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HomeMy WebLinkAbout99-07678 I .o e CIO i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ry PENNA. 15- CHARLES F. PECKHOLDT. Plaintiff NO. 7678 iogg VERSUS HELEN V. nECKHOTTYP Defendant DECREE IN DIVORCE 4 1 ? C?r /.•461..'4 . AND NOW, IT IS ORDERED AND DECREED THAT__ CHARLES F P CKHOTiYP , PLAINTIFF, AND HELEN V. PECKHOLDT 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; NONE. BY THE ATTEST: J PROTHONOTARY u -,//?•CD wow l -el-& CHARLES F. PECKHOLDT, Plaintiff V. HELEN V. PECKHOLDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7678 CIVILTERM CIVIL ACTION - LAW 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 § 3301(c) 338l(dj of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on December 30, 1999 by certified, restricted delivery, return-receipt requested mail that was signed for by the Defendant. 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by the PlaintifT. April 5, 2000; by the Defendant: April 5, 2000. (b) (1) Date of execution of the Plaintiffs Affidavit required by § 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's 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, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by § 3301(c) of the Divorce Code: y the Plaintiff: April 5, 2000; by the Defendant: April 5, 2000. 1 Date: April 6, 2000 Thomas S. Diehl, Esquire Attorney for Plaintiff ti ?l ? J ti 1;L 7 7 U I CHARLES F. PECKHOLDT, Plaintiff V. HELEN V. PECKHOLDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 76 7f CIVIL TERM CIVIL ACTION - LAW 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 divorce is indiSmities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the 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, Pennsylvania 17013 (717) 249-3166 CHARLES F. PECK14OLDT Plaintiff V. HELEN V. PECKHOLDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,13ENNSYLVANIA NO. 99- 769F CIVILTERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE The Plaintiff, Charles F. Peckholdt, through his attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Charles F. Peckholdt, is an adult individual who currently resides at 1481 Trindle Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Helen V. Peckholdt, is an adult individual who currently resides at CME Lot 136, Newville, Cumberland County, Pennsylvania 17241. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 26, 1992 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America of its Allies. o 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. PlaintilTand Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff Charles F. Peckholdt, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) of the Divorce Code. Date: l a - -) ?- 1 I Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX i CHARLES F. PECKHOLDT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99- CIVIL TERM HELEN V. PECKHOLDT, : CIVIL ACTION - LAW Defendant : IN DIVORCE VERIFICATION 1 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. § 4904, relating to unswom falsification to authorities. &. -(dw - ?' I? eA e: ? CHARLES F. PECKHOLDT, Plaintiff i CHARLES F. PECKHOLDT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO.99-7678 CIVILTERM HELEN V. PECKHOLDT, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on December 28, 1999. 2. The marriage of the Plaintiff' and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. f 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. § 4909 relating to unswom falsification to authorities. Date: L, ?2- 0 0 0 X ?z CHARLES F. PECKHOLDT, Plaintiff WAIVER OF NOTICE OF INTENTION'rO REOUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE I. I 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 1 will not be divorced until a Divorce Decree is entered by the Court and 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. § 4909 relating to unsworn falsification to authorities. Date J moo 0 CHARLES F. PECK ODLT, Plaintiff Cj ' Z) I l ? I i i CHARLES F. PECKFIOLDT, Plaintiff V. HELEN V. PECKHOLDT, Defendant IN Ti it. COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.99-7678 CIVILTERM CIVIL ACTION - LAW W DIVORCE AFFIDAVIT OF CONSENT I. A gcoplaint in divorce under §3301(c) of the Divorce Code was filed on December 28, 1999. 2. The marriage of the 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. § 4909 relating to unsworn falsification to authorities. Date: ACR-HOLDT, PlamUff I 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. 1 understand that 1 will not be divorced until a Divorce Decree is entered by the Court and 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. § 4909 relating to unsworn falsification to authorities. Date: _ 0 00 HELEN V. PECKHODLT, Plaintiff ??~ C? `. ?. '?i.: ?, L , .? _ ? ? ?? _: r. ?= .?i? LI n t C ?,? CHARLES F. PECKI IOLDT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99- 7678 CIVIL TERM HELEN V. PECKHOLDT, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 4`h day of January 2000, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Charles F. Peckholdt, and states that he personally mailed a certified copy of a Complaint in Divorce to the Defendant, Helen V. Peckholdt, at CME Lot 136, Newville, Pennsylvania by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on December 30, 1999. Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 240-0893 - FAX . a Z 339 067 E56 US Postal Service Receipt for Certified Mail sr- ineitrnnea Cnveraae Provided. 36 p Posialle $ .55 q Ce lified too 1.40 W Special Delivery Fee a Restricted Delvery Fee 2.75 N Return Recdpl Showing 110 25 1 whom B Date Delivered _ . W TOTALPO ??.Fees 5.95 V) Posbna a in J ?JN 4 t N Cf 1 Ln a 4 ?- m SENDER: I also wish to receive the L • Complete items I andlor 2 for additional samicas. following services (for an o • Complete items 3.4a, and 4b. • Print your name and address on ilia reverse of this loon sa that we can return Ibis extra lee): o card to yyo. • Attach lldsulorm to tho bank or the maapieco, or on the back it sryxO likes not 1.0 Addressee's Address ppermit. h below dui t as Ra on l arum • 2. ® Restricted Delivery t t the date rmer The flatnatum nacalpl w kill will sphes ow to la whom In tha article was was delivered tlai° ad suit • The Consult postmaster for lee. delivered. 0 3. Article Addressed to: d PTELEN V. PECKHOLDT 0 E CME TAT 136 0 a NENVILLE, PA 17241 L?'?liver Fn aiTrir?sc?? nsh+ 5. R,?e,ceIf By: (Pdnl N ?7EGL'?t/'kyn! !17' ' nature: (Add sse Avert p O T veil 2 PS Form 3811, December 1994 u o.» VUr 6 10 E 4b. Service Type a ? Registered Certified ? Express Mail ? Insured c ' ? Relurn Receipl far Merchandise ? COD Ui 7. Date of Delivery /,Z • j0-7 7 0 B. Addressee's Address (Only it requested Y and tae is paid) n F- 102595 98 n 0229