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HomeMy WebLinkAbout99-04905 i Iz l i i y e ii XV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Doris Aungst-Storms, .......................... ..................................................... Plaintiff N o.9! ,- . 49,95......... 19 Vm•sus II Bruce K. Storms, _ ......................... -. .........Defendant ......... .I DE CRE E IN DI VO RC E AND NOW, .... `. 1f • .. { ...... 19.99... , it is ordered and decreed that ...... Doris• Aungst-storms......................... plaintiff, and ....Bruce K. Storms ...... ............... 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..... rx.. ex. r* • •Ar +&;• By The o rt: f Attest: J. Prothonotary ' I j v e i ti •r , _N IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA - Cumberland County Doris Aungst-Storms, • Civil Action -Law Plaintiff vs. No. 99 - 4905 Bruce K. Storms, Defendant In Divorce a v.m. 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(d) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant on September 1, 1999. 3. Date of execution of plaintiffs affidavit required by Section 3301(d) of the Divorce Code: July 30, 1999. Date of filing of the affidavit: August 13, 1999. Date of service of the plaintiffs affidavit upon the defendant: September 1, 1999. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to request entry of divorce decree, a copy of which is attached, if the decree is to be entered under Section 3301(d)(1)(i) of the Divorce Code: personal service by the undersigned attorney on September 23, 1999. e A. McCracken ttorney for Plaintiff Date l_ M ? Z LC i- --n r? ?Li m U IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY Doris Aungst-Storms, Plaintiff Civil Action - Law vs. Bruce K. Storms, Defendant = 1999 - ,119CA5 In Divorce a v.m. 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 in the office of the Prothonotary Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE TIC 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. Pennsylvania Bar Association - Lawyer Referral Service Telephone 1-800-692-7375 (PA ONLY) or (717) 238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Doris Aungst-Storms, Civil Action - Law Plaintiff VS. IAA. 94_ -/9o5 &1?j *r" Bruce K. Storms, Defendant In Divorce a v.m. COMPLAINT NOW COMES the plaintiff and for cause of action against the defendant says: COUNT ONE DIVORCE - SECTION 3301(d) Plaintiff is Doris Aungst-Stones, who resides at 756 Arlington Road, Camp Hill, Cumberland County, Pennsylvania since June of 1997. 2. Defendant is Bruce K. Storms, who resides at 406 East Old York Road, Cumberland County, Pennsylvania since 1985. 3. Plaintiff has been a bona fide resident of 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 May 25, 1980 in Chambersburg, Franklin County, Pennsylvania. 5. There has been no prior action for divorce or annulment between the parties. 6. The parties to this action separated in May of 1996 and have continued to live separate and apart for a period of at least two years. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, A. McCracken Attorney for Plaintiff I verify that the statements made in this complaint 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. Da Doris Aungst-Storms -1 17? V _ `J V? IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA - Cumberland County Doris Aungst-Storms, Civil Action - Law Plaintiff VS. Bruce K. Storms, Defendant In Divorce a v.m. NOTICE TO THE 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 or before May 7, 1996 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 of property, 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. Section 4904, relating to unworn falsification to authorities. Date ?- Aungst-Storm Date Doris _ I!' _ ? ? ; = j ?.. ? . IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA - Cumberland County Doris Aungst-Storms, Civil Action - Law Plaintiff vs. F.R. 99- .4146S Bruce K. Storms, Defendant In Divorce a v.m. DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE I. Check either (a) or (b): r/ (a) I do not oppose the entry of a divorce decree. _(b) I oppose the entry of a divorce decree because: Check (i), (ii) or both: -(i) The parties to this action have not lived separate and apart for a period of at least two years. _(ii) The marriage is not irretrievably broken. 2. ; Check either (a) or (b): ? (a) I do not wish to make any claim for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter-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: j - 323 -72 6A-z,I A Alzr .,_ Bruce K. Storms NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not rile this Counter-Affidavit. t== Lu CD u _ G c'n =ti o+ Z3 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA - Cumberland County Doris Aungst-Storms, Civil Action - Law Plaintiff VS. No. 99 - 4905 Bruce K. Storms, Defendant In Divorce a v.m. ACCEPTANCE OF SERVICE NOW, this day of SeFrr, e E rL , 1999, I, Bruce K. Storms„ Defendant above, hereby accept service of the Complaint in Divorce filed Aug. 11 1999 in the above case, and acknowledge receipt of a true and attested copy of said Complaint. Bruce K. Storms Defendant t I U ?= J " r? 6~ G} __l C? IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA - Cumberland County Doris Aungst-Storms, Plaintiff • Civil Action -Law vs. No. 99 - 4905 Bruce K. Storms, Defendant In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE TO: DEFENDANT, Bruce K. Storms: You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after October 18, 1999, 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. A counter-affidavit which you may file with the prothonotary of 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. Pennsylvania Bar Association Lawyer Referral Service Telephone 1-800-692-7375 (PA ONLY) or (717) 238-6715 > !n LJ i- n=Z i ti?a o rn U