The URL can be used to link to this page

Home My WebLink About03-5364ROBERT E. WASHINGER, Plaintiff VS. SUSAN VON STEiN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 0 3~ ~"~q Civil Term ACTION 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 divome 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of maniage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 ROBERT E. WASHINGER, Plaintiff VS. SUSAN VON STEIN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COL~ITY, PENNSYLVANIA : No. ~ -~- ,5~$ 6 ~ Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Robert E. Washinger, a competent adult individual, who has resided in Carlisle, Cumberland County, Pennsylvania, 17013, since 199'7. 2. Defendant is Susan Von Stein, a competent adult individual, who has resided at 883 Mount Rock Road, Carlisle, Cumberland County, Pennsylvania, 17013, since 1978. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were parties to a comanon law marriage in Cumberland County; an document evidencing the common law marriage was signed on July 31, 1991. (Please see Exhibit A) 5. There have been no prior actions of divoree or for mmulment between the parties. 6. Plaintiffhas 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the/tuned Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to emer a decree in divorce. Respectfully submitted, /~a~ ^d~s, Esqu'~re ~ ( I~ .No. 79465 '~36 ~outh Pitt Street Carlisle, l?a. 17013 (717) 245 -8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Rbbert E. /qashinger, Plai~J~f ' ROBERT E. WASHINGER, Plaintiff VS. SUSAN VON STEIN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. ~)~' ~/ Civil Term : : ACTION IN DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated in September 1993 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 my rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification to authorities. Robert E. Washinger, Plainti~ ROBERT E. WASHI~GER, Plaintiff VS. SUSAN VON STEIN AND NOW, on or about October 1N DIVORCE, and ~ receipt requested, res~ Susan Von Stein 883 Mount Rock Roa~ Carlisle, Pa. 17013 DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03 - 5364 Civil Term ACTION 1N DIVORCE Defendant AFFIDAVIT OF SERVICE is October 23, 2003, I, Jane Adams, Esquire, hereby certify that 2003, a certified true copy of the NOTICE TO DEFEND, COMPLAINT ~IDAVIT OF SEPARATION, were served, via certified mail, return icted delivery, addressed to: JJ~e Adams, Esquire '~ I.D.\No. 79465 36)gouth P:[tt Street '"~--C~ffrlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF HAROLD D. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT ETREET CARLISLE PA 17013 (7'17) 243-6000 ATTORNEY FOR DEFENDANT ROBERT E. WASHINGER, Plaintiff SUSAN VON STEIN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 03 - 5364 CIVIL TERM : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1 'l //"Check either (a) or (b): v (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 period 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) wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. In understand that in addition to 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 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 unsworn falsification to authorities. February 4, 2004 ~'~J I J~ ~'~ SUS~AN YON STEIN NOTICE: If yOU do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file this ROBERT E. WASHINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff: CUMBERLAND COUN'~, PENNSYLVANIA ., VB SUSAN VON STEIN, Defendant : CIVIL ACTION - LAW : : NO. 03 - 5364 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330'1(CI 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 divomed 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 unswom falsification to authorities. February 4, 2004 SUSAN VON STEIN ROBERT E. WASHINGER, Plaintiff VS. SUSAN VON STEIN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03 - 5364 Civil Term : : ACTION 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 deerce: 1. Ground for divorce: irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted- delivery. Delivered on: October 17, 2003. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff: October 8, 2003. Date of filing and service of the plaintiffs affidavit of separation required by §3301 (d) of the Divorce Code on respondent: Filed: October 9, 2003. Served on Defendant: October 17, 2003. Affidavit of Service filed: October 23, 2003 4. Related claims pending: No claims raised. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Notice of intention was forwarded to Defendant's Attorney; Defendant signed a Waiver of Notice Dated February 4, 2004, and filed February 9, 2004. Date: Respectfully Submitted: yJan~ Adams, ss~irc I.D~./No. 79465 --36 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS Robert E. Washinger, Plaintiff VERSUS Susan Von Stein, Defendant OF CUMBERLAND COUNTY STATE OF PENNA. No. 03 - 5364 Civil Term NO. DECREE IN DIVORCE AND NOW, ~.g, I ~ Robert E. Washinger DECREED THAT Susan Von Stein AND , Z.¢'"l . 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; None. ~/F/ ~ ~/ P R O O N O TA ATT E