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Home My WebLink About07-5136._~ JOSEPH R. FRANK, Plaintiff v. CHRISTINA L. FRANK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No.. o ~ ~ 5"13 ~ IN DIVORCE NOTICE TO DEFEND Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Respectfully submitted, SAIDIS, FLOWER & LINDSAY ~~ I1NllSAY 26 West High Street Carlisle, PA 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 inetrievable breakdown of the marriage, you may request marriage counseling. A fist of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. ' I.F "YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT t0 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. By IAfi" Matas, E~uire Supr Court ID #84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff .. JOSEPH R. FRANK, Plaintiff IN THE COLT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vi. CIVIL ACTION -LAW CHRISTINA L. FRANK NO ~ ~ ' S/ 3 ~ Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Joseph R. Frank, an adult individual currently residing at 2 Dandelion Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant is Christina L. Frank, an adult individual currently residing at 3379 Route 46 East, Apt. 2U, Parsippany, NJ 07054. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 11, 2005, in Allentown, Pennsylvania. 5. There has been no other prior action for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. FhO~VFdt ~ISz I~VDSAY 26 West High Street Cazlisle, PA 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to partiapate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Ma tas, Esgwre Attorney I No. 84919 Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 FIAVVE~~'SL LIlVDSAY 26 West High Street Cazlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. _. W ., DATE: _ ; _ ,. .. , seph .Frank, Plai tiff .~ ... SAII~IS, FLIONVJ~ 6z LINDSAY 26 West High Street Carlisle, PA ~~ +~. (~.~ ~'r = r ' ~ N ~ 0 D ~~ ~'~ ~ r ~ ~C W k p ~ c . t_' ~: ~ , =c> ~ ~ ~ ~~ ~ ~ ~ ~ -may ~ ~' A ~~ N E A- JOSEPH R. FRANK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, ENNSYLVANIA v. CIVIL ACTION -LAW NO. 0~- 53(0 CHRISTINA L. FRANK Defendant IN DIVORCE ACCfPTA-(~CE OF SERVtGE I, Christina L. Frank, Defendant, accept service of the Divorce Complaint in the above-captioned matter by U.S. Mail. Date Christina L. Frank FI~O'WF '6z LINDSAY z6w«:~s~ Culisle> PA ~ ~ ° c~ ~i _ --ca ~;, ~ m~3 !. '.~ J= ~ ~ ~ " ~ ~~ { V l ~ l ~ a rr J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH R. FRANK Plaintiff vs. CHRISTINA L. FRANK Defendant File No. 07-513b IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above matter, [select one by marking "x"] 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 Christina L. Schaffer, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: ~1 EJ{~p ~ .~ ~n~ ~- Christina L. Frank Christina L. Schaffer STATE OF NEW JERSEY COUNTY OF ~~ ~ `~ S Can the ~~ day cif ~ `_ _~.. 200 7, before me, the SAIL7IS, FIAWER Sz LINDSAY 26 West High Sweet Carlisle, PA 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 she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and Official Seal. ~iC -~ o r ~bli~ ~ _` ~ ~i ° ~ ~ ~ ~.,J ~ ~ t ..... ;~ ~ ~ S- ~ ~ ~.~ ~ ~~ N JOSEPH R. FRANK, Plaintiff v CHRISTINA L. FRANK Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed August 28, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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: IZ~ ~/ t~~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, ENNSYLVANIA CIVIL ACTION -LAW NO. 07-5136 IN DIVORCE ,,;~ --~ oseph .Frank PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 icl OF THE DIVORCE CODE 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 SAIDIS, F7AWER S~ IINDSAY 26 West High Strett Carlisle, PA 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 to the best of my knowledge, information and belief. 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: 1 Z J I ~-~~~ ~ ~".~ _. oseph R. rank s C'y G 4 ~~ ° --~ r '`` J ~`; . -t? ', „~ J ~'' ~ __ ~ `~ ~, , ~ ~ '' ~: c3~ " 3 ~ JOSEPH R. FRANK, Plaintiff v CHRISTINA L. FRANK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, ENNSYLVANIA CIVIL ACTION -LAW NO. 07-5136 IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed August 28, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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: l I~ x ~ ~n'~""~-~ Christina L. Frank. DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVI DECREE UNDER§ 3301 (c) OF THE DIVORCE BODE 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 { 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 SAIDIS, F~~OWER ~ LINDSAY 26 West High Street Cazlisle, PA 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 to the best of my knowledge, information and belief. 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: ~~ Christina L. Frank - ~ ~'~' ~- ~_. _~._~ :~ ~;-~ _ : ~u ~~m .-~, ~ ~, :.gib .~ .~ ~ .. JOSEPH R. FRANK, Plaintiff v CHRISTINA L. FRANK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, ENNSYLVANIA CIVIL ACTION -LAW NO. 07-5136 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on September 13, 2007, via U.S. mail. Proof of service was filed with the Court on September 26, 2007. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was signed: By Plaintiff: December 14, 2007 and filed with the Prothonotary on December 17, 2007. By Defendant: December 19, 2007 and filed with the Prothonotary on January 2, 2008. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301(c} of the Divorce Code was signed: By Plaintiff: December 14, 2007 and filed with the Prothonotary on December 17, 2007. By Defendant: December 19, 2007 and filed with the Prothonotary on January 2, 2008. FLOWER 8z. 26 West High Street Cazlisle, PA SAIDIS, FLOWER & LINDSAY r~~~~~~~~~~ Maryl atas, Esquire Supre Court ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 ~~ rr ~. r . t.... ~ ~ ~~ ~~. ; i .,.~ ;.~ J , r _a ~ ~s., ' ~ . ~ ~~ ~. ~ fi~ ~ ~ jM1 v, ; ' ..- r a sue. "1 '~~ "Jt'~l ~ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JOSEPH R. FRANK =~ ~, °~ N VERSUS CHRISTINA L. FRANK NO. 07-5136 DECREE IN DIVORCE AND NOW, C~/.__., L~=~ , ~~ IT IS ORDERED AND JOSEPH R. FRANK DECREED THAT AND PLAINTIFF, CHRISTINA L. FRANK 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 COURT: PROTHONOTARY ~~ ~~ti~~ .,