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Home My WebLink About99-06456 * 4 yY 1 J? 4 . `Y X ? Y ' " 5 1 „ ? E ?A 4 ` x ky 1 F k5 } ? d 3 [ ?y.'. A j 4 H? is x p ? Y 4t i? ? k s' 'F t t ? ' ? . Y f 5 Py d? F L C 6" .aF t A ?Y t ?' S. ,?yy s ? S W 3.r L1 Y i lx4 "F R>S t ? \ \ \ ? I IF sb rf rx ? 'r? i` x L y re l F ?fyA sf , ? .?? XA'J Fl- a f}ty Y n k. : I ? k? J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. s n? a D., . TERESA V. ERA N O. 1999-6456 VERSUS TIM0T11Y R. ERR DECREE IN DIVORCE AND NOW, -e+,ACCi/ 2000 IT IS ORDERED AND DECREED THAT TERE SA V. ERR , PLAINTIFF, AND TIMOTIIY R. ERR 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; nojvr BY THE COURT: , ArrE J. ROTHONOTARY r 3 ?> ear Z S 40 Y{Lf d i i s \i Ij (ry IY at+ S ? FL 1 t , to Y t kn Y Y i t ?LIwAl . l?4? yy _ AM TERESA V. ERB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 1999-6456 Civil TIMOTHY B. ERB, IN DIVORCE Defendant TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievably broken under Section (XX) 3301 (c) or ( ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint: Certified Mail on October 27, 1999. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, March 11, 2000; by Defendant, February 22, 2000. (b) Date of execution of Plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: N/A date of service of Plaintiffs affidavit upon Defendant: N/A. 4. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: N/A. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff: simultaneously herewith; by Defendant: simultaneously herewith. ti 5. Related Claims Pending: None BY: Diane M. Rupich, s re (717) 232-9724 Attorney for (xx ) Plaintiff ( ) Defendant sR ?'ftv y: ?y GKt gx K?3 s` 4. x?: C7 i ul ? 17.x: t1" 14 w. CZ) V C:V fJ. s 9 1 4 "`yam u ' uj 1.4 V C; ?Jl a? N N N U U a1 a. V "v M r1i \. % ?o as a w it P y 44 .4 r. m _ a G zz 41 a U"W n a = w W. , i W Q a c >MU 0 >4 v M (a H M W C.) H 0 ' a a zU a 0 0 w W H H 0 EE U > ?' E U I>1 a 0 z > z W G 33 A >4 x 94 a o w c E w ? 00 xw E m a uz H F o z? o H TERESA V. ERB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND CO// UNTY, PENNSYLVANIA vs. No. 99- to ?/A TIMOTHY B. ERB, CIVIL ACTION - LAW Defendant 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 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. 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 T IE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKEI TI IIS 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 OUI' WI IERE YOU CAN GET' LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA. 17013 (717) 249-3166 1-800-990-9108 TERESA V. ERB, Plaintiff vs. TIMOTHY B. ERB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. The Plaintiff is Teresa V. Erb, an adult individual who currently resides at 842 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17020 and whose social security number is 174-54-0828. 2. The Defendant, Timothy B. Erb, is an adult individual, who currently resides at 123 South York Street, Etters, York County, Pennsylvania 17319, and whose social security number is unknown at this time. 3. Plaintiff and Defendant were married on September 23, 1989 in York, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff and Defendant are both citizens of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are two children born of the marriage. -2- 10. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, DILS & RUPICH BY: 1017 North Frodt Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 -3. I verify that the statements made In this are true and correct. I understand that false stco,mPlaint in atements herein aree made subject to the penalties of 18 PA, C.S. Section 4904 relating to unsworn falsification to authorities. DATE: O@tober 10, 1999 Teresa V. P•.Rb ?Nr2 F ?E s= r o. } Fy Cl) r tt?uC?? 3 - F+ F l O, lfl .;i /n JJ ?k•i Z 1' ``t ? ll tU C) 0 N a a w a J g O i . ? +?t C C N S > U 44 ° W z a • C aUH -v w v " m t: u s a ON H R a a cn 7. •- x W > N k H U ? a Z' W ° W f+ H TERESA V. ERB, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 1999-6456 Civil TIMOTHY B. ERB, IN DIVORCE Defendant 1, Diane M. Rupich, Esquire, hereby certify that a true and correct copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code was served upon the Defendant, Timothy B. Erb, by First Class, United States, Certified Mail No. Z 569 114 904 at his address of 123 South York Street, Etters, York County, Pennsylvania 17319. Attached hereto is the return receipt card executed by Timothy B. Erb, evidencing receipt of the same and dated October 27, 1999. _-__ . 11 i l iane . Rup quire (717) 232-9724 I.D. No. 71873 March 14, 2000 I? I I? I 1 i 1 I SENDER: Ms norm t actor 7 for ¦dauaw wwaa 1 Woo wlslt to roe" tla sCom mar 3.446 Wd s0. following services (for an ¦? pnnrm ad sOdms m ft nww of 9* lorm a mrrs an MOm ode pMfN): ¦Ansdt wsbrm to ro 1ron1 of ft m¦kWM or an go b¦d n OM don M 1. 0 AddronoWs AddmN ¦ AwnRtW flog¦asewthermkkmbelow fmannismft" 2.OllestrkisdDoMry I ¦ frtu RsoWwaaowMwlrmersurdswasdshersdadItodtls The CoraWtpxtrnssisrIce1N. /70f 0//,y 6- ?.eh ?3 joe,.14 y`r 1t C.eS /1/7317 5.R I 8.8 i? PSI 4a. ArWe Number z G9 /r 9a I eb. rvke Type O Registered GYCfrAAed O Express Mall O Insured O PAMNOWformoolrrdn O COD D D W 7. ate o ary /c-Z7-'11, S E" 0. Addrsases's Address (Or# d requosled and roe Is raid) MEMO TERESA V. ERB, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs. No. 1999-6456 TIMOTHY B. ERB, DIVORCE Defendant 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 22, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final Decree in Divorce. 4. 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. 5. I have been advised of the availability of marriage counseling, and being so advised, I do not request that the Court require my spouse and myself to participate in marriage counseling. I verify that the statements made in this affidavit are true and correct. 1 understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date: 3 I it I o o wu'-'? VN Teresa V. Erb, Plaintiff TERESA V. ERB, Vs. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY B. ERB, Defendant NO. 1999-6456 CIVIL ACTION - LAW IN DIVORCE 1. 1 consent to the entry of a final Decree in 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. 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 Waiver are true and correct. 1 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: 31 1116 o .r?ww V`_ 0- Teresa V. Erb, Plaintiff 0 TERESA V. ERB, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs. No. 1999-6456 TIMOTHY B. ERB, DIVORCE Defendant 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 22, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final Decree in Divorce. 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 marriage counseling, and being so advised, i do not request that the Court require my spouse and myself to participate in marriage counseling. I verify that the statements made in this affidavit are true and correct. l understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date: re 6 U 00/,7 /" - A. f Timothy B. trb, Defendant f x : E..r? att. ,t a'?.. •!t. ? F _ ! ? :2:2 ? Itas. v if k 5 TERESA V. ERB, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. TIMOTHY B. ERB, Defendant NO. 1999-6456 CIVIL ACTION - LAW IN DIVORCE 1. I consent to the entry of a final Decree in 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. 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 Waiver 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. Date: ra--6 coca ?., 8 Ed Timoth, Defendant as" N 5; ? p . CJ ;r a S v ? a ? " ? t