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HomeMy WebLinkAbout03-3791 Steven C. Singiser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 03 - 379/ C~~L~~ Bobbie Jo Singiser, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE You have been sued in Court If you wish to defend against the claims set forth in the following papers, 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 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 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, PA 17013 (717) 249-3166 chi!~:t~re Attorney for Plaintiff Steven C. Singiser, Jr., Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. OJ - 3'79/ (];u~C-T~ Bobbie Jo Singiser, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Steven C, Singiser, Jr" who currently resides at 108 East Locust Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055, 2, Defendant is Bobbie Jo Singiser whose last known address is believed to be 201 Mulberry Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050, 3, Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint 4, Plaintiff and Defendant were married on October 2, 2000, III Cumberland County, Pennsylvania, 5, There have been no prior actions for divorce or annulment between the parties, 6, The Plaintiff is a citizen of the United States of America, 7, The Defendant is not a member ofthe Armed Services of the United States of America, 8, Plaintiff avers that there are no children ofthe parties ofthis marriage, 9, The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling, COUNTl REOUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 10, The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full, I }, The parties have been living separate and apart since on or about April 2, 2002, 12, The marriage of the parties is irretrievably broken WHEREFORE, Plaintiff requests this Honorable Court to enter a decree dissolving the maniage between Plaintiff and Defendant. Respectfully Submitted, eJt/~1-~ Supreme Court ID# 86889 Attorney for Plaintiff !OI South Market Street Mechanicsburg, Pennsylvania 17055 (717) 790-5451 VERIFICATION I verify that the statements made in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalti f 18 Pa,C.S, 94904 relating to unsworn falsification to authorities, J/ Date: Steven C. Singiser, Jr., Plaintiff IN THE COURT OF COMMON PLE~S CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-3791 Civil Term Bobbie Jo Singiser, Defendant CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO SUBSTITUTE VERIJIICATION PROTHONOTARY; Kindly the substitute the enclosed verification for the v(:rification of the complaint in this , matter that was inadvertently left undated when filed with your office, Respectfully SubmJitted, d/l i!~ Christopher J, eller, Esquire Supreme Court ID# 86889 Attorney for PlaintijJ 101 South Market Street Mechanicsburg, Pennsylvania 17055 (717) 790-5451 VERIFICATION I verify that the statements made in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the~nalties of 18 Pa,C.S, ~4904 rot";',: ~:~: fu";fi"tioo '''ollie"''" ~.. Date: 0 / ~ / / > ! f .. C) ~ -n( '.:2)'" ~;I 6J i::; ~~. ~2 /~. :~ ..' ) \.~. ; ) i'l "_'1 , ~;_J -< Steven C. Singiser, Jr., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-03791 Civil Term Bobbie Jo Singiser, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Christopher J, Keller, Esquire, hereby certify that I have served the Defendant, Bobbie Jo Singiser, with a copy of the divorce complaint on August 15,2003, by certified mail number 7003 101000008131 2580 as evidenced by the attached original United States mail return receipt 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,A. Section 4904, relating to unsworn falsification to authorities, c~~,~ Supreme Court ID# 86889 t.: . ,.....- --~ '.... (') c <: ;:f~ v~ ~r o -<.,- ~~ ~-:~ ' j> '~ -~"") 1 (,.J ~, ~<'\ r-...) ~ , o Steven C, Singiser, Jr., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Bobbie Jo Singiser, Defendant : NO, 03 - 3791 CIVIL TERM NOTICE TO.PLAINTlFF If you wish to deny any of the allegations set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. DEFENDANT'SAFFIDA VIT UNDER SECTION 330Hdl OF THE DIVORCE CODE 1. The parties to this action separated in April 2002, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property , lawyer's fees or expenses if! 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. ~4904. relating to unsworn falsification to authorities. Date 8'1:g -o~ ;6f~. ~ Bobbie Jo Singiser Defendant ('") c: s: "OJ''' nlr:'~ Z .;~ -"r- E: ~~1 If; 2: =<! ~~l ...., "'" '= "'" :- c:: en N N ..., ::J:: ~ :r m::D r- -om ~~6 ;5 2.f"~ ~-._~o om -.. 55 -< s:- O'> '\ Steven C. Singiser, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CNIL ACTION - LAW : IN DIVORCE r-,-J [';~' C) i'l '-'-J =1 :,1 Bobbie Jo Singiser, Defendant ""'"',; --'-1 : NO. 03 - 3791 CIVIL TERM c, PLAINTIFF'S COUNTER-AFFIDAVIT UNDER ~3301( d) OF THE DIVORCE CODE \, :'.