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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
a
RITA MARIE SEIBERT,
Plaintiff
No. 99-4873 CIVIL TERM
VERSUS
JAMES EDWARD SEIBERT,
Defendant
DECREE IN
DIVORCE
AND NOW,g "i J 1! 2007-, IT IS ORDERED AND
DECREED THAT
Rita Marie Seibert
PLAINTIFF,
AND James Edward Seibert 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 COURT:
ATTE J.
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PROTHONOTARY
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RITA MARIE SEIBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0. 99-4873
VS.
JAMES EDWARD SEIBERT,
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
CIVIL 19
Transmit the record, together with the following information, to the court
for entry of a divorce decree:
b&k
1. Ground for divorce: irretrievable breakdown under Section (284(c4)
33oi
(39i(d) (1) of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the complaint :_?p mtr i? 2001
by C'n f "ble
3. (Complete either paragraph (a) or (b) .)
3301 (a) Date of execution of the affidavit of consent required by Section
z^frl(c) of the Divorce Code: by the plaintiff N/A
;
by defendant
(b) (1) Date of execution of the plaintiff's affidavit required by
33ot
Section-24M(d) of the Divorce Code: 12/26/00
(2) Date of service of the plaintiff's affidavit upon the defendant:
4. Related claims pending: None
5. Indicate date and manner of service of the notice of intention to file
praecipe to transmit record, and attach a co 33o+
py of said notice under section 404
(d)(1)(i) of the Divorce Code, oi,.,,,,
dL ) tip: ?
Attorney for (Plaintiff) /
090940944)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
JAMES EDWARD SEIBERT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NO. 98-4873 CIVIL
NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE
TO: JAMES EDWARD SEIBERT. Defendant
You have been sued in an action for divorce. You have failed to answer the complaint or file
acounter-affidavittothePlaintifrsaffidavit. Therefore. onorafterOctober 1,2001,orthe2lstday
following service of this Notice on you, whichever occurs later, the Plaintiff can request the Court
to enter a final decree in divorce.
If you do not file with the prothonotary of the Court an answer with your signature notarized
or verified or a counter-affidavit by the above date, the Court can enter a final decree in divorce.
Unless you have already filed with the Court a written claim for economic relief, you must do so by
the above date or the court may grant the divorce and you will lose forever the right to ask for
economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE COURT
IS ATTACHED TO THIS NOTICE.
UNLESS YOU HAVE ALREADY FILED WITH THE COURT A WRITTEN CLAIM
FOR ECONOMIC RELIEF, YOU MUST DO SO BY THE ABOVE DATE OR THE COURT
MAY GRANT THE DIVORCE AND YOU WILL LOSE FOREVER THE RIGHT TO ASK
FOR ECONOMIC RELIEF. THE FILING OF THE FORM COUNTER-AFFIDAVIT
ALONE DOES NOT PROTECT YOUR ECONOMIC CLAIMS.
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
Phone (717) 249-3166
or
1-800-990-9108
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MICHAEL J. HANFT
' ATTORNEY & COUNSELLOR AF LAW
19 BROOKWOOD AVENUE SUITE. 106 CARLISLE, PA 17013-9142
717249.5373 FAX 717.2420457
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CbUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT,
Defendant
NO. 99- -?,P7,3 CI vt l ! a
NOTICE TO DEFEND AND CLAIIA 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 borne 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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
IN THE. COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
RITA MARIE SEIBERT.
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-
Defendant
COMPLAINT IN DIVORCE
AND NOW, this 12" day of August, 1999 comes Plaintiff, Rita Marie Seibert, 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 Rita Marie Seibert, who currently resides at 413 5'h Street,
Summerdale, Cumberland County, Pennsylvania.
2. The Defendant is James Edward Seibert, who currently resides at Wayne Hotel, 25
South 4'h Street, Harrisburg. Dauphin County, Pennsylvania.
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 September 23, 1977 in Dauphin County, 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 him,
the injured and innocent spouse, as to render his condition intolerable and his life burdensome. The
foregoing facts are averred and brought under Section 3301(a)(6) of the Divorce Code of 1980, as
amended.
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.
Respectfully submitted,
4'AU:?el J. Han, Ey ire
Attorney ID No. 57 76
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorney for Plaintiff
Verification
I verify that the statements made in the foregoing Complaint in Divorce are true and correct
to the best of my knowledge, information and belief. This Verification is made by Plaintiffs counsel
based upon information provided by Plaintiff to Plaintiffs counsel regarding the factual avennents
contained herein. 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.
