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Home My WebLink About99-07176V. V .a ?I a IN THE COURT OF COMMON FLEAS 'Z OF CUMBERLAND COUNTY WARREN R. LINDERMANN, II :. ..... ........................----.......... P,laintiff...... No ......99-7176 ................. 19 99 Rr STATE OFD; PENNA. a?•-?h-r. Versus CAROL M. LINDERMANN, ....... ................................... _ ....................... Defendant i i if d DECREE iN DIVORCE AND NOW, .....? ............. M.2999, it is ordered and WARREN R. LINDERMANN II decreed that ............................'...................... plaintiff, CAROL M. LINDERMANN °•' and ......................................................... . defendant, are divorced from the bonds of matrimony. s 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. ++ t• ......................................................................... By The , Cpl r t: Attest.•U J. i Prothonotary •..? •. {? • .:eS •:1:• {e:• {? •. {?• •Y:• •:e:• •:1:• •:1:• :e:• •.ei •:1i •:1:• •:O:• •Y:• Ce:• {1:• •:1:• •:1:• :!:• LOS {1:• {e:• C/:. .,w:. :e:.r.. G 1eo 4;di.e.v `1(O?GU /suz?1? WARREN R. LINDERMANN,11, Plaintiff VS. CAROL M.LINDERMANN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. 99-7176 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: 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 330I(c) of the Divorce Code. 2. Date and manner of service of the complaint: December 13. 1999 by Sheriff of Staunton County, Virginia 3. (Complete either paragraph (a) or (b).). a. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on May 22, 2000; by defendant on May 22.2000. b. (1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 6, 2000. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: June 6, 2000. Date: (, - 6 - 0D ?I. S// MARIE COVNE, ESQt; E A brney for Plalnffff Pa. Supreme C1. No. 53788 d) M ice. (U 7C 'J J C( 7 `? U U a6wl3'. JFa e.r-1 t ?s.li -uL•tinr..s-'?;?5?::.L rid..4:' s I.r.?a?Sit:b1 WARREN R. LINDERMANN, II, Plaintiff, VS. CAROL M. LINDERMANN, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. tJ 9- 7) 7 4 CIVIL TERM : 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 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, PA 17013 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, TO GET LEGAL HELP SHOULD CONTACT: Cumberland County Lawyer Referral Service 2 Liberty Avenue, Carlisle, Pennsylvania 1-(800)-990-9108 COYNE & COYNE, P.C. r0 Marie Coyne, Esfiuire Market Street Camp Hill, PA 17011-4227 (717)737-0464 Pa.. Supreme Ct. No. 53788 Attorney for Plaintiff r- WARREN R. LINDERMANN, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA NO. qq_ 71 J4. CIVILTERM VS. CAROL M. LINDERMANN, Defendant. : IN DIVORCE COMPLAINT UNDER SECTION 3301(c 1 OR 3301 (d) OF THE DIVORCE CODE NOW COMES the Plaintiff, Warren R. Lindermann, II, by his attorney, Lisa Marie Coyne, Esquire and files this Complaint In Divorce and avers the following in support thereof: I. The Plaintiff, Warren R. Lindermann, is an adult individual residing at 130 Conodoguinet Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Carol M. Lindermann, is an adult individual residing at 124 Baylor Street, Staunton, Virginia. 3, The Plaintiff has been a bona fide resident in the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 2, 1990, in Little Creek, Virginia, and separated on or about April 7, 1998. 5. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 6. There are no children of the marriage. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 2 9. Plaintiff has been advised that counseling is available and that plaintiff may have the I right to request that the court require the parties to participate in counseling. Further, Plaintiff waives his right to request that the parties participate in marriage counseling. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a decree in Divorce to Plaintiff. Respectfully submitted: COYNE & COYNE, P.C. Dated: 2 et N L"' 9 ry 3991 Market Street F Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff 3 VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. 54904. Dated: //-Z9- 7? S ? s ? u I O C-- U Ln Z3 J ? y 1? WARREN R. LINDERMANN, II, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 99-7176 CIVIL TERM CAROL M. LINDERMANN, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on November 30, 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. 1 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 unswom falsification to authorities. P l \ nl l , i Dated: 5'^ 2 2- o y ` t Yvr A N R. ERMANN, II, Plaintiff :..?.