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HomeMy WebLinkAbout99-0675711 C-9 .J j ? I N J N S I I °? 1 .7 ?.9 0 :ey CeY •;e:• 'y:• W. •;e:• c, :.:e:•- :e:•?;e`Ve: •;e?..v:- Ce> :.>?:e?.-tia: ;e:•. t. ti IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PENNA. e, i ?S PLEAS i _ ._. 6757 Civil 1999 c t ........................ CHARLES R. UHRICH •i j SANDRA L. UHRICH of •°-ll DE CRE E 'r D /V0 R el fi e s e w A t Y IN C E q; or A.M i 0 is • • • , it is ordered and AND NOW, ....C• ?- ?• - • • • • • . )4(fn CHARLES, •R. -UHRICH decreed that , , • _ • • . • , , • _ , • , , • ...., Plaintiff, ............ and • • • • - • • .. • • - SANDRF? ,L; • UFIRICII ..... _ .. , • , • , , . , defendant, i 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 o been entered: e NONE l ..... ... ............................... ............................. j4 By The Alt est. .... ?. __. J• T f . Prothonotary 10 1. 4,. ?e..;e:• Ce} {e} .V, (e - ce:? W. ;e:• .V. <o:• W. -.47- :e:• -W.- %o:• :e} :e:.._ W. {ei •:c: :e:• iei :e> <e:- <e:• [e:• <?: 4-) Ila" CF'APLES P.. U!'PICE VS. SArF)PA I. G!IPICV IN THE COURT OF CONDION PLEAS OF CG:MER1,.VMD COUNTY, PENNSYLVANIA 19(?7 NO. 67 57 CIVIL -n.Rf?t PR,1E•CIPE TO 'LILLV5:4IT 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 QK(s)-) 3301(c) g(t?gl{dk>$L) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: 11/?/SD certified rail, restricted delivery, return receipt reruestec 3. (Complete either paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required by Section 3301 201(c) of the Divorce Code: by the plaintiff 10/16/0..^, ; by defendant 11/01/00 (b) (1) Date of e:cecution of the plaintiff's affidavit required by Section 201(d) of the Divorce Code (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 copy of said notice under section 201 (d)(1) M of the Divorce Code. P. Fichard I'icrer, °so.(Der p?latcL) • _AN tr E: c?S? N tF,LLI Cn ,a i Y ? n? 4 5r ?. II ? ? V6 v ? r;. ` q 2 J 3 W ?: W 3U ? 2 z N ^ L I L } 1 CHARLES R. UHRICH, Plaintiff, V. SANDRA L. UHRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. -7 CIVIL ACTION - LAW IN DIVORCE 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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, 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 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 CHARLES R. UHRICH, V. Plaintiff, SANDRA L. UF[RICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, CHARLES R. UHRICH, by and through his attorneys, Mancke, Wagner, Hershey & Tully, and files the following Complaint in Divorce: 1. The Plaintiff, CHARLES R. UHRICH, is an adult individual currently residing at 177 Spring Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, SANDRA L. UHRICH, is an adult individual currently residing at 835 Longs Gap Road, Carlisle, Ct niberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on December 10, 1991, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any otherjurisdiction. 6. Neither Plaintiff nor Defendant are members of the Anicd Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the availability of counseling and that he has the right to request that the Court require both parties to participate in counseling. 8. The Plaintiff avers as grounds on which this action is based are: It. That the marriage is irretrievably broken; and b. That as of January 1, 2001, the parties will have lived separate and apart for a period of at least two (2) continuous years. _2. ?R1R? d7imwh?'C?PXS_L w1Y4'Y rc ? n.;-?_T -'LTrtL.:•?Cfc ?^"•C?=ttSfr'?2C-"', L?°. ..•v ra?4? WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. Respectfully submitted, Mancke, Wagner, Hershey & Tully P. Richard Wa?dier, Esquire I.D. #23103 ,-)2-33-North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: -3- c .' -cwnee?+--?-+-- -..__.,.,:rr?.-_uuenr_wee5µ.=?rs_tir=?oti='e??^.^u.?,^:s?cYQL'+SL"?Ii99RNYSAB?on?r-.?