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Home My WebLink About01-6284MARTHA A. ULRICH, Plaintiff VS. LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. ~ CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTR 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 mardage counselors is available in the office of the Prothonotary, Cumberland County, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAW~'ER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 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 BATURIN & BATURIN Dated: October 31, 2001 By: HARRY M. BJ~TORIN, ESQUIRE Attorney I.D. No. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 MARTHA A. ULRICH, ) Plaintiff : ) VS. : ) LOUIS A. ULRICH, : Defendant ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. ,~1 - /_...~>~, CIVIL TERM f CIVIL ACTION -- LAW IN DIVORCE COMPLAINT UNDER SECTION 330'1(C) OF THE DIVORCE CODF AND NOW, this $1st day of October, 2001, comes the Plaintiff, MARTHA A. ULRICH, by and through her attorneys, the Law Offices of B^TURIN & BATURIN, and respectfully represents the following: 1. The Plaintiff is MARTHA A. ULRICH, an adult individual, sui juris, with a Social Security Number of 183-60-6311, and who currently resides at 35 North Market Street, Duncannon, Perry County, Pennsylvania 17020. 2. The Defendant is LOUIS A. ULRICH, an adult individual, sui juris, with a Social Security Number of 178-56-6432, and who currently resides at 207 S. Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 13, 1989, in Winchester, Virginia. 5. There has been no pdor action for divome or annulment of the marriage between the parties hereto in this or any other jurisdiction. 6. Plaintiff avers that there is one (1) child born to the parties under eighteen (18) years of age. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member of the Armed Fomes of the United States of America. 9. The Plaintiff avers that the grounds upon which this action is based is that the marriage is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce dissolving the mardage between the Plaintiff and Defendant and for such further relief as the Court may determine equitable and just. Respectfully submitted, BATURIN & BATURIN Dated: October 31,2001 By: HARRY M. I~ATURIN, ESQUIRE Attorney I.D. No. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 Attorney for Plaintiff I VERIFY THAT THE STATEMENTS MADE IN THIS DIVORCE COMPLAINT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE FALSIFICATION TO AUTHORITIES. DA'r~u: October 30, 2001 0 z ~ ~' ~, '31 0 ~o MARTHA A. ULRICH, ) Plaintiff : ) VS. : ) LOUIS A. ULRICH, : Defendant ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE CERTIFICATE OF SERVICE I, Harry M. Baturin, Esquire, of the law firm of Baturin & Baturin, attorney for the Plaintiff in the above captioned matter, do hereby certify that on November 7, 2001, I deposited in the United States Mail, at the United States Post Office, an article &Certified Mail, Return Receipt Requested, marked "Restricted Delivery", a certified copy of the Complaint in Divorce and Notice to Defend and Claim Rights attached thereto, bearing Article No. 7000 0520 0023 0124 9483 to: Louis A. Ulrich, 207 S. Sporting Hill Road, Mechanicsburg, PA 17050. The said article of Certified Mail, as shown by the Postal Return Receipt Card was received by the Defendant herein on November 9, 2001, and according to same, was signed by him, to wit: Louis A. Ulrich, which card is attached hereto and marked as Exhibit "A", along with the deposit slip dated November 7, 2001, for said article of Certified Mail aforementioned. BATURIN & BATURIN Harry M. Baturin, Esquire Attorney I.D. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 (Attorney for Plaintiff) Dated: November 13, 2001 To~ ~,,~.,,~ & Fe~ $ 7.37 Louis A. Ulrich ~---~;-~r~-~-~-~ .................................................. ~7 ~. S~ing Hill ~. ~ics~q~ PA 17050 · C~ Items 1, 2, and 3. ~es complstm item 4 if Restricted Delivery is desired. · Print your nama and address on the reversa so that we can · Attach this card to or on the front if ~ A. Rece#~lb~l~t~seRn~tC'fear/y) S. Date of De~iver~ Agent 1. Article Addressed to: 7~i1-1 Yes [] No Louis A. ULrich 207 S. Sporting Hill Mechanicsburg, PA 17050 [] Insured Mall C.O,D. 4. Restdcted D~lve~y? (~xlra Fee) 2. Article Number (Copy from service ~abel) 7000 0520 0023 0124 9483 PS Fo~n 3811, July 1999 Demotic Fletum P,~ce~pt EXHIBIT "A" m MARTHA A. ULRICH, Plaintiff VS. LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM 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 the divorce is indignities or irretrievable t~reakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary, Cumberland County, 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. 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 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 BATURIN & BATURIN Dated: May 14, 2003 By: Attorney I.D. No. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 MARTHA A. ULRICH, Plaintiff VS. LOUIS A. ULRICH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-6284 Civil Term : : CIVIL ACTION-LAW : IN DIVORCE AMENDED COMPLAINT COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Martha A. Ulrich, by and through her attorneys, the law firm of BATURIN & BATURIN, and files the within Amended Complaint for the purpose of changing the divorce firom a 3301(C) to a 3301(D): 1. The Plaintiff, Martha A. Ulrich, avers that the parties to this action separated on April 23, 2001, and have continued to live separate and apart for a period of at least two (2) years. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree In Divorce dissolving the marriage between the Plaintiff and Defendant under Section 3301(D) of the Pennsylvania Divorce Code. Date: May 14, 2003 Respectfully submitted, BATURIN & BATURIN By: Attorney I.D. