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Home My WebLink About07-6932 IN THE COURT OF Nancy L. Myers, Civil Action - Law Plaintiff V V. No. Robert L. Myers, Defendant In Divorce a.v.m. 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 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 Courthouse, Carlisle, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Bar Association - Lawyer Referral Service Telephone 1-800-692-7375 (PA ONLY) or 717-238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. In 1 rnE UV URT OF COMMON PLEAS OF PENNSYLV. CUMBERLAND COUNTY Nancy L. Myers, Plaintiff Civil Action -Law v. No. O. 6 Q 3 2 Ci,, :d Robert L. Myers, Defendant In Divorce a.v.m. --_- ?i•? ivi? J3U1 A OR 3301 C OR OF THE DIVORCE CODE COUNTI DIV-_ 1. Plaintiff is Nancy L. Myers, a sui juris adult, who currently resides at 180 Fogelsan er Ro Shippensburg, Cumberland County, Pennsylvania. g ad, 2. Defendant is Robert L. Myers, a sui juris adult, who currently resides at an unknown locati in Newburg, Cumberland County, Pennsylvania. Defendant still receives mail at 180 on Fogelsanger Road, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least si months immediately prior to the filing of this Complaint. x 5. There have been no prior actions of divorce or annulment of marriage between the arties except the action represented by this Complaint. p 6. The parties were married on March 3, 2000. 7. The marriage is irretrievably broken. 8. Neither the Plaintiff nor Defendant is a minor or incompetent. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the ri h request that the court require the parties to participate in counseling. g t to WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II T FOR A FAULT DIVOPPE T TAT CODE O 10. The prior paragraphs of this Complaint are incorporated herein b forth in full. y reference as though set 11. Plaintiff avers that in violation of their marriage vows and the law Pennsylvania, Defendant has committed adultery. s of the Commonwealth of 12. Plaintiff is the innocent and injured spouse. 13. This action is not collusive as defined by Section 3309 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a D Pursuant to Section 3301(a)(2) of the Divorce Code. ecree of Divorce COUNTIII E UITABLE DISTRI N SECT IAN 3502 14. The prior paragraphs of this Complaint are incorporated herein b forth in full. y reference as though set 15. The parties have been unable to determine and equitably dis ose and interests in the marital property. P of their respective rights 16. Plaintiff will, within 60 days after service of this Complaint upon filed an inventory and appraisement of all property owned or the Defendant, cause to be Complaint is filed. Possessed at the time this WHEREFORE, Plaintiff requests your Honorable Court toeguitabl and assign the marital property pursuant to the provisions of Section 35 y divide, distribute 02 of the Divorce Code. FOR CP(lT TV A T .1. TT--- C0 "1?1'-n 3tu11ONS 3701(a) AND 3702 OF THE DIVORCE CODE LIMON 17. The prior paragraphs of this Complaint are incorporated herein b forth in full. y reference as though set 18. Plaintiff is unable to sustain herself during the pendency of the divorce action. 19. Plaintiff lacks sufficient property to provide for her/his reaso sustain herself through appropriate employment in accordance with the needs and is unable to established during the marriage, a standard of living WHEREFORE, Plaintiff respectfully requests that the Court enter of spousal support and/or of alimony pendente lite until the termination of litigation and, at th award e appropriate time, enter an order of alimony in her favor pursuant to Sections 3 Divorce Code. 701(a) and 3 702 of the Respectfully submitted: TRGOVAC LAW OFFICE Date:_, ZIA U / C./ By: V-M TERI HA L STIL ER, ESQUIRE Attorney I.D. No. 86337 The Professional Arts Building 25 Penncraft Avenue, Suite 310 Chambersburg, Pennsylvania 17201 (717) 262-9091 Attorney for Plaintiff I verify that the statements made in this Complaint are true and correct, and understand that false statements herein are made subject to the ena "worn ' to that false s falsification to authorities. p lhes of 18 Pa.C.S. Section 4904, relating Nancy L. My s 7j ?w t- ^0 ?? gym? N cz C:a w c.n r (L4> "?y t? 11 { IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Plaintiff V. Robert L. Myers, Defendant Civil Action - Law No. 07-6932 In Divorce a.v.m. AFFIDAVIT OF SERVICE OF COMPLAINT IN DIVORCE BY CERTIFIED MAIL M. Teri Hall Stiltner, Esquire, counsel for Plaintiff, Nancy L. Myers certifies that a true and attested copy of a Complaint in Divorce was deposited in the U.S. Mail at Chambersburg, Franklin County, Pennsylvania for delivery to the above-named Defendant, Robert L. Myers by Certified Mail, Restricted Delivery Return Receipt Requested on November 21, 2007. Defendant, Robert L.Myers received the aforementioned Complaint in Divorce as evidenced by the return receipt attached hereto, and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalities of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date ?G x,?G a7 dd67 By: 11 Respectfully Submitted: TRGOVAC LAW OFFICE M. Teri Hall Stiltner, Esqu re Attorney I.D. No. 86337 The Professional Arts Building 25 Penncraft Avenue, Suite 310 Chambersburg, Pennsylvania 17201 (717) 262-9091 Fax: (717) 262-9095 Attorney for Plaintiff 7007 0710 0005 6421 1333 m o? o m 70? ?? ? ? mm Z c ma 0 i w (D m cx I . n . n . - omm ICE 7007 0710 0005 6421 Lddd 1$m ;? ° x 3 ° m 51 `° 3 °0 M m m ° 33 ° ' ? ? fl0 m °c Q ?m ? a °m6 A f7t ? ?... W F C> C?q too 13 O Eml' T is Y" fog W" o. o; 0 Ln O' ru L-j !