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Home My WebLink About99-07488 1 0 4 Ir a 0 IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY STATE OF PENNA. 1 O ' BARBARA A. NIEDERLANDER .................. ............................... _ ................ 99-7488 Plaintiff '(t ......................... ................. ....... ......................... .......... Versus MICHAEL D. NIEDERLANDER Defendant DECREE IN DIVORCE -` :•: ......... . ..... ( 190.0. , it is ordered and :? AND NOW, .. decreed that ........... .............giu. g4. ••.•........., plaintiff, and •••••••••..........••MICHAEL D. NIEDERLANDER defendant, i •O.• are divorced from the bonds of matrimony. d 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; none pending ..................................... . .................................................. B r At st: J. w y Prothonotary !A•. s:•. •W• •A:• <t• et:• -W.- {t:• IV. <?:• {t} Ct• -Vi :?:• W. :?: W. ;t:• W. A.- W. :!h :e• •:E• {e:• •:e:• :e:• W. W., ;.-= BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : CIVIL NO. : IN DIVORCE PRAECIPE TO TRANSMIT 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: U. S. Mail Return Receipt Requested mailed 01/12/00. received 01/14/00 per affidavit of Susan J. Hartman. Esquire 3. (1) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff 4/17/00 by defendant 4/17/00 4. Related claims pending: none 5. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 4 6. Date Defendants Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: _ 4/18/00 y??C- _.._ . .a..?,. ... c L ?? , -'-_ =z ?' ?? ?: - ?cn i ?_i - ?Ll c? -i ?. c > r.<? BARBARA A. NIEDERLANDER, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MICHAEL D. NIEDERLANDER : CIVIL NO. 99-0911 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 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 at Cumberland County Courthouse, Carlisle, Pennsylvania 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, 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, PENNSYLVANIA 17013 TELEPHONE: 717-249-3166 BARBARA A. NIEDERLANDER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MICHAEL D. NIEDERLANDER : CIVIL NO. 99.7yB 7 C't ?? Defendant : IN DIVORCE COMPLAINT AND NOW COMES the above-named Plaintiff, by her attorney, Susan J. Hartman, Esquire, and makes the following Complaint in Divorce: 1. Plaintiff, Barbara A. Niederlander, is an adult individual currently residing at 1953 Holly Pike, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Michael D. Niederlander, is an adult individual currently residing at 1953 Holly Pike, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint, but Defendant has been serving in the United States Army and is presently stationed at the above referenced address. 4. The Plaintiff and Defendant were married on June 11, 1981 in Waynesville, Missourri. 5. There has been a prior action of divorce Civil No. 1993-1829 filed in the Office of the Prothonotary of Cumberland County on June 2, 1993. On or about September 8, 1995 said case was discontinued as requested by the Plaintiff. 6. Plaintiff avers, in accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7. 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. f; 8. The Plaintiff requests this Court to enter a Decree in Divorce. t WHEREFORE, Plaintiff prays this Honorable Court to enter a decree dissolving the marriage between the parties. Respectfully Submitted, Susan j. Hart a , uire Attorney for Plain ff Duncan & Hartman, P.C. 1 Irvine Row Carlisle, PA 17013 (717)249-7780 ?LC. lN, /994 BARBARA A. NIEDERLANDER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA V. : CIVIL ACTION - LAW MICHAEL D. NIEDERLANDER : CIVIL NO. Defendant : IN DIVORCE VERIFICATION 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. sec. 49004, relating to unswom falsification to authorities. rUGff' ?A.('s??Gu Barbara A. Niederlander Date: /5! Q.ec 99 BARBARA A. NIEDERLANDER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANLI V. : CIVIL ACTION - LAW MICHAEL D. NIEDERLANDER : CIVIL NO. r'9- 7q,?8 C% ?Q -7- - Defendant : IN DIVORCE AFFIDAVIT BARBARA A. NIEDERLANDER, Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I (DID/DO NOT) request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 4. I realize that if the divorce is brought under section 3301(c) of the Divorce Code, then counseling must be completed within ninety days after the filing of the complaint. II'the divorce is brought under section 3301(d) of the Divorce Code, then counseling must be completed within one hundred and twenty days after the filing of the complaint. I understand that false statements herein are made subject to the penalties oft' 18 Pa.C.S.4904 relating to unsworn falsification to authorities. &14u& 2' /`C?I& Barbara A. iederlander BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL NO. : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with section 3301(c) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relation Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost off counseling sessions are to be born by you and your spouse. If you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW CIVIL NO. IN DIVORCE AFFIDAVIT OF SERVICE I, Susan J. Hartman, Esquire, being duly sworn according to law, do swear that I served the Complaint in Divorce on the Defendant, Michael D. Niederlander, by U.S. Mail Return Receipt Requested on January 14, 2000. Susan J. Hartma , s re Sworn to and subscribed before me this i 7 day of P ; I 12000. ` 'cl otary Public :dOlanal LI, Cynthia L. Dar, Waary Pubic Soulh f,tdJ'eion 7wp,, runbtaarRl Co.rn? lily Coru"asron crpi; es iu,g. 15, a0pp is I - I ? •tQ 1 3a; .= 0 1 a` I d rn UmE N m L a a to w S yr u: N ?°ca j°- a z°C 0 I ^ 1i 1 ? /I1 I'l y 2 r n `? Cy $ n 9661 IIIW'008E Wloj Sd ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the maiiplece, or on the front if space permits. 1. flclo Addressed to: ?hael 1J?ede<,av,dec' a'76 we5+ Cacl She. QQ 17o13 oegwaived by (P/oese Print Clearly) B. Date of Tlrn r K; v, r 00;':? r4'elL. 0. Signature r D. Is delivery address different from Item 19 u Yes I If YES, enter delivery address below. 