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HomeMy WebLinkAbout07-62849 v HEATHER J. BRETZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DAVID L. BRETZ, : NO. 07- -(,,,2 y CIVIL TERM Defendant : IN DIVORCE NOTICE 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 irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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. V HEATHER J. BRETZ, V. DAVID L. BRETZ, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07- 6.2 Wy CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Heather J. Bretz, who currently resides at 9 Falcon Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is David L. Bretz, who currently resides at 3514 Walnut Street, Apt. D, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 14, 2001, in Mechanicsburg, Pennsylvania 5. Plaintiff and Defendant separated on or about July 1, 2006. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 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. Neither party is now serving in the United Armed Forces, nor have ever served in the United States Armed Forces. 10. Plaintiff requests the Court to enter a Decree in Divorce. By: Paul Bradford Orr, Esquire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 71786 VERIFICATION I verify that the statements made in the foregoing Petition 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. r DATE: Heather J. Bretz, etitioner \ cr? t ?, f 'j C `v t HEATHER J. BRETZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DAVID L. BRETZ, : NO. 07- 6284 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OFCUMBERLAND ) AND NOW, this 6T" day of November, 2007, 1 Paul Bradford Orr, Esquire, attorney for Heather J. Bretz, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above- captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original return receipt card signed by the Defendant on November 5, 2007, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. LA Dated: BY Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 I. D. # 71786 V ¦ Complete items 1, 2, and 3. Also complete Rom 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 1A \ )i ? Agent B. Received by (Printed Name) 11fate of Del If YES, enter delivery address below: 13 No ix V I ? L ? Addressee D. Is delivery address different from item* 13 Yes 3. Service Type Certified Mall ? Express Mail Registered "R Return Receipt for Merchandise ? Insured mail ? C.O.D. 4. RestrlCted Delivery? (Extra Fee) O(Yeg 2• Article Number ? 7003 1010 0001 1204 7894 (Transfer teem service /abeq PS Form 3611, Fmnwry 2004 Don?ltc Rlrtum.FMoW 10e0e5-o2-Wt540 EXHIBIT "A" ?.? . ?, =? G .a ? ^x '? ? 4i `i-? ?" = i,,,,.. r •} 3` ,J .. ?! -` ?` 1 r._S *'^ 49 ;v- c =? !_ HEATHER J. BRETZ, V. DAVID L. BRETZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 07- 6284 Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) & (d) of the Divorce Code was filed on October 26, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. Date: Heather J. Bre , Plaintiff <:u --.-a s I ?„_ .i.` ? '- ? ?l;:m ;M.? s• . - r? - _ .. _. ? .. HEATHER J. BRETZ, V. DAVID L. BRETZ, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07- 6284 Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) & (d) of the Divorce Code was filed on October 26, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. C? e Date: G? - ON 0g ?.. David L. Bretz, Defendant C_ 7 -=i k '' ? --"{ --r _ i ?' . z t ?, ._ ?-j: I' ? ?'?: _ rJ' " ' G? , . i? i ..fix ? - W `?. ? ? . , . .J HEATHER J. BRETZ, V. DAVID L. BRETZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07- 6284 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) & (d) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. §4904, relating to unsworn falsification to authorities. Date: David L. Bretz, Defendant r>'s ,`? ?? ram ?? ' T' `S " ( Y - e ,,., i ? ? „. r __ T`, ?? ..- ,_. ?._ ('`i .? ? .a ?J ?. HEATHER J. BRETZ, V. DAVID L. BRETZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07- 6284 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) & (d) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. §4904, relating to unsworn falsification to authorities. Date: ,;7. ti c1 Heather J. Bre Plain iff C ? `?' x ?.a = ? . r} = ? ?``?. ,_ l1,«1 ?, ',`'" 'rte. "?' .. HEATHER J. BRETZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DAVID L. BRETZ, : NO. 07- 6284 CIVIL TERM Defendant : 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 3301(c) & (d) of the Divorce Code. 2. Date and manner of service of the complaint: November 5, 2007, by U.S. Mail, postage prepaid, certified, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) & (d) of the Divorce Code: by the Plaintiff on May 23, 2008; by Defendant on May 23, 2008. 4. Related claims pending: NONE 5. Date Plaintiff's Waiver of Notice in §3301(c) & (d) Divorce was filed with the Prothonotary: May 27, 2008. 6. Date Defendant's Waiver of Notice jn §3301(c) & (dj Divorce was filed with the Prothonotary: May 27, 2008. Date: B Y• W1j t aul Bradford Orr, Esquire 50 East High Street Carlisle, PA 17013 (717) 258-8558 "`' ; ?? ?? -- ?? ? Y-? %? , - ,., , =? ..,T; = ?. ?' ?,., ?, =G V! 11, Vs i- $ + IN THE COURT OF COMMON PLEAS + + + OF CUMBERLAND COUNTY + + STATE OF PENNA. + + + + HEATHER J. BRETZ, + + No. 6284 of 2007 + + Plaintiff + + + + VERSUS + DAVID L. BRETZ, + + + + Defendant + + + + DECREE IN + + DIVORCE + + + + + + + + AND NOW, Z:up !_ ]: , 266 , IT IS ORDERED AND + + + + DECREED THAT HEATHER J.BUTZ PLAINTIFF, + AND DAVID L. BUTZ 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; + + + + BY THE CO T: + + ATT T: J. + + + > PROTHONOTARY