HomeMy WebLinkAbout03-5585
II
II
CHRISTOPHER L. POITRINAL,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION, LAW
NO. 03- :fSY)'
KATE F. POjJ"RINAL,
Defendant
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 foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Courthouse
1 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
Telephone: (717) 249-3166
CHRISTOPHER L. POITRINAL,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.
KATE F. POTRINAL,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that
in accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
II
CHRISTOPHER L. POITRINAL,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 03- 5..fY'J/
KATE F. PO/TRINAL,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, CHRISTOPHER L. POITRINAL, by his
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is CHRISTOPHER L. POITRINAL, an adult individual who currently
resides at 706 State Street in Lemoyne, Cumberland County, Pennsylvania.
.
2. The Defendant is KATE F. PO;rRINAL, an adult individual whose precise
address is unknown to the Plaintiff but she is employed at Coakley's Restaurant at
305 Bridge Street in New Cumberland, Pennsylvania and who can be served there.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 4 September 2000 in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE. Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
~L. An s
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne. Pa 17043
(717) 761-5361
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 1 8
Pa. C.S. 4904 (unsworn falsification to authorities).
Date: fo I/fe, /0 S
CHRISTOPHER L. POITRINAL,
Plaintiff
IN THE COURT OF COMMON
PLI:AS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION, LAW
KATE F. POITRINAL,
Defendant
NO. 03-5585 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSEI\IT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
3 October 2003 and was served upon the Defendant on or about 4 November 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
ays have elapsed from the date of filing of the complaint and the date of service of the
omplaint on the Defendant.
3. I consent to the entry of a final decree in divorc,s either after service of a Notice of
ntention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
ntention to Request Entry of the Decree.
4. I have been advised of the availability of marria~le counseling and understand that
he Court maintains a list of marriage counselors and that I may request the Court to require
,'y spouse and i to participate in counseling and, being so advised, do not request that the
ourt require that my spouse and I participate in counseling prior to the divorce becoming
ina!.
I verify that the statements made in this Affidavit are true and correct and I
nderstand that false statements herein are made subject to the penalties of 18 Pa. C.S.
ection 4904 relating to unsworn falsification to authoritiels.
<S\~\D-\
ATE
r:A/~
CHRISTOPHER L. POITRINAL
~
C".)
",,-
Cl
~n
.....
:r: -n
t-t1i;
-1"1r11
'LiO
(') ,.L,
'~~-;h
t'~~rJ
'::,i";':"')
"'~"; i11
s:!
~ci
-.
.",.
c::::
G'")
\
C../l
:;;'!:l<
::~',:
'-!?
c::>
~
I
I
I
I
i CHRISTOPHER L. POITRINAL,
! Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
KATE F. POITRINAL,
Defendant
NO. 03-5585 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSEINT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
3 October 2003 and was served upon the Defendant on or about 4 November 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
ays have elapsed from the date of filing of the complaint and the date of service of the
omplaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
ntention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
ntention to Request Entry of the Decree.
4. I have been advised of the availability of marria~le counseling and understand that
he Court maintains a list of marriage counselors and that I may request the Court to require
y spouse and I to participate in counseling and, being so advised, do not request that the
ourt require that my spouse and I participate in counseling prior to the divorce becoming
inal.
I verify that the statements made in this Affidavit are true and correct and I
nderstand that false statements herein are made subject to the penalties of 18 Pa. C.S.
ection 4904 relating to unsworn falsification to authorities.
~J!
, 'ii~_ ~
A F. POITRINAL
~.
'.;?
"?
:P'
(-
G)
\
(..,.
o
-'n
:.:;1
~~_~"n
[l1~
-0 (l}
::nC(
()C)
..~.~ "'r
"_1:4-"
0;;5
:<.(1.'1
(:~~
:e:
E:
~.~'.'
::.:..
"';'i_
'-P.
o
:;;:-
':
,
':
I
! CHRISTOPHER L. POITRINAL,
, Plaintiff
I
)
)
)
)
)
)
)
)
)
vs.
KATE F. POITRINAL,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PI:NNSYL VANIA
CIVIL ACTION.. LAW
NO. 03-5585 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 rc) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
awyer'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
ourt and that a copy of the decree will be sent to me immediately after it is filed with the
rothonotary.
I verify that the statements made in this Affidavit are true and correct. I under"tand
hat false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
elating to unsworn falsification to authorities.
~' I ///!!t.~~. ;:;/. ",-
'J. ,,.' ,I ~
" /---",.,
CHRISTOPH~R L. POITRINAL
,....,
co
=
.<:"
~:
G'J
\
t.n
~.:
((,
31....1'\
f\i~
-(Jto'"
~1J
c'b
.~~~, ":t\
725
,"~\'~ \'T\
'~':.?t
?l3
.'<.
...p,
o
:;;:-
II
CHRISTOPHER L. POITRINAL,
Plaintiff
INI THE COURT OF COMMON
PL.EAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
KATE F. POITRINAL,
Defendant
NO. 03-5585 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 33011c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
awyer'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
ourt and that a copy of the decree will be sent to me immediately after it is filed with the
rothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand
hat false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
elating to unsworn falsification to authorities.
