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HomeMy WebLinkAbout99-05442IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. +nJ3 k TARA LYNN SCHREINER No. 99-5442 CIVIL TERM pl a' riff VERSUS SAMUEL S. SCHREINER Defendant DECREE IN DIVORCE AND NOW,_4Q'I `/' 2ozo IT IS ORDERED AND DECREED THAT TARA LYNN SCHREINER PLAINTIFF, AND SAMUEL S. SCHREINER ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; BY THE COURT: 411 ATT ST: J N ' PROTHONOTARY • .. TARA LYNN SCHREINER, Plaintiff V. SAMUEL S. SCHREINER, Defendant IN THE COURT OF COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA No. 99 -5442 CIVIL ACTION - DIVORCE PRA ECIPE to TRANSMIT RECORD TO THE PRONTHONOTARY: Kindly 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(c) of the Divorce Code 2. Date and Manner of Service of the Complaint: Personal service on September 16, 1999 by hand delivery by Plaintiff to Defendant's mother at his residence 3. Date of Execution of Affidavit of Consent required pursuant to Section 3301(c) of the Divorce Code: a. By Plaintiff: March 3, 2000 b. By Defendant: March 3, 2000 4. Related Claims Pending: All outstanding economic issues have been resolved between parties outside the above Divorce action 5. Date of Plaintiff's Waiver of Notice in Section 3301(c) Divorce filing with Prothonotary: March 3, 2000 6. Date of Defendant's Waiver of Notice in Section 3301(c) Divorce filing with Prothonotary: March 3, 2000 Respectfully Submitted, THE LAW OFFICES of JOHN M. GLACE n Glace, Esquire Ste ourt I.D. 23933 132-134 Walnut Street, Harrisburg PA 17101-1612 (717) 238-5515 Attorney for Plaintiff r?? c? } L-.. ? _. ?^ h ?, !. ) `' _ (_) l? ? ? ?J .? q ... i ..': _ ci;,u .L L :7 `-= ?? CJ TARA LYNN SCHREINER, Plaintiff vs. SAMUEL S. SCHIREINER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 99 -' q q a CIVIL ACTION - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend yourself 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 in divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the office of the Court Administrator, Fourth Floor, Cumberland County Courthouse, Carlisle, PA. 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 THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO A 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 COURT ADMINISTRATOR'S OFFICE Fourth Floor, Cumberland County Courthouse One Courthouse Square Carlisle, PA. 17013 (717) 240-6200 TARA LYNN SCHREINER, IN THE COURT of COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. SAMUEL S. SCHREINER, Defendant CIVIL ACTION - LAW IN DIVORCE AND NOW this 1- day of September, 1999 comes Plaintiff TARA LYNN SCHREINER, by and through her attorney, John M. Glace, Esquire, and seeks to obtain a Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff TARA LYNN SCHREINER (nee LITTLE) is an adult individual and a citizen of United States, who resides in Cumberland County at a location known to below signed attorney; but who does not wish to disclose her residence location to Defendant. Prior to her July 25, 1999 separation from the Defendant and throughout the course of their marriage, parties resided at 6961 Wertzville Road, Enola Cumberland County, PA 2. The Defendant, SAMUEL S. SCHREINER, is an adult individual who, since the July 25, 1999 separation of parties has resided at 151 Lincoln Avenue, Harrisburg, Dauphin County, PA 17111 3. Plaintiff and Defendant were married by District Justice Charles Clement on August 11, 1997 at Lower Allen Township, Cumberland County, PA 4. Both Defendant and Plaintiff have been continuous residents of the Commonwealth Pennsylvania for more than six (6) months. 5. There have been no prior actions for Divorce or Annulment between parties in Pennsylvania or any other jurisdiction. 6. Defendant and Plaintiff together have had no children. 7. Neither party is a member of the United States Armed Forces nor of any of its allies. 8. Defendant has been advised of the availability of counseling and his right to request that this Honorable Court require both parties to participate in counseling. 9. Plaintiff avers that the marriage is irretrievably broken to Section 3301 (c) of the Pennsylvania Divorce Code, Act 206 of 1990. WHEREFORE PlaintiffTARA LYNN SCHREINER respectfully prays this Honorable Court enter a Decree from the bonds of matrimony RESPECTFULLY SUBMITTED. THE LAW OFFICE of dO11N M. GLACE The Law 001ce of John M. Glace s6Urg, PA VI01-1612 (717) 238-5515 Supreme Court ID11 23933 VERIFICATION The Undersigned hereby verifies that the facts averred in the foregoing Complaint in Divorce are true and correct to the best of her knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A., Section 4904 relating to unsworn falsification to authorities. Date -J0`-z0=&0 2 (.Y1QIL, Tara nn Schreiner or cteyl RIIEI I HEREBY CERTIFY that this"7;4 of September, 1999 1 have served a time and correct copy of Complaint in Divorce by Certified, Return Receipt requested mail upon:: Samuel S. Schreiner 151 Lincoln Avenue Harrisburg, PA 17111 LAW OFFICE of JOIIN M. GLACE Wr3?2 (i c % Esquire 3A nut Sl rcet h g, PA. 17101-1612 (717) 2311.5515 Identillcalion No 23973 Counsel Ibr Plaintiff F., 9) u _d _,zr?