®I? I verify that the statements made in the foregoing document 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: CHARLES R. UHRICH, Plaintiff, V. SANDRA L. UHRICH, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6757 CIVIL 1999 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of MANCKE, WAGNER HERSHEY & TULLY, do hereby certify that on this date a copy of the COMPLAINT IN DIVORCE was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Ms. Sandra L. Uhrich 835 Longs Gap Road Carlisle, PA 17013 DATE: 11/09/99 By J i % . I) o"L L) Debra K. Spinner,l Secretary MANCKE, WAGNER, HERSHEY & TULLY 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff 11 Z 231 525 506 m an Return ; Shoving to n a A e s ta:ress 1.10 0 O W py E ` o LL N a ` u SENDER: I also wish to receive the v ` .Compete Items 1 andfor 2 for additionai services. following services (for an m 0 .Complete items 3,4a, and 4b. . Print your name end address on the reverse of INS loan so that we can return INS extra fee): ° u card to you. . Attach this form to the front of the mallpiece. or an the back if space does not 1.0 Addressee's Address ° 2 pemet. W te'Return Receipt Requesfad'on the mailpieW below t he article number. 2. fl Restricted Delivery ° V. o $ The Return Receipt will show to whom the anido was delivered and the dale Consult postmaster for fee. a delivered. 3. Article Addressed to: 4a. Article Number ° a 231 2 217 E 5s. Sandra Uhrich 4b. Servce Type a E 835 honds Gar) °oad El Registered ® cenine @ Carlisle, PP_ 17013 ?Express Mail ?Insured m ? Return Receipt for Merchandise ? COD ` 0 7. Date of Dell try / C c c . 5. Qeceivod By: (Pmt Name) R. Addr sloe ddress (Only requested ' c ° ?;,,clrt' Ltir LII?(I?? and fee is paid) enq g n re: (Addressee or 6. S ? ` X Domestic Return Receipt Ps Fornr3811, De mbar 1994 r US Postal Service Receipt for Certified Mail No Insurance Coverage Pm•nded. Do not uSn fn, Inlmna an- al Area ,c- .....,...,.., $ rare Ms_s-aaara Uhri 8 Numoer q 835 I,oncrs Gap Road .. n..., e . qo re;,, Carlisle PA 17013 Postage S .55 CeMf od Fee 1.35 Spcaal Dchvery Fee Res:nded Dnrvery Fro 2 .75 Dowered ca?q to'efm ed Fees S 5 .75 ata 11/16/99 ?, ?--. ?: ?, = c?_. - v; CHARLES R. UHRICH, Plaintiff, v. SANDRA L. UHRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6757 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 8, 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 of divorce after service of notice of intention to request entry of the decree. 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. 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 /u/nsworr. falsification to authorities. DATE arles R.- Uhrii6h c I :. -' __3 CHARLES R. UHRICH, Plaintiff, V. SANDRA L. UHRICH, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6757 CIVIL ACTION - LAW IN 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 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 unsworn falsification to authorities. Charles R. Uhridb/ DATE: CHARLES R. UHRICH, Plaintiff, V. SANDRA L. UHRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6757 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 8, 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 of divorce after service of notice of intention to request entry of the decree. 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. 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 unsworn falsification to authorities. DATE: I Gi' Cu i??? Sah'ra L. hrich ?:? ?? . - - CHARLES R. UHRICH, V. Plaintiff, SANDRA L. UHRICH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6757 CIVIL ACTION - LAW IN 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 of divorce without notice. 2. 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. 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 unsworn falsification to authorities. JSadraa L. Uhrich DATE: k-1-?L, 0