~ c..) L' , ._.J --- 1. Check either (a) or (b): ~ (a) I do not oppose the entry of a divorce decree. ( ) (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ( ) (i) The parties to this action have not lived separate and apart for a period of at least two years. ( ) (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): 00 (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. .. ' J. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date /6 -G,-oCc, STATE OF PENNSYLVANIA ) )SS: COUNTY OF CUMBERLAND ) Sworn or affinned to and acknowledged before me by Steven c. Singiser this 6th day~'~6f October, 2006. ~//II~&Wk{ Public ." Steven C. Singiser, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Bobbie Jo Singiser, Defendant : NO. 03 - 3791 CIVIL TERM PLAINTIFF'S COUNTER-AFFIDAVIT UNDER ~3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ( ) (a) I do not oppose the entry of a divorce decree. ( ) (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ( ) (i) The parties to this action have not lived separate and apart for a period of at least two years. ( ) (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ( ) (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic reliefwhich may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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. Date Steven C. Singiser Steven C. Singiser, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA v. Bobbie Jo Singiser, Defendant : CIVIL ACTION - LAW : DIVORCE : NO: 03 - 3791 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: PLAINTIFF You have commenced an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the ~ 3301(d) affidavit. Therefore, on or after October 25,2006, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ~....._--) ::::! -, I J.. ;-,--, C" l~ () -:-, (' {Jl { I Steven C. Singiser, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 03-3791 CIVIL TERM Bobbie Jo Singiser, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown and separation for two years under 9 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Service by certified mail at 201 Mulberry Drive, Mechanicsburg, P A 17050 on August 15, 2003. 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 PlaintiffN/A ; by Defendant N/A (b)(l) Date of execution of the affidavit required by ~ 3301(d) of the Divorce Code: August 13, 2006; (2) Date of filing and service of the defendant's affidavit upon the plaintiff: Filed and served on August 22, 2006. 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: September 29,2006 by first class mail at 108 E. Locust St., Mechanicsburg, P A 17055. (b) Date plaintiffs Waiver of Notice was filed with the Prothonotary: N/A Date defendant's Waiver of Notice was filed with the Prothonotary: N/A . Date Jlll7j dt~ j{/\;~UU _Arh,{kU'~f Suzanhe Sekutowski Certified Legal Intern Robert . ams, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire Megan Riesmeyer, Esquire Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 p ..-.. Steven C. Singiser, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE Bobbie Jo Singiser, Defendant : NO. 03 - 3791 CIVIL TERM PI,AINTIFF'S COUNTER-AFFIDAVIT UNDER ~3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ~ (a) I do not oppose the entry of a divorce decree. ( ) (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ( ) (i) The parties to this action have not lived separate and apart for a period of at least two years. ( ) (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ~ (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. .. ,- - .' - I verify that the statements made in this counter-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. Date /6 - G:, -aCe, STATE OF PENNSYLVANIA ) )ss: COUNTY OF CUMBERLAND ) Sworn or affinned to and acknowledged before me by Steven C. Singiser this 6th day:<~of October, 2006. ~/-/?c/f~W4 Public ,...,.. .... Joette L. ..a:.__.. NotIfy PuIIIo MICtIIl......~II_ 'M Commission e 8 2010 C) f"~, c_~:, (......) c:- C~:) -ll Q"""" 1'.' 0 ::-":fi ., ~~;~~~ (,,) ;;"'J -< ..,.,. "';'~""'';.~~~,.t..." : ,,*' tr",~I<.. 1 ~.".)I.;t',;i~'; \'.{',(:(1 .....C.t}::.!tit .1 , . "'~~:' ~ ,~':1 '~-.~.J.+":'!'1\{; t, t".:"I~ !\.. .;..i1!", 'I ') ,.: t'.,,".'.. Of. Of. Of. Of. "':+::+::+::+::+: "'''' :+: "''''''':+:''':+: :+: :+:'" Of. ltl Of.:+:'" Of. :+: "''''''' IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Steven C. Sinqiser No. 03-3791 Plaintiff VERSUS Bobbie Jo Sinqiser Defendant DECREE IN DIVORCE ~2.... ~ , IT IS ORDERED AND AND NOW, Steven Sinqiser DECREED THAT , PLAI NTI FF, Bobbie Jo Singiser AND , 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; No claims pendin9 ATTEST:~ ~ (~ PROTHONOTARY :F.:F.:t3 :F. :F.:F.:F.:F.:F.:F.fl'!fl'!:F. fl'!:F.fl'!fl'!fl'! :F. :F. ~ltlltl~~~~:F.~~ "'ltl:f.ltlltl ltl:f.:f. J. "'7:.7 ? ~ ~u. 1i? l-cl P l' ~ lup'~ ?to I -6'1 .".... ,If; "',,~ ~"