-' w UJ W ? IDo? fit 001 s« rd 0 ., a?:>t lp =Y%7 Sri IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Civil Action - Law Plaintiff V. No. 07-6932 Robert L. Myers, Defendant In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Compliant in Divorce under Section 3301(c) or 3301 9(d) of Divorce Code was filed on November 16, 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 the 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: t - / U ,C2,1t?727 NNa y L. Mye C,'} '- ? (= r? C`, {^?. ? ??, --., --... r"? "?' 1 ,. ? - (J !`i f. ? e l-J ?'? ? ; ' "-?- C IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Plaintiff V. Robert L. Myers, Defendant Civil Action - Law No. 07-6932 In Divorce a.v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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 the Waiver 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: ???- f Q U N cy L. Mys _.2 77: 1-0 =4 IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Plaintiff V. Robert L. Myers, Defendant Civil Action - Law No. 07-6932 In Divorce a.v.m. AFFIDAVIT OF CONSENT 4. A Compliant in Divorce under Section 3301(c) or 3301 9(d) of Divorce Code was filed on November 16, 2007. 5. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 6. 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 the 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: Robert L. My s - Zr, .?. IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Plaintiff V. Robert L. Myers, Defendant Civil Action - Law No. 07-6932 In Divorce a.v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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 the Waiver 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: C7 Fp c Robert L. Myer ?? ?, +a .? ? , -1 i.,r 1 ? C1?y?,n +? 1: ?y=_ i ? ` ? ? ::? IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Plaintiff V. Robert L. Myers, Defendant To the Prothonotary: Civil Action - Law No. 07-6932 In Divorce a.v.m. PRAECIPE FOR WITHDRAWAL You are hereby directed to mark as withdrawal the following counts and claims for relief: 1. Count II-Request for a Fault Divorce under section 3301(a)(2) of the Divorce Code; 2. Count III-Equitable Distribution under section 3502 of the Divorce Code; 3. Count IV-Request for Spousal Support; Alimony Pendente Lite and Alimony under Sections 3701(a) and 3702 of the Divorce Code; as the above referenced matters have been settled pursuant to a private agreement between the parties. Respectfully Submitted: B G Date: U 0 Y M. Teri Hall Stiltner, Esquire Attorney I.D. No. 86337 The Professional Arts Building 25 Penncraft Avenue, Suite 310 Chambersburg, Pennsylvania 17201 (717) 262-9091 Fax: (717) 262-9095 Attorney for Plaintiff ° 0 ?xa . " co IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Civil Action - Law Plaintiff V. No. 07-6932 Robert L. Myers, Defendant In Divorce a.v.m. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the 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: Defendant accepted service of the Complaint on November 21, 2007. An Affidavit of Service was filed by Plaintiff s counsel on November 29, 2007. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on April 10, 2008 by Defendant on August 4, 2008. (b) (1) Date of execution of the affidavit required by § 3301 (d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiff s affidavit upon Respondent: ; 4. Related claims pending: Settled by private agreement 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: April 11, 2008. Date Defendant's Waiver of Notice was filed with the Prothonotary: August 12, 2008. Respectfully Submitte : M. Teri Hall Stiltner, Esquire Attorney for Plaintiff r t?`° ..o r-?., ? ?? sxp?; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Namv L. MM I Plaintiff VERSUS Robert L. Myers, DefErrhzt. N o. 07- 6932 DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT Nggj L NM , PLAINTIFF, AND Pdmft T Tye' 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; /uQ u BY TH ATT O U RT: PROTHONOTARY 61 .? - IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY Nancy L. Myers, Plaintiff V. Robert L. Myers, Defendant Civil Action - Law No. 07-6932 In Divorce a.v.m. NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that Plaintiff in the above matter, after the entry of a Final Decree in Divorce dated September 16, 2008 hereby elects to resume the prior surname of Beam, and gives this written notice avowing her intention pursuant to 54 P.S. § 704. Date: !2 - C, 6 Nanc L. Myers Nanc L. 13eam COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN On this, the a-Lf day of , 2008, before me, bare' fi Z2delr , the undersigned officer, personally appeared Nancy L. Myers now, Nancy L. Beam, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within consent to adoption and acknowledged that he executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seal. ao"'?/o '?14'- Notary Public My commission expires: (- 9`0 I maintain my office in /im COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL CLARE R. ELDER, Notary Public Boro of Chambersburg, Franklin County My Commission Expires Jan. 9, 2009 -704Z ; :71 Q? V f i 77- Ste,