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HomeMy WebLinkAbout07-3200JEREMY UHL, Plaintiff, vs. TABITHA UHL, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O'I -3~Qd CIVIL ACTION -LAW IN DIVORCE . ~" N O T I C E 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 Domestic Relations Office, 13 North Hanover Street, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE 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, PA 17013 JEREMY UHL, Plaintiff, vs. TABITHA UHL, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 7- 3 2 o-v ~<.! 7~ CIVIL ACTION -LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint 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 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Plaintiff JEREMY UHL, IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA //~~ TABITHA UHL, :CIVIL ACTION -LAW Defendant. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, JEREMY UHL, by and through his attorney, LESLEY J. BEAM, ESQ., and makes the following Complaint in Divorce: 1. The Plaintiff is JEREMY UHL, an adult individual who currently resides at 165 Cedar Lane, Carlisle, Cumberland County, Pennsylvania, 17015. 2. The Defendant is TABITHA UHL, an adult individual who currently resides at 17 Woodcrest Building, Middletown, Dauphin County, Pennsylvania, 17057-2533. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 8, 2003, at the office of Magisterial District Judge Susan K. Day in Mt. Holly Springs, Cumberland County, Pennsylvania. 5. The Parties separated on February 21, 2006, when Defendant moved out of the marital residence. 6. Neither the Plaintiff nor Defendant is in the military service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and the right to request that the Court require the parties to participate in counseling. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, if both parties file affidavits consenting to a divorce after (90) ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 12. The marriage of the parties is irretrievably broken. 13. The parties are living separate and apart and at the appropriate time Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for at least two (2) years as specified in Section 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. Respectfully Submitted, KOPE & ASSOCIATES ~.1 ,~-- Date: ? 3 0 L y J. , E q. VERIFICATION I, Jeremy Uhl, the Plaintiff in this matter, have read the foregoing Complaint. I verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Dated: S"-e`~ ~ ~ y7 ~ ~ ~+v o ~ ~ c ~ ~ ~ ~ ~ ~~~ ~ f .~..:_ ~w \l.._. na © ~ -~ ~~ ~.~~' ~` ~~ ~ ` ca ~rn cn r.~ ~ KOPE ~ ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com JEREMY UHL, Plaintiff, vs. TABITHA UHL, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANLA NO. 07-3200 CIVIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Tabitha Uhl, Defendant in the above-captioned matter, hereby accepts service of the Complaint in Divorce. Date: - ~ Tai a c"> ~ ~ :~° -_~~; ~ -; -~; 1 --~a - = . ; 4 s J _ E~~ ~~ ~ KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam a~kopelaw.com JEREMY UHL, Plaintiff, vs. TABITHA UHL, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-3200 CIVIL ACTION -LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divonre Cade was filed on May 23, 2007. 2. The Complaint was served by Acceptance of Service signed by the Defendant on June 6, 2007. 3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 4. t 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 sub}ect to the penalties of 18 Pa. C. _~ S. Section 4904 relating to unswom falsification to authoriti Date: 9 ~ ab~tha Uhl ~~ ~!+-: ~~ ~.. 1 ~~ 1 KOPE +& ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com JEREMY UHL, Plaintiff, vs. TABITHA UHL, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-3200 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 in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 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 wiN 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 S. Section 4904 relating to unswom fais~cation to Date: ~4--/~ penalties of 18 Pa. C. -. ' ~ ~ ~~ ~' --~ KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY LD. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 IbeamQkopelaw.com Att©rney for Plaintiff JEREMY UHL, IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA vs. N0.07-3200 TABITHA UHL, :CIVIL ACTION -LAW Defendant. IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was 81ed on May 23, 2007. 2. The Complaint was served by Acceptance of Service signed by the Defendant on June 6, 2007. 3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 4. 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. l understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to < Date: ~- - ~ ~' 'p i~ vs 33 µ ~' ~~ _~ ---• KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY l.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717} 761-7573 (beam@kopelaw.com JEREMY UHL, Plaintiff, vs. TABlTHA UHL, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.07-3200 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 frnal 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 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 statemen#s herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to autl Date: ~ --o ,, fix.. cr.~~W-_ ~ ~~ ~-~ ~ --- M ttt IiV THE COURT OF COMMON PLEAS JEREMY uHL CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION TABITHA UHL NO. 07-3200 CIVIL TERM PRAE~IPE 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) ~1~~~~!'c6~~ (Strike out inapplicable section). 2. Date and manner of service of the complaint: Accept nice Qf Servi~-P signgd 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 plaintiff September 6, 2007 by defendantSeptember 13, 2007 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (~) Bate of filing and service of the plaintiff's affidavit upon the respondent: 4. Rela#ed 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: (bj Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed.with the Prothonotary: September 18, 2007 Date defendant's Waiver of Notice in §3341 (c) Divorce was filed with the Prothonotary: Se tember 1 1 2007 r y for Plaintiff /Defendant ~° CJ> N ~,, ~~ --, - __ ~ ~w -s-t ~ ~-.. ~ rte' ~ .,1~^' j ~ v 1 ~/ S l.,.f • I N T'H E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. _l .. ,r N O. 07-3200 VERSUS DECREE IN DI~IORCE AND NOW, ~ 1,~~ IT IS ORDERED AND DECREED THAT JEREMY UHL PLAINTIFF, AND TABITHA UHL DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIGH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; -~ ~~, aaV~7' ~ ~' ~~ gyp. ~'- o/ ~ ~'~a ~ ~Q. ~ o~ ., ,,