HomeMy WebLinkAbout07-3798Vt '
Darlene A. Farrands-Neidigh IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 07- 3 79 ? CIVIL TERM
Samuel E. Neidigh, Jr.
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 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, 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
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
,, w
Darlene A. Farrands-Neidigh IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 07- 3 7 9 ? CIVIL TERM
Samuel E. Neidigh, Jr.
Defendant IN DIVORCE
COMPLAINT UNDER §3301(cA) or (d) OF THE DIVORCE CODE
1. Plaintiff is ? y, 1? Cnrrpnr) s- ?y who currdntl resides at
213
Cumberland County, Pennsylvania.
2. Defendant is , who currently resides at
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on 3n 19q at
5. The marriage is irretrievably broken, and the parties separated on
Maya ?N Ado `1
6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the
military service of the United States of America, but is in fact living at the address
given in Paragraph 2 above.
4 .
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request that the Court require the parties participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
L - etL] - \
Date Plaintiff, Pro e
? y
I, rl )(? V P?l?°_? ?iAb I'A?LC)5' J? ,dv?r that the statements made in this Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities as
provided in 18 Pa. C.S. §4904.
o;- 1 -0-7
Date:
Plaintiff, Pro Se /
Assisted by:
Marcus A. McKni t, s
Irwin & McKnight Law Offices
60 W. Pomfret Street
Carlisle, PA 17013
(717) 249-2353
O
?y Lr:i '; ; f4? ?3 ?7
{ . C) .L
j c._>
=
? ? 7
t
?' 1 V yC
o rn
-<
Darlene A. Farrands-Neidigh IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 07- 37 9 CIVIL TERM
Samuel E. Neidigh, Jr.
Defendant IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Darlene A. Farrands-Neidighh, Plaintiff, to proceed in forma ap uperis.
I, Marcus McKnight, attorney for the party proceeding in forma ap uperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to the
party.
Date: June 21, 2007
Marc .c night, 11
ttorney for Plaintiff
Irwin & McKnight Law
60 W. Pomfret Street
Parlisle, PA 17013
(717) 249-2353
C H
?
O
c?
cN
?
... r
DARLENE A. FARRANDS-NEIDIGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
3ngg
NO. 2007 - 08 CIVIL TERM
SAMUEL E. NEIDIGH, JR.,
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a (1)(i)
COMMONWEALTH OF PENNSYLVANIA
. SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant,
Samuel E. Neidigh, Jr., on June 26, 2007, certified, restricted delivery mail, addressed to him at
P. O. Box 278, Newville, Pennsylvania 17241, with Return Receipt Number 7004 1350 0003
7289 3518.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of Pa. C. S. Section 4904, relating to
unsworn falsification to authorities.
MARCUS A. Mc T, III, ESQUIRE
Attorney for Plaintiff
Date: June 29, 2007
a
t.n .
III
cr
rtmi imidPQ6 FA
Postage
M
0 Certified Fee
0
M Return Redept Fee
(Endorsement Required)
O ResMcted Del
Ln (Endorsement uired)
m
Total Postage & Fees
C3
O
r-
¦ Ptiltt your nanie and address on the reverse
so that we can return the card to you.
¦ Attach this card to the beck of the mailpiece,
or on the front If apace psm ta.
1. Ardde Addressed to:
M- Ste[. E 11EIDIGH JB
PIG DU 278
NWWnJ.E PA 17241
A.
Agent
B. Rea?y Id (PnYr d )^ C. Dabs of Delivery
D. Is ddvery address cift firm item 1? 0 Yes
if YES, enter ddvwy address below: 0 No
& SWVIN Type
'mod Ma8 0 Etpm Mail
0 Repfsbera OrRattrrt for Mwdtmtdiee
0 k - 90
Rodddsd DatNtroyl (mantra Fbo tL ym
2. Artk:kNtxntm 7004 1350 0003 7289 3518
(1?artelirr from Service kW
PS Form 3811, February 2004 D, dc 11e4rm IModpc , -tit-,sw
?'?
-- r..7
? Q
-r?
f
?'? 3
Y
?
?
?
?
?'' C"
?;
u'
DARLENE A. FARRANDS-NEIDIGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 2007 - 3898 CIVIL TERM
SAMUEL E. NEIDIGH, JR.,
Defendant IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, 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 that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I participate in
counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
S U E. NEIDIG .
