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HomeMy WebLinkAbout07-3804•r Jennifer E. Paup IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 3$Oy CIVIL TERM Michael A. Paup 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 Jennifer E. Paup IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 3 £s0 q CIVIL TERM Michael A. Paup Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is J e o n( fC X14 , who currently resides at _,1(55 Cumberland County, Pennsylvania. 2. Defendant is jic-'?Ojj c U D , who currently resides at sit) ?)ett)cam?jal"d L-? /70,70 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 at 5. The marriage is irretrievably broken, and the parties separated on 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. P 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. L1 ti Date Plaintif , Pro f) I, n ff Awp verify 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 unswom falsification to authorities as provided in 18 Pa. C.S. §4904. L'Ial ('l Date: Assis ed by: - -7 1?;? Marcus A. Mc night, III, Esqii Irwin & McKnight Law Offices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 C N c? -on rv cl e- cz rn C) Jennifer E. Paup Plaintiff v. Michael A. Paup Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 3 kVV CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jennifer E. Paun, Plaintiff, to proceed in forma au eris. I, Marcus McKnight, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. June 25, 2007 Irwin & McKnight Law Offices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 Q O C. rt`t r'r; C __ IV C' Ln -< C3 JENNIFER E. PAUP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW • 3P?? NO. 2007 - 3498 CIVIL TERM MICHAEL A. PAUP, 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, Michael A. Paup, on June 26, 2007, by certified, restricted delivery mail, addressed to him at 101 Market Street, New Cumberland, Pennsylvania 17070, with Return Receipt Number 7004 1350 0003 7289 3488. hereof. 3. That the said receipt for certified mail is signed and attached hereto and made a part I verify that the statements made in this affidavit are e and correct. I understand that false statements herein made are subject to the penalties o Pa. C. S. Section 4904, relating to unsworn falsification to authorities. MARCU*A. McEWHT, III, ESQUIRE Attorney for Plaintiff Date: June 29, 2007 CEFfrI IFC (Domestic Mail Or Ir 43 ru Postage $ M O Cerdlled Fee 0 0 Return Redept Fee (6Woreernent Requ O Ln M a Total Postage & Fees S C3 aw# To r3 M HI? ? -- Q N >o UNIT O v rn if '` o T co e? 91g0Z A PAUP MARKET STREET ¦ Complete Items 1, 2. and 3. Also oon *% Kern 41f Reabicted Delivery Is desired. ¦ Print yotu name and address on the roverse so that we can Mum the card to you. • Atbwh this card to the bads of the mailpiece, or on the front if space permits. 1. Artlcie Addressed to: MR MICHAEL A PAUP 310A MARKET STREET NEW CUMBERLAND PA 17070 v ?- ?c O Z M Z-1.1 00 jo A ? 0 Apart 13 cAddresses B. r by &C 41 -410 D. Is dellvay address Ilan 1? ? Yea If YES, wvW dedvay address below: ? No a Type /?d Meq C?, MM O Rephtened 7tpeaxrr Receipt for MaGiprrdlse 2" mwxfsrftmswv?wkw 7004 1350 0003 7289 3488 PS Form 3811, February 2004 Dom ft AeWm A - lpt 102595-024A-1540 r? ? ? C,;; _.. R ? z_'° C..... ? ' _ -. _- i ...,. .^' " Y s- ,., ?' 1..F? „? ?::. JENNIFER E. PAUP, Plaintiff V. MICHAEL A. PAUP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3804 CIVIL TERM 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:. March 10, 2009 MICHAEL A. P UP Defendant N r t"2'F?? Z '' 7y m. - Fn JENNIFER E. PAUP, Plaintiff V. MICHAEL A. PAUP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3806 CIVIL TERM IN DIVORCE PLAINTIFF'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 unworn falsification to authorities. Date: March 10,- 2009 J.L -a,?2 JENNIFER . PAItP Plaintiff cr cr, JENNIFER E. PAUP, Plaintiff V. MICHAEL A. PAUP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 -3804 CIVIL TERM 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: mare-1h in _ 7009 -4c 'All JE IF E. PAUP Plai tiff P O t. ? ?Ln cr% JENNIFER E. PAUP, Plaintiff V. MICHAEL A. PAUP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3804 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: March 10, 2009 MI HAEL A. PAUP Defendant C? JENNIFER E. PAUP, Plaintiff V. MICHAEL A. PAUP, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - 3804 CIVIL TERM 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: March 10, 2009 MICHAEL A. PAUP Defendant ? ? ? i _ s" ° `'? ? u tr rr, ?? rn f_., k ?? ? V .?-- r ?? ?,: ?._ cu ?'' - ? . JENNIFER E. PAUP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2007 - 3804 CIVIL TERM MICHAEL A. PAUP, Defendant IN DIVORCE To the Prothonotary: (b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with 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) 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, Michael A. Paup, on or about June 26, 2007, by certified, restricted delivery mail, addressed to him at 101 Market Street, New Cumberland, Pennsylvania, 17070, with Return Receipt Number 7004 1350 0003 7289 3488. 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: March 10, 2009; by defendant: March 10, 2009. (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: March 11, 2009. March 11, 2009. PRAECIPE TO TRANSMIT RECORD Date defendant's Waiver of Notice in Section 330 1 (c)4&vorc7was filed with the Prothonotary: A. McKnight, III, Esquire y lbf Plaintiff Date: March 11, 2009 r? c' 7 r ? W :77 cr) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA Vs File No. IN DIVORCE a ej Pa L)IQ Defendant 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 ? /() (6 , and gives this written notice avowing his / her intention pursuant to the provisions of 54 704. Date: j0 d ?#atuie COMMONWE TH OF PENNSYLVANIA COUNTY OF p q ignatur f name being resumed On the day of , 200x, 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. NOTARIAL of Publi PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE: MY COMMISSION EXPIRES JANUARY 4, 2010 O r ? ?:s .?, .? -,? -?__ ? ? x? - ? ? ?? ?' w ? ? ?? L. t G o?.'S??lr1?,3 : IN THE COURT OF COMMON PLEAS OF JENNIFER E. PAUP : CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL A. PAUP NO. 2007 - 3804 CIVIL TERM DIVORCE DECREE AND NOW, m an" i8' Zao , it is ordered and decreed that JENNIFER E. PAUP , plaintiff, and MICHAEL A. PAUP , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE. By the Court, 1/14 A t: J. r -q .