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Mich el J. Hanft, Esq re
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TIMOTHY L. SHIRK
PA. STATE CONSTABLE
. ..:' e• v . . .!: L. M1pMjOkN? UMWMR,4MNr .. .,
P.O. BOX 421 - 217A S. HARRISON ST. - PALMYRA, PA. 17078 - USA
Phone 717-554-2833 - Home Phone 717.838-9146
INVOICE
DATE: 9/24/01
TO: LAW OFFICE OF MICHAEL J. HANFT
19 BR90KWOOD AVE. SUITE 106
CARLISLE. PA. 17013-9142
DATE nccnoisr?n., ..?
9/11/01 SERVICE OF DIVORCE COMPLAINT
SERVICE OF PLAINTIFF'S AFFIDAVIT
SERVICE OF NOTICE OF INTENTION TO FILE
ON DEFENDANT JAMES EDWARD SEIBERT
$ 35.00
$ 35.00
MILEAGE 72 $.34 $ 24.48 $ 24.48
3 HOURS $10.00 PER HR. $ 30.00 $ 30.00
DATE: 9111/01
TIME: 8:15 AM
LOCATION: UNI-MART
SECOND ST., WEST FAIRVIEW, PA. 17025
BY: TIMOTHY.L SHIRK
SUB TOTAL $89.48
PAYMENTS
GNATURE TOTAL $89.48
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-4873 CIVIL
Defendant
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-
affidavit within twenty (20) days after this affidavit has been served on you or the statements will
be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. The parties to this action separated on February 15, 1982 and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division ofproperty, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom
falsification to authorities.
Rita Marie Seibe , Plaintiff
n use FnldetlFi= NC$,G0nd0C$2W \1013.1 aRJavil Ilald%Pd
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-4873 CIVIL
Defendant
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
SS.
COUNTY OF Cb- )
D hlu
1. A Com taint in divorce under Section 3301(c) of the Divorce Code was filed on
August 12, 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. coo
Date: L'- -=- G
Rita M. Seibert, Plaintiff
Sworn to and subscribed before me this
y* day of 9 J ?"o2000
Not 61 Public J Notarial Seal
Judith A. Geyer, Notary Public
Fiu.FuldWT,.. DOCtlGeMa,904UrL?Ni w?ivm Harrisburg, Dauphin County
My commission Expires Sept. 24, 2000
Member. Pennsylvania Association of Notaries
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-4873 CIVIL
Defendant
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 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 unworn
falsification to authorities.
Date: 1 "N - z UV
Rita M. Seibert, Plaintiff
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LAW Or-FICr OF MICHAEL J. HANFT
AT'roltNrvS & CouNsrrrolts AT LAw
19 BROOKWO01i Aviwi tiurn 100 CAM mr, PA 17013-9142
717.249.5373 Ax 717.2-19,0457 N'ww.11ANb11.MV111W.COM
IN 7 HE CUUK I OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-4873 CIVIL
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce that was filed in this matter.
LAW OFFICE OF MICHAEL J. HANFT
Date: January 8, 2001 By:
Michael J. Han squlr
Attorney 1. D. No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
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LAw OFFICE OF MCCHAR J. HANF-r r
ATl'ORNEYS & COUNSELLORS Ar LAw
19 BROOKWOOD AvI NUI' SUITI 106 CAM.ISH. PA 17013-9142
717.249.5373 rAX717.2420457 WWWAIANI'71.AMIRM.COM
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-4873 CIVIL
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce that was filed in this matter.
LAW OFFICE OF MICHAEL J. HANFT
Date: June 26, 2001 By:_
Michael J. Han , Esquire
Attorney I.D. No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
JAMES EDWARD SEIBERT,
Defendant
NO. 99-4873 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce that was filed in this matter.
Date: / 4 -7 1
LAW OFFICE OF MICHAEL J. HANFT
By: 'L w -
Richard L. Webber, Jr., Esquire
Attorney I.D. No. 49634
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT,
Defendant
NO. 99-4873 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce that was filed in this matter.
I l
Date:
LAW OFFICE OF MICHAEL J. HANFT
By: e-L
Richard L. Webber, Jr., Esqu}
Attorney I.D. No. 49634
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
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717.249.5373 M717.249.0457
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-4873 CIVIL
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce that was filed in this matter.