Defendant
{7 0
DARLENE A. FARRANDS-NEIDIGH,
Plaintiff
V.
SAMUEL E. NEIDIGH, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2007 - 3898 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 25,
2007.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
Date: l?/'Z - 0 2
C?
cs -n
4A J
fix, t. 1?r rn
DARLENE A. FARRANDS-NEIDIGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
NO. 2007 - 3898 CIVIL TERM
SAMUEL E. NEIDIGH, JR.,
Defendant 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. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn
falsification to authorities.
Date:
n?
e? O
-n
g C d
rT t ? ?
?
r?
W m
'?C ?
DARLENE A. FARRANDS-NEIDIGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
NO. 2007 - 3798 CIVIL TERM
SAMUEL E. NEIDIGH, JR.,
Defendant IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
2007.
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 25,
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
Date: JANUARY 24, 2008
?-? ;.??
c:-
??? -
'• ? ??
? ?-
..t3 ?
'?
?Ai
^`? + _
'
~
__ )
?
L. ?i '_-1
4 ?
?r^^ .+?n.
?n
?.
4.^'
DARLENE A. FARRANDS-NEIDIGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
NO. 2007 - 3798 CIVIL TERM
SAMUEL E. NEIDIGH, JR.,
Defendant 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. 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: JANUARY 24, 2008
,,.-, 'r-?f 'il
K`
C`.`w .,.?..+E
_ ?..+' ?.6? ?i
?????':
?+
?~ ,?i?P
? ? t t`t
?.A ? ~ -.^..?y?y
.1.'.
..+??. \.Y...
DARLENE A. FARRANDS-NEIDIGH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 2007 - 3798 CIVIL TERM
SAMUEL E. NEIDIGH, JR.,
Defendant IN DIVORCE
To the Prothonotary:
PRAECIPE TO TRANSMIT RECORD
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) and or (d) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Samuel E. Neidigh, Jr., on or about June 26, 2007, by certified, restricted delivery mail, addressed
to him at P. O. Box 278, Newville, Pennsylvania, 17241, with Return Receipt Number 7004 1350 0003 7289
3518.
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: January 24, 2008; by defendant: October 2, 2007.
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b)(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:
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
January 24, 2008.
Date defendant's Waiver of Notice in Section 3301(c) D' ce was fi with the Prothonotary:
October 11, 2007.
Mar A. Mc fit, III, Esquire
Att ey for Plain 'ff
Date: January 24, 2008
f7 -P
. 3
r- .;J
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
DARLENE A. FARRANDS-NEIDIGH
No. 2nn7-3798 cTyu TERM
PLAINTIFF
VERSUS
SAMUEL E. NEIDIGH, JR.,
DEFENDANT
DECREE IN
DIVORCE
.V'A'?Xj -Zvl5R
AND NOW, Z O", IT IS ORDERED AND
DECREED THAT
DARLENE A. FARRANDS-NEIDIGH_ , PLAINTIFF,
AND SAMUEL E. NEIDIGH, JR. , 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 TIAE COURT:
ATTEST: J.
PROTHONOTARY
J J
?? ? ?n? '??°G? ? - 1 ?. ?
??.? ?? ? CGS ' ?? ?° ' l? ? r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
~~ r1P~ ~~~.r~~~n~s- ~1~~ ~ h
Plaintiff ~ ',
Vs File No. ~, ~ ~'
" ~ IN D ORCE _ T
i l~ ~
efe ant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff /defendant in the above matter,
[select one by marking "x"]
prior to the entry of a Final Decree in Divorce,
or ~ after the entry of a Final Decree in Divorce dated ~~
hereby elects to resume the prior surname of d gives this
written notice avowing his /her intention pursua the provisions of 54 P.S. 704.
~.
Date:
Sig ure
Q
Signature of name being resumed
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CumbcrlCtr~a~ )
a0/oZ.
On the ~l~ day of ~-up~,~gf , ~fifr ,before me, the Prothonotary or the
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 set my hand hereunto set my hand and official
seal. \
~ ~ ~M Prothonotary or No ary Pu c
Mht ~®pU~M~~dJ~.~N
{ ;~ .'S
d~1...~. ~t ~I(
~1~1 AUG 29 PM ~2: ~3
e ,~i+rr
~ 3. ~U ~,~ ~ ~~ ~~
N61t.~M1 m ~~ irq a,~ ~ ~~