- .. .? r n. i? t? Ujr? -?. ?: t%i ^? i ?? cp ![ <p .: . ? , , ._ _- _ G C ., U I 1 i 1f 1Y I 1 2"j EI't(t?V,r?..Ji ,A•&94 ?Y.' WARREN R. LINDERMANN,11, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 99-7176 CIVIL TERM CAROL M. LINDERMANN, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on November 30, 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. 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. S. Section 4904 relating to unswom falsification to authorities. Dated:-?oZ?2?4D CAROL M. L NDERMANN, Defendant r r. Li, h..', ' f 7 S l17 ff C f: ,t fJ 1 f ?If ? U Q U WARREN R. LINDERMANN, II, Plaintiff VS. CAROL M. LINDERMANN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7176 CIVIL TERM :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(el 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. Section 4904 relating to unsworn falsification to authorities. Date: T-.2 z -o0 *AOEEANN, II, Plaintiff :L cz) C^ ...e L[ :I 7 '?y7 _ ..aye U Cam.7Z WARREN R. LINDF.RMANN, II, Plaintiff VS. CAROL M. LINDERMANN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99-7176 CIVIL TERM 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. 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 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: CAROL`IK. L VDERVIANN, Defendant ti C u.'.. V1G ?= Q C? 7 U ;?.:.'.: i i. .,.:::'r :.c?aa.'•5+i.aw.rt ?....Y.::ai c?ri?.iisrrt'??1??''?I??M4t(fi+hl.RY°{1. WARREN R. LINDERMANN, II, IN THE COURT OF COMMON PLEAS ?r!® Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99-7176 CIVIL TERM CAROL M. LINDERMANN, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that a true copy of the Complaint Under Section 3301(c) or 3301(d) of the Divorce Code was served December 13, 1999, by way of Personal Service by the Sheriff of the City of Staunton, Virginia, upon Carol M. Linderman in person at her home address. (See Attached Sheriffs Return). COYNE & COYNE, P.C. Dated: -)C BY:L?.???I?w /LISA MARIE COYNE, ESgUIRE 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 WARREN R. LINDEML1,\N, H, Plaintiff, VS. CAROL M. LMERMANN, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 9y- 717E CIVIL TERM 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 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 tare plairitiff. You may lose money or property or other rights important to you, including custody or visitation of your -n r` 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, PA 17013 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, TO GET LEGAL HELP SHOULD CONTACT: Cumberland County Lawyer Referral Service 1 Liberty Avenue, Carlisle, Pennsylvania 1-(800)-990-9108 COYNE & COYNE, P.C. Yiti.-- G TRUE COPY rPOW, RECORD In Testimony e,.hU??Yrf, I herau :oset my hand and tha wl of sari Cowl at Cart6,1e. Pa. Thls.?o? Coy occurr 1QiZ_ Proltionotary t Marie Coyne, EsAuire O1 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa.. Supreme Ct. No. 53788 Attorney for Plaintiff WARREN R. LINDERIMANN, II, Plaintiff, VS. CAROL M. LINDERNIANN, Defendant. : IN THE COURT OF CONLrION PLEAS OF : CUNIBERLAND COUNTY, PENNSYLVANIA NO. 7 C CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE NOW COMES the Plaintiff, Warren R. Linderman, IT, by his attorney, Lisa Marie Coyne, Esquire and files this Complaint In Divorce and avers the following in support thereof- I. The Plaintiff, Warren R. Lindemann, is an adult individual residing at 130 Conodoguinet Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Carol M. Lindemann, is an adult individual residing at 124 Baylor Street, Staunton, Virginia. 3. The Plaintiff has been a bona fide resident in the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 2, 1990, in Little Creek, Virginia, and separated on or about April 7, 1998. 5. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 6. There are no children of the marriage. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 2 F. 9. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. Further, Plaintiff waives his right to request that the parties participate in marriage counseling. WHEREFORE, Plaintiff respectfully requests that this Honorable Court eater a decree in Divorce to Plaintiff. Respectfully submitted: COYNE & COYNE, P.C. Dated: 24 NOV 1re ?reu nvNF_ 14scuire 39 Market Street V amp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff 3 t MM CAI-IQN The facts set forth in the foregoing are true and correct to the best of the undesigneXs knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. §4904. Dated L:: Z 2- 2 EHCCUTGO Ti4 ?y n')IIN YAmr 014 TH, 3 h ML Uec '"' T?` _evo¢uvskixc 119e[nr rne... ?..--- Ui P®?uDM, IIY: CL . R Sworn to and subscribed before me this 14th day of December, 1995 Notary u, My commission expires: September 30, 2003