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Home My WebLink About03-5027KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff RANDY BISTLINE, Plaintiff ELKE BISTLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW 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 at:: Cumberland County Courthouse One Courthouse Square Carlisle, PA 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 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 (800) 990-9108 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff RANDY BISTLINE, : Plaintiff : ELKE BISTLINE, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~- CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I Request for a No-fault Divorce Under ~3301/c) of the Domestic Relations Code 1. Plaintiff is RANDY BISTLINE, who currently resides at 137 Summer Lane, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is ELKE BISTLINE who currently resides at 62 South Corporation St., Newville, Cumberland County, PA 17241. 3. Plaintiff/Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 3, 1981 in Germany. 5. There have been no prior annulment between the parties. 6. 7. actions of divorce or for The marriage is irretrievably broken. The Defendant is not a member of the armed services. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. There are no children born of the marriage. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to § 3301(c) of the Domestic Relations Code. COUNT II Reauest for a No-fault Divorce Under ~3301(d) of the Domestic Relations Code 10. Plaintiff hereby incorporates Paragraphs 9 of his Complaint as if fully set forth herein. and apart enter a Decree Relations Code. 1 through 11. Plaintiff and Defendant have been living separate since approximately August of 1997. WHEREFORE, Plaintiff respectfully requests this Court to of Divorce pursuant to § 3301(d) of the Domestic KE~NET~ F. LEWIS, ESQUIRE Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated:~/~ ~ KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff RANDY BISTLINE, Plaintiff ELKE BISTLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Plaintiff avers that Defendant is not in the Military Service or in any branch of the armed forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' civil Relief Act of Congress of 1940 and its Amendments. I hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. KENNETH F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff RANDY BISTLINE, Plaintiff ELKE BISTLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in August of 1997 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 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 are made subject to t.h.e penalties of 18 Pa.C.S. Secti~ relati~3~~ to unsworn falsification to authorities, f ~_~/ Dated: ~//~/03 ~L~~ KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff RANDY BISTLINE, Plaintiff ELKE BISTLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5027 civil CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I certify I have served the Complaint in Divorce upon the Defendant, Elke Bistline, by mailing same by certified mail, postage prepaid at Harrisburg, Pennsylvania addressed to: Ms. Elke Bistline, 62 South Corporation St., Newvi]le, PA 17241 and that Ms. Bistline received, and signed for, the Complaint on September 26, 2003, as evidenced by the return receipt attached below. KEN H . LEWIS, ESQUIRE .~ SENDER: I al~o wish to receive the · C~me~o ~ 1 mxVm' 2 for addltlm~d ~c~. Iol!owlng senates (for an ./~ac~,om~tothemoftlmmail~,~o. the~m~:~lf.P~ed"~"~ 1. [] Addres~ee's Addreas m,41v..d Consult postmaster for fee. , ~ ~ 3. arUcl~.~m~,~aedt.o: 7DD'I. 'l.q. gO DDD$ 4D'1,5 5D~, . · ,---,k D,3..I' -- -- ~ ........ -, ...... '¥'~ " ~ loc ~,~:" ~ /._ £[,../ ~ % I~ ExpreseMal~ [] insured -~ - Ps Fo~ ~11, Oe~mb~- ~4 D~T,~,~,C Retum Receipt RANDY BISTLINE, : Plaintiff : v. : : ELKE BISTLINE, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5027 Civil CIVIL ACTION - LAW IN DIVORCE PRAECIPE 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 Section ~ (X) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail; receipt signed on September 26, 2003; Affidavit of Service filed on September 29, 2003. 3. (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: 9/18/03; (2) Date of filing and service of the plaintiff,s affidavit upon the respondent: 9/18/03. 4. Related claims pending: NONE, no economic issues requested in Com laint. 5. Notice of intention to file praecipe (copy attached) served by regular mail upon Defendant on 4/].2/04. DATED: 5/5/04 Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff RANDY BISTLINE, Plaintiff v. ELKE BISTLINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5027 Civil IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF S330~(d) DIVORCE DECRI~E TO: ELKE BISTLINE, Defendant You have been sued in an action for divorce. You have failed to answer the complaint br file a counter-affidavit to the §3301(d) affidavit. Therefore, On or after ~[ay 5, 2004, the other party can request the court to enter a final decree in divoroe. 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 AFFO]~D ONEv 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 1-800-990-9108 ;AANDY BISTLINE, : Plaintiff : v. ELKE BISTLINE, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5027 Civil.' IN DIVORCE COUIq~ER-AFFIDAVIT UNDER SECTION 3301(4) OF THE DIVORCE CO~ 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.p~rlod 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 in addition ko 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 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. Section 4904, relating to unsworn falsification to authorities. DATE: ~LKE BISTLINE, Defendant NO?ICE~ IF YOU DO NOT WISH TO OPPO~ THE ENTRY OF A DIVORC2 D~CRE2 AND YOU DO NOT WISH TO MAKE ANy CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. IN THE COURT OF COMIViON OF CUMBERLAND COUNTY STATE OF RANDY BISTLINE VERSUS ~T ~T.T~ PENNA. NO. 03- PLEAS DECREE IN DIVORCE AND NOW,. DECREED THAT AND ~ ~ANDY BISTLINE ELKE BISTLINE , J~J~04~, IT IS ORDERED AND , PLAINTIFF, , 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; ~~ n/a ATTEST: J. PROTHONOTARY