LAW OFFICE OF MICHAEL J. HANFT
Date: November 30, 2000 By:
Michael J. Hanft, squire
Attorney I.D. No. 57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
F:Ws rFuWnTimil s?Gcndon'AW?1013-Ipre iM i %1?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
JAMES EDWARD SEIBERT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NO. 99- IIP-13 0110d
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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
TRUE CORY FROM RECORD
in Testimony whereof, I harp unto set my hano
and the seal of said Court at Carlisle, Pa.
rlti ay
0 othonotary
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCE
JAMES EDWARD SEIBERT, NO. 99-
Defendant
COMPLAINT IN DIVOR E
AND NOW, this 12" day of August, 1999 comes Plaintiff, Rita Marie Seibert, 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 Rita Marie Seibert, who currently resides at 413 5ih Street,
Summerdale, Cumberland County, Pennsylvania.
2. The Defendant is James Edward Seibert, who currently resides at Wayne Hotel, 25
South 41h Street, Harrisburg, Dauphin County, Pennsylvania.
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 September 23, 1977 in Dauphin County, 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 him,
the injured and innocent spouse, as to render his condition intolerable and his 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.
Respectfully submitted,
4 Mi ael I Han , E ire
Attorney ID No. 57 76
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorney for Plaintiff
Verification
I verify that the statements made in the foregoing Complaint in Divorce are true and correct
to the best of my knowledge, information and belief. This Verification is made by Plaintiffs counsel
based upon information provided by Plaintiff to Plaintiffs counsel regarding the factual avennents
contained herein. 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.
Mich el J. Hanft, Esq re
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IN
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff No. 99 - 4873
V. CIVIL ACTION - LAW
JAMES EDWARD SEIBERT, IN DIVORCE
Defendant
CERTIFICATE OF SERVICE
AND NOW, this 12th day of August, 2002, I, Lindsay Gingrich Maclay, Esquire, hereby
certify that the following person was served with a copy of the Defendant's Counter-Affidavit under
Section 3301(d) and with a copy of the Notice to Request Entry of a Divorce Decree in the above-
referenced matter. These documents were mailed on August 12, 2002, with a Proof of Mailing.
These documents were mailed in the United States Mail, Proof of Mailing Requested, Postage Pre-
Paid, addressed as follows:
Mr. James Edward Seibert
1707 North 4th Street
Harrisburg, Pennsylvania 17110
A copy of the signed Certificate of Mailing is attached hereto as Exhibit "A" and by
reference incorporated herein and made a part hereof. A copy of the Freedom of Information Act
Form indicating that the above-referenced address is, in fact, Defendant's address, is attached
hereto as Exhibit "B" and by reference incorporated herein and made a part hereof.
Respectfully submitted,
HANFT & KNIGHT, P.C.
{ J
By:
chael J. . Esquire
Attorney I.D. No. 57976
Lindsay Gingrich Maclay, Esquire
Attorney I.D. No. 87954
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorneys for Plaintiff
E\Ufa FoWa FiM 1Txfta")".'N3VU1 Y 1 am %v% %Pd
Exhibit "A"
U .S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE - POSTMASTER
Rm,,oE From:
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One pece of ordnary mail adoresseo to,
Mr, I3alnes Edrrard c3et6erj
1707 North Yd, .. +reet
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PS Form 3817, Mar. 1989
Exhibit "B"
HANFT & Kmu-rr' I :C.
Arl'011NCYS & Co tjNSI l I()RS AI LAW
August 2, 2002
W11 I.IAM A. ADDAMS
MICHAEI. 1. HANFT
Gw0. stmt' 1-1. KNIGHT
I INIINAY CIINGRICII MACLAY'
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Postmaster
Uptown Station
2347 North 7th Street
Harrisburg, Pennsylvania 17110
Rrrlnost for Change of Address or Boxholdor
Information Needed for Service of Legal Process
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: James Edward Seibert
Address: 1707 North 4th Street Harrisburg Pennsylvania 17102
NOTE: The name and last known address are required for change of address information. The name, if known, and post
office box address are required for boxholdcr inforn ation.
The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee
for providing boxholder in formation. The fee for providingchange of address information is waived
in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual
352.44a and b.