S--~-C>'f
ated;
~f~I~~L '}
r-->
=
c:;;!
-""'
o
-11
~-n
rn'~
--om
coS?
q<;;
I.-'r!
'::>(')
'g\rn
'-!? ~
'2
:i~
(-"~
G")
,
,.)1
c::>
.;-
.,
CHRISTOPHER L. POITRINAL,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION.. LAW
KATE F. POITRINAL,
Defendant
NO. 03-5585 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I hereby accept service of the Complaint in Divorce and acknowledge that it was
served upon me on 4 November 2003.
~'
'~
TE F. POITRINAL
g-s-o,-/
~
5i::'
:t:',,,.
c.::-:':
(i;;
\
(i"1
~:
o
-t',
.-1
-r: -n
fi'\:n
:?lO
"",,,) 1..
"";',C>
''::c.:H
c!.-'C')
~:',,~rn
\::~.?\
....R
~rg
C>
J;'
CHRISTOPHER l. POITRINAl,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVil ACTION... lAW
KATE F. POITRINAl,
Defendant
NO. 03-5585 CIVil TERM
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. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceotance of Service filed bv Plaintiff's
counsel indicatina service on or about 4 November 2003.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301
(c) of the Divorce Code: By Plaintiff: 3 Auaust 200'~ By Defendant: 3 Auaust
2004
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
4. Related claims pending:
None.
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is
attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: Dated 3 Auaust 2004. and filed contemooraneouslv
herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: Dated 3 Auaust 2004. and filed contemooraneouslv
herewith.
Date: 3 August 2004
'~
By <.:::
- ~amuel L. Andes
Attorney for Plaintiff
()
c:,
'.;?
c;:)
:.s:-
,,~
c:'.
G~)
\
,..11
".;,.,
"
~-;::f
':::2.
<;,;
-'
:f.-n
r't\c:
_Onl
~nO
("-"') :1.....
:;:-I~.
-C:...-
'?~-,:~
'::-"7''- ~
-"..("
':.:3
7'
3.
.1-;~
.~
'-F!
o
'.1'
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
" .
.
. ..
:+: :F.:+:;Ii ;+;
...
...
.
..
.
..
. . .
.
.
.
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
.
PEN NA.
STATE OF
.
.
.
.
.
.
CHRIS'IDPHER L. POITRINAL ,
.
.
.
Plaintiff
No.
03-5585 Civil Term
VERSUS
.
.
.
.
.
.
.
KATE F. POITRINAL,
Defendant
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
DECREE IN
DIVORCE
j q~(~"
.
DECREED THAT
, PLAINTIFF,
AND NOW,
, 2004
, IT IS ORDERED AND
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
AND
Kate F. Poitrinal
, 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;
.
~IORC
~ ~-I."...
\~ ~-'< ( ,
-"
.... ............'"
~...~....
".~ ..-
'-, ..
, ,
, ,
j
"'"
J,
'--""
"
-', ,:..
0""
/
-
A
,,-"~ .,,~ "'_.~..... _..:;,-~
\,"" ..... ...~ "
\.-, ""J -. ...........':....- '-\'
..,:,. ~':''' ~\"lO
~"......'"
PROTHONOTARY
. .
'" ;+;'t;:+; :+: ;t;'f.;t;
Of. :of. :f ;t;;t;;f.'I; Of.
Of. '" "''+';t; ;t;'f' :+:;t;;+:",'f'
. .
.
:to;t; ~~
.
+
.
+
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
+
.
.
.
.
.
,
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
+
.
.
.
.
.
.
.
.
.
.
.
.
.
+
.
+
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
+
. +'
, ~ ~ ~ _??~ ~~ Ar?'II,~
~ ~ ~ ~ ~ ~ A,;?/r.jS
:
.' .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
e }.'(",S-Tophe..r L. -Poitr ;T'\(LI.
Plaintiff
Vs
FileNo. b,>_c-;-~,<;,5
IN DIVORCE
~(l:k ~, lliihiflQ\
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
_ prior to the entry of a Final Decree in Divorce,
or ~ after the entry of a Final Decree in Divorce dated Al-\Wd- II,. d-.c'OLt '
hereby elects to resume the prior surname of WII\( (l1Y) s. ,and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P.S, 704.
,
Date: i\\y, \ d.d-, riDc6 jQ~O~ )
Signature
h Ml1..u:....~ __
Signature of name being resumed
COMMONWE;(\LTH OF PI;NNSYL VANIA ) .
COUNTY OFClAmber\and)
On the ~ day of ~ --\ ~ 2 , 2005, before me, the 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 he / she executed the
foregoing for the purpose therein contained.
sea],
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
fl1)~J~hYlL
Prothonotary or Notary Public
NOTARIAL SEAL
PROTHONOTARY, NOTARY PUBLIC
;AHUSlE CUMBERlAND COUNTY COURT HOUSE
I M:,:.~~MISSION EXPIRES JANUARY 2, 2000 __
0 r-" C,
C:::';:)
...., l.::',:' Tl
A:J <:':""1
~ ~ :L~';
~-"'~'
0 i"\:'i ..
() N
.....
~ ~
I..> I!:.'
~ en
~ r c:'
t