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Home My WebLink About07-5898DENISE MEYER Plaintiff V. DEAN MEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 6 7- 5-c 99 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 South Bedford St. Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 r DENISE MEYER Plaintiff V. DEAN MEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- s'Syf CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Denise Meyer, who currently resides at 59 Partridge Circle, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Dean Meyer, who currently resides at 65 Ngaio Road, Waikanae, New Zealand 5036. 3. The Plaintiff and Defendant have been separated for six months. 4. The Plaintiff is a resident of Pennsylvania and the Defendant agrees to the venue of Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant were married on April 13, 2001. COUNT I - DIVORCE 6. Paragraphs 1 through 5 of this Complaint are incorporated herein by reference as though set forth in full. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Divorce is sought pursuant to the provisions of the Divorce Code, § § 3301(c), and 3301(d), in that: a. The marriage is irretrievably broken. r b. Plaintiff and Defendant have lived separate and apart since, May 1, 2007, and continue to do so. 9. 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 such counseling. 10. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, ? n Date: -07 By: Andrew H. Shaw, Esquire Sup. Ct. ID No. 87371 200 S. Spring Garden Street Suite 11 Carlisle, PA 17013 (717) 243-7135 Attorney for Plaintiff VERIFICATION I, Denise Meyer, verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: / C? V 7 Denise Meyer s` CIO G DENISE MEYER Plaintiff V. DEAN MEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. () 1`l -59q CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE I, Andrew H. Shaw, Counsel for the Plaintiff, Denise Meyer, hereby certify that a true and correct copy of the Divorce Complaint in the above captioned case was served upon Defendant via First Class Mail on October 6, 2007. A copy of the Acceptance of Service is attached. Date:/ 0 '',,,2 Q -V Andrew H. Shaw, Esquire Counsel for Plaintiff PA Sup. Ct. ID Num. 87371 200 S. Spring Garden Street Suite 11 Carlisle, PA 17013 (717) 243-7135 z DENISE MEYER Plaintiff V. DEAN MEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5898 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE Date: I, Dean Meyer, hereby accept service of the Divorce Complaint. Dean Meyer, Defendant 65 Ngaio Road Waikanae New Zealand 5036 C'? CZ) f Ci DENISE MEYER Plaintiff V. DEAN MEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5898 CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, prior to the entry of a Final Decree in Divorce, hereby elects to resume the prior surname of Bowers, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. § 704. Date: P. Denise P. Meyer COMMONWEALTH OF PENNSYLVANIA kP. eDenise P. Bowers SS COUNTY OF CUMBERLAND On the L/-day of ?(?' ??GbEr 2007, before me, a 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. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Andrew H. Shaw, Notary Public Carlisle Boro, Cumberland County My Commission Expires Oct. 24, 2010 Member, Pennsylvania Association of Notaries eL-- t--l' CA) C?l fcs?, 4CO I DENISE MEYER Plaintiff V. DEAN MEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5898 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under s 3301 (c) of the Divorce Code was filed on October 5, 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 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 subject to the penalties of 18 Pa. C.S. s 4904 relating to unworn falsification to authorities. Dated: 7 "-)vz ?, ' -?? 0 11'a enise Bowers. Vki-Xbe-msc- Plaintiff 0 rn ' •' ? 4A.Y v.w( DENISE MEYER Plaintiff V. DEAN MEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5898 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301 (c) of the Divorce Code was filed on October 5, 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. 1 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 subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dated: Dean Meyer, Defendant r?g on 77 3 t DENISE MEYER Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.01- ,j,g qq DEAN MEYER Defendant 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 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 are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. DATE: UAzwo L,2 Denise Bower, fWa-Denise Meyer, Plaintiff Q .,,? 0:, DENISE MEYER Plaintiff V. DEAN MEVER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5898 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUES'T' ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) 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 are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. DATE: 4 `19 Dean Meyer, Defendant r-a 0 t 60 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DENISE MEYER, Plaintiff V. DEAN MEYER, Defendant To the Prothonotary: No. 07-5898 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Via Certified Mail, Return Receipt Requested, No. 7005 1820 0002 4614 9447, October 6, 2007. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff on January 7, 2008; by Defendant on January 6, 2008. 4. None. 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary's Office: January 7, 2008. Date Defendant's Waiver of Notice was filed with the Prothonotary's Office January 7, 2008. Date: /- 7-- Ve By: Andrew H. Shaw, Esquire Attorney I.D. # 87371 Attorney for Plaintiff 200 Spring Garden Street, Ste. 11 Carlisle, PA 17013 ?. "S r 3 A`. I.yTT1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. DENISE MEYER No. 07 5898 VERSUS DEAN MEYER DECREE IN DIVORCE AND NOW, JQ^ %36, 2008 , IT IS ORDERED AND DENISE MEYER DECREED THAT PLAINTIFF, DEAN MEYER AND 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: ?k -? ATTEST: J PROTHONOTARY 75- 5a._ I! -I