Capacity of requester (e.g., process server, attorney, party representing himself): Attorney
2. Statute or regulation that empowers the to serve process (not required when requester is an
attorney or a party acting pro se - except it corporation acting pro se must cite statute): N/A
3. The names of all known parties to the litigation: James E Seibert. Defendant and Rita M.
Seibert. Plaintiff
4. The court in which the case has been or will be heard: The Court of Common Pleas of
Cumberland County. Pennsylvania
5. The docket or other identifying number if one has been issued: Docket Number 99-4873
CIVII,fIn ivorcc)
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6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant
WARNING
THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE
OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION INFORMATION FOR ANY
PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH
ACTUAL OR PROSPECTIVE LITIGATION OR (2) TO AVOID PAYMENT OF THE FEE FOR
CHANGE OF ADDRESS INFORMATION COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF NOT MORE THAN 5
YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be
used solely for service of legal process in connection with actual or prospective litigation.
S'gnature
Hanft & Knight, P.C.
19 Brookwood Avenue. Suite 106
Address
Lindsay Gingrich Maclay, Esquire
Printed Name
Carlisle. Pennsylvania 17013-9142
City, State Zip Code
FOR POST OFFICE USE ONLY
- No change of address order on file.
- Not known at address given.
- Moved. left no forwarding address.
No such ddress.
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NEW ADDRESS or BOXHOLDER'S POSTMARK
NAME and STREET ADDRESS
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
V.
JAMES EDWARD SEIBERT,
Defendant
No. 99 - 4873
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 section 3301(d) of the divorce
code.
2. Date and manner of service of the Complaint: September 10, 2001 by Constable
3. (b)(1) Date of execution of the Plaintiff's Affidavit required by section 3301(d) of
the Divorce Code: December 26, 2000
(b)(2) Date of service of the Plaintiff's Affidavit upon the Defendant: September 10,
2001
4. Related claims pending: None
5. Indicate date and manner of service of the Notice of Intention to file Praecipe to
Transmit Record, and attach a copy of said Notice under section 3301(d)(1)(i) of the
Divorce Code: August 12, 2002, via United States Mail, Proof of Mailing requested.
HANFT & KNIGHT, P.C.
Date: `?4}1GYN 1? 10,1DOZ,
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By
/Lindsay ich clay, Esquire
Attorney I.D. No. 87954
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013-9142
(717) 249-5373
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RITA MARIE SEIBERT,
Plaintiff
CIVIL ACTION - LAW
V. IN DIVORCE
JAMES EDWARD SEIBERT, NO. 98-4873 CIVIL
Defendant
NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE
TO: JAMES EDWARD SEIBERT, Defendant
You have been sued in an action for divorce. You have failed to answer the complaint or file
a counter-affidavit to the Plaintiffs affidavit. Therefore, on or after the 21st day following service
of this Notice on you, the Plaintiff can request the court to enter a final decree in divorce.
If you do not file with the prothonotary of the Court an answer with your signature notarized
or verified or a counter-affidavit by the above date, the Court can enter a final decree in divorce.
Unless you have already filed with the Court a written claim for economic relief, you must do so by
the above date or the court may grant the divorce and you will lose forever the right to ask for
economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE COURT
IS ATTACHED TO THIS NOTICE.
UNLESS YOU HAVE ALREADY FILED WITH THE COURT A WRITTEN CLAIM
FOR ECONOMIC RELIEF, YOU MUST DO SO BY THE ABOVE DATE ORTHE COURT
MAY GRANT THE DIVORCE AND YOU WILL LOSE FOREVER THE RIGHT TO ASK
FOR ECONOMIC RELIEF. THE FILING OF THE FORM COUNTER-AFFIDAVIT
ALONE DOES NOT PROTECT YOUR ECONOMIC CLAIMS.
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
Phone (717) 249-3166 or
1-800-990-9108
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RITA MARIE SEIBERT, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
JAMES EDWARD
SEIBERT,
Defendant NO. 99-4873 CIVIL TERM
ORDER OF COURT
AND NOW, this II1h day of October, 2001, upon consideration of Plaintiffs
praecipe to transmit record, and it appearing that Plaintiffs notice of intention to file
praecipe to transmit record was served simultaneously with Plaintiffs affidavit under
Section 3301(d) of the Divorce Code, in contravention of the holding in Burdick v.
Burdick, 41 Cumberland L.J. 64 (1991) (Bayley, J.), a divorce decree will not be entered
at this time, without prejudice to the parties' right to correct the deficiency and file a new
praecipe to transmit.
BY THE COURT,
Michael J. Hanft, Esq.
19 Brookwood Avenue
Suite 106
Carlisle, PA 17013
Attorney for Plaintiff
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