\ o ? V :J TARA LYNN SCHREINER, Plaintiff V. SAMUEL S. SCHREINER , Defendant : IN THE COURT of COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 5442 CIVIL ACTION - DIVORCE Affidavit of Consent 1. A Complaint}' Di orce was filed under Section 3301 (c) on and served on 9/ . 2. The marriage of the Plaintiff' and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice 4. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of manage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. I verify that the statements made herein 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 unsworn falsification to authorities. 3?3 f CC _ ?7 C?zP.!/It.e?. Date Tara Lynn Schreiner it Pl c? t__ `_`' '.r _ ?.-; ? J '^ ,? 1 1_^ fl c' ti ??1 -? i., CJ TARA LYNN SCHREINER, : IN THE COURT of COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. SAMUEL S. SCHREINER , No. of 1999 Defendant CIVIL ACTION - DIVORCE Affidavit of Consent 1. A Complaint' Divpreee was filed under Section 3301 (c) on and served on 2F? 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice 4. 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. 5. I have been advised of the availability of marr iage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. I verify that the statements made herein 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 unsworn falsification to authorities. 7^'`- ??"L-JJJ/ Date Samuel S. Schreiner '-- nl L iii ? ?: , N ?r ? _? ' .? • _i L r) . ? (.? ' ? ? % i' ?' _ , i O .J ??? 7 ?, TARA LYNN SCHREINER, IN the COURT of COMMON PLEAS Plaintiff CUMBERLAND COUNTY, V. PENNSYLVANIA No. 99 - 5442 SAMUEL S. SCHREINER, Defendant CIVIL ACTION - DIVORCE Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 33oi (c) of the Divorce Code 1. 1 consent to the entry of a final Decree in 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 that Decree is filed with the Prothonotary. I verify that the statements herein are made 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 unsworn falsification to authorities. 31 3 1 00 ?? CIUz?,inA?L Date Tara Lynn chreiner ? .J 1 _ ..; CL C7` TARA LYNN SCHREINER, Plaintiff V. SAMUEL S. SCHREINER, Defendant IN the COURT of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No, of 1999 CIVIL ACTION - DIVORCE 'Waiver of Notice of intention to Request Entry of a Divorce Decree Under Section 3301 (c) of the Divorce Code 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that 1 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 that Decree is filed with the Prothonotary. I verify that the statements herein are made 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. i 3 66 Date amuel S. S remer ORIGINAL i. JOHN M. GLACE ATTORNEY AT LAW 132-134 WALNUT STREET HARRISBURG, PENNSYLVANIA 17101 ORIGINAL 1 I. I' I FF l TARA LYNN SCHREINER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 5442 V. SAMUEL S. SCHREINER, CIVIL ACTION - DIVORCE Defendant RETURN OF SERVICE The undersigned hereby certifies that, on the date below written , service of the Complaint in Divorce the above-captioned action was made upon Defendant, above named, pursuant to the provisions of Pennsylvania Rules of Civil Procedure, Rules 403 and 404 by mailing the same to said Defendant, at the address set forth below: Lynn Schreiner, Mother of Defendant Samuel S. Schreiner 151 Lincoln Avenue Harrisburg, PA 17111 Defendant SAMUEL S. SCHREINER, since his separation from Plaintiff TARA LYNN SCHREINER has resided with his parents at the above address. After the certified mail, return receipt requested delivery of the Complaint in Divorce was ignored; under- signed attorney personally, by hand delivery, went to above residence and served said Complaint. Service was perfected upon Lynn Schreiner, mother of Defendant. Lynn Schreiner confirmed that Defendant resided with her and that the Complaint would be given to Defendant The undersigned further avers that he is a competent adult individual and that the averments of this Return of Service are true and correct to the best of his personal knowledge, information, and belief. September 16, 1999 DATE OF SERVICE VERIFICATION The Undersigned hereby verifies that the facts averred in the foregoing Return of Service are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A., Section 4904 relating to unworn falsification to authorities. sbk ?J Z2 Date M. Glace, Esquire . , r? Lr) o a. L. ?1J n' ra m Az W ?O J ri[ -' V) '. L v T C;N Z) 0 jonN M. GLACE ATTORNEY AT LAW 132-134 WALNUT STREET HARRISBURG, PENNSYLVANIA 17101 SCHREINER, IN THE COURT of COMMON PLEAS, Plaintiff DAUPHIN COUNTY, PENNSYLVANIA V. No. 99 - 9542- SS1H.Q, SAMUEL S. SCHREINER, Defendant CIVIL ACTION - DIVORCE COMMONWEALTH of PENNSYLVANIA COUNTY of DAUPHIN : ss TARA LYNN SCHREWER, being duly sworn according to law and says that she is the Plaintiff in the above-captioned Divorce Action in which a final Decree from the bonds of matrimony was entered and she hereby elects to resume her prior surname of LITTLE and therefore gives written notice avowing said intention, in accordance with Number 704 of the Act of November 15, 1972, P.L. 1063, 54 Pa. C.S.A. 704 ?Q11, t??-- Ta1'< Lynn Schreiner To be known as: JX7 Tar ynn L' tle Sworn and subscribed to before me this ,;7L4,r j day of 2000 Notry Pub 'c M Commission Expiresi Notarial Sbal Marilyn Cosgrove MOrOSKy. NOIarY Pub,, wPlara Tvro. 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