0 No I $fl I 3. Service Type Certified Mail 0 Express Mail I Registered pIC"Rotum Receipt for Merchandise i O Insured ? Mell C.O.D. 4. Restricted Delivery? (E%lm Fee) ? Yes 2. Article Number (Copy Imm serv/ce labs I 1z - ysa W9 9?6 i PS Form 3811, July 1999 Domestic Return Receipt 102595.99-M-1789 1.1.?M i BARBARA A. NIEDERLANDER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA V. : CIVIL ACTION - LAW MICHAEL D. NIEDERLANDER : CIVIL NO. 99-7488 Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on 1/12/2000 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. I consent to the entry of a final decree of 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. 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. sec. 49904 relating to unswom falsification to authorities. Date: ?t- /0O gml?qz . & Barbara A. Niederlander - I I BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW : CIVIL NO. 99-7488 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 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 degree 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. sec. 49904 relating to unswom falsification to authorities. Date: ?- / 7 -o o Barbara A lander :-, ti _=- ?. :`-? ?_, _ _?-?_ a :? BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW : CIVIL NO. 99-7488 : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on 1/12/2000 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of 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. 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. sec. 49904 relating to unworn falsification to authorities. Date: &1- /-7- O/) Michael D. Niederlander k \. ^' ?? .. l . _. j r? t??n `? _ ?? ?? i . ?r±-.- ,.,_i.,w BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW : CIVIL NO. 99-7488 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 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 degree 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. sec. 49904 relating to unsworn falsification to authorities. Date: '-r- )7- 70 Michael D. Niederlander P..;. 4?'. .? f_ •1 .) ?.) BARBARA A. NIEDERLANDER, Plaintiff V. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW MICHAEL D. NIEDERLANDER : CIVIL NO. 9'7-11188 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 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 at Cumberland County Courthouse, Carlisle, Pennsylvania 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, 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, PENNSYLVANIA 17013 a .y TELEPHONE: 717-249-3166 BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL NO. iq- elyW : IN DIVORCE AMENDED COMPLAINT AND NOW COMES the above-named Plaintiff, by her attorney, Susan J. Hartman, Esquire, and makes the following Complaint in Divorce: 1 Plaintiff, Barbara A. Niederlander, is an adult individual currently residing at 1953 Holly Pike, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Nfichael D. Niederlander, is an adult individual currently residing at 276 West Ridge Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 11, 1981 in Waynesville, Nfissourri. 5. There has been a prior action of divorce Civil No. 1993-1829 filed in the Office of the Prothonotary of Cumberland County on June 2, 1993. On or about September 8, 1995 said case was discontinued as requested by the Plaintiff. 6. Plaintiff avers, in accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 7. 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. 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff prays this Honorable Court to enter a decree dissolving the marriage between the parties. Respectfully Submitted, ?e j usan J. Harty n, Espy ire Attorney for Plat tiff Duncan & Hartman, P.C. 1 Irvine Row Carlisle, PA 17013 (717)249-7780 4r, t l , 20OO VERIFICATION 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. sec. 49004, relating to unswom falsification to authorities. Barbara A. Niederlander Date: / / _STJ-w) i WO . BARBARA A. NIEDERLANDER, Plaintiff V. MICHAEL D. NIEDERLANDER Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL NO. rl9- 7 `fS9 IN DIVORCE AFFIDAVI'T' BARBARA A. NIEDERLANDER, plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I (H® O NO request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 4. I realize that if the divorce is brought under section 3301(c) of the Divorce Code, then counseling must be completed within ninety days after the filing of the complaint. If the then counseling divorce is brought under section 3301 (d) of the Divorce completed within one hundred and twenty days after the filing Code, of the complaint must be I understand that false statements herein are made subject to the penalties off 18 Pa.C.S.4904 relating to unsworn falsification to authorities. Barbara A. Niederlander BARBARA A. NIEDERLANDER, PlaintHF V. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW MICHAEL D. NIEDERLANDER : CIVIL NO. Defendant : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with section 3301(c) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A fist of professional marriage counselors is available at the Domestic Relation Office, 13 North Hanover Street, Carlisle, Pennsylvania You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost off counseling sessions are to be born by you and your spouse. If you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary ? H C w0 c.?,: m Q<3 z = -cc U d U 0 O C5 Z) U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BARBARA A. NIEDERLANDER l Plaintiff File No. VS. MICHAEL D. NIEDERLANDER Defendant 99-7488 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff /Defendant in the above matter, having been granted a Final Decree in Divorce on the 2nd day of May , 39 2000 , hereby elects to resume the prior surname of Barbara A. Propester , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: May 4, 2000 Ll- Sig ature Signature of n me being resumed COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND On the 4th day of May, 2000 , 39 , before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto se my h?and? nd official seal. r Notarial Snal CYntnia L. Darr. Notary Public South Ibil Ietan lwp. GomAu?aj? Y 2000 MY Coinnussiun E P i r- Cy o C?? CO L_L C? L.D .u Wi L f L' ! Ltil.u U o