered Certllled York, PA 17404 0 Exprass Map 0 insured , ReNmRsosoforMediandse 0 COD Q 7. Date of Doi ? 0..r j .... 5. Reoelvied By: (Vint Name) S. AddrSWWS Addrep and fee Is paid) aj S.Sigru..._ _.....__. Q, ?( = I PSFoR Lrdll,r4irl.111forr,Irr1,J1 111.11.1.rldrGalrlarfill 191.11 T al =t C? _ .r '. Yl C ll_ C, Gl j O1 J BRIAN TODD YUFER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-4868 CIVIL TERM GEORGINA ANN YUFER, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 12, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in 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. I I - /y-jf u- ? ZxL _ Date Brian Todd Yufer v ' cV S -r :l c ?- ca U BRIAN TODD YUFER, Plaintiff V. GEORGINA ANN YUFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 994868 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER G 33010 OF THE DIVORCE CODE 1. 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 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. ri-/y-25 /lyrru o- D Date Brian Todd Yufer . i CI !f BRIAN TODD YUFER, Plaintiff V. GEORGINA ANN YUFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.99-4868 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 12, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in 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. u °Irl,-n-le,., &AY Ia,1991 ? Date Georgina nn Yufer .! . _. i _ :Iiy r BRIAN TODD YUFER, Plaintiff V. GEORGINA ANN YUFER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4868 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER 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. 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 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. p ?e?ieivla .19 9 Date Georgia Ann Yufer ? SY'1 . ` CJ LJ _ C.1 r LrJ i . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA a (' . T laintiff Vs File No. - ' n IN D VO , _ © 0 cj? Pi Q, A e r li 6 n 'I Defe dant 7M --q T'.'` _ c NOTICE TO RESUME PRIOR SURNAME -?r Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, G? or after the entry of a Final Decree in Divorce dated -L l " q u? l 9 9 / hereby elects to resume the prior surname of nn-- and gives this written notice avowing his / her intention pursuant to e prA(id?S dt P. 704. Date: - - 40/1 Signal #e (?T ? o 'O Signatur of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF C(A-h ) On the N- day of Ck. '200 -, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. 1 3 . Od PGA -/ Prothonotary or Notary Public J C?°? ,? cg5tino- -1 PM Al