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-.2427 Attorney For Plaintiff MARTHA A. ULRICH, Plaintiff VS. LOUIS A. ULRICH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-6284 Civil Term : : CIVIL ACTION-LAW : IN DIVORCE VERIFICATION I verify that the statements made in this Amended Complaint are true 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. Date: May 13, 2003 IqARTHA A. ULRICH (SEAL) MARTHA A. ULRICH, Plaintiff VS, LOUIS A. ULRICH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-6284 Civil Term : : CIVIL ACTION-LAW : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. Plaintiff's Affidavit Under Section 3301(d) Of The Divorce Code 1. The parties to this action separated on April 23, 2001, and have continued to live separately and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if l do not claim them before a Divorce is granted. I verify that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. (Seal) MARTHA A. ULRICH, Plaintiff VS. LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE CERTIFICATE OF SERVICE I, Harry M. Baturin, Esquire, of the law firm ofBaturin & Baturin, attorney for the Plaintiff in the above captioned matter, do hereby certify that on May 21, 2003, I deposited in the United States Mail, at the United States Post Office, Harrisburg, Pennsylvania, an article of Certified Mail, Return Receipt Requested, marked "Restricted Delivery", a certified copy of the Amended Complaint in Divorce and Notice to Defend and Claim Rights along with Notice To Defendant/Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code attached thereto, bearing Article No. 7000 0520 0023 0126 3526, addressed to: Louis A. Ulrich, 207 S. Sporting Hill Road, Mechanicsburg, PA 17050. The said article of Certified Mail, as shown by the Postal Return Receipt Card, was received by the Defendant herein on May 23, 2003, and according to same, was signed by him, to wit: Louis Ulrich, which card is attached hereto and marked as Exhibit "A", along with the deposit slip dated May 21, 2003, for said article of Certified Mail aforementioned. BATURIN & BATURIN By: H~, Esquire~ Attorney I.D. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 (Attomey for Plaintiff) Dated: May 27, 2003 I~ECHAHICSP.,LIR6 PA 17050 P~ge T $ $0,60- 60 H~ ~nd~me~ R~ulm~ ~. ~ R~ ~,~ ~ .50 ~nd~m~ R~uim~ Reclplent's Name PI~ Print Cl~y) ~o ~ aomp~ by mailer) ~;;~:-~:;~;-~ ~-~ .......................................................... .~.~L.~.,...~_~i~a.~... ~ ............................... tlIlI~4B.M-15401 EXHIBIT "A" MARTHA A. ULRICH, Plaintiff VS, LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Louis A. Ulrich 207 S. Sporting Hill Road Mechanicsburg, PA 17050 yOU HAVE BEEN SUED IN AN ACTION FOR DIVORCE. You have failed to answer the Complaint or file a Counteraffidavit to the Plaintiffs Affidavit. Therefore, on or after July 3, 2003, the Plaintiffcan request the Court to enter a Final Decree In Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the Court can enter a Final Decree In Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. A Counteraffidavit which you may file with the Prothonotary of the Court is attached to this Notice. 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 Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Dated: June 12, 2003 BATURIN & BATURIN Har~n/J/ry M. Baturiff~n,'Esqai~re ' 717 N. Second Street Harrisburg, PA 17102 (717) 234-2427 (Attorney for Plaintiff) MARTHA A. ULRICH, Plaintiff va. LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 0'1-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE DEFENDANT'S COUNTERAFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either Ia) or (b): Ia) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check Ii), (ii), or both: Ii) 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 Ia) or (b): Ia) 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) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I VERIFY THAT THE STATEMENTS MADE IN THIS COl INTERAFFIDAVIT ARE TRIJE AND CORRECT. l IJNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA C.S. SECTION 4904 RELATING TO I JNSWORN FAI,SIFICATION TO AUTHORITIES. DATE: LOUIS A. ULRICH, Defendant NOTICE: 1F YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTERAFFIDAVIT. MARTHA A. ULRICH, ) Plaintiff : ) VS, : ) LOUIS A. ULRICH, : Defendant ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Louis A. Ulrich 207 S. Sporting Hill Road Mechanicsburg, PA 17050 YOU HAVE BEEN SUED IN AN ACTION FOR DIVORCE. You have failed to answer the Complaint or file a Counteraffidavit to the Plaintiffs, Affidavit. Therefore, on or after July 8, 2003, the Plaintiff can request the Court to enter a Final Decree In Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the Court can enter a Final Decree In Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. A Counteraffidavit which you may file with the Prothonotary of the Court is attached to this Notice. 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 Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Dated: June 18, 2003 BATURIN & BATURIN Harry M. Bliturin, Esquire 717 N. Second Street Harrisburg, PA 17102 (717) 234.-2427 (Attorney for Plaintiff) MARTHA A. ULRICH, Plaintiff vs. LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE DEFENDANT'S COUNTERAFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): __ (a) I do not oppose the entry ofa divome 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 (h): __ (a) I do not wish to make any claims for economic relief. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I VERIFY THAT THE STATEMENTS MADE IN THIS COUNTERAFFIDAVIT ARE TRUE AND CORRECT. l UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: LOUIS A. ULRICH, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COLrNTERAFFIDAVIT. MARTHA A. ULRICH, ) Plaintiff : ) VS. : ) LOUIS A. ULRICH, : Defendant ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE CERTIFICATE OF SERVICE I, Harry M. Baturin, Esquire, of the law firm of Baturin & Baturin, attorney for the Plaintiff in the above captioned matter, do hereby certify that on June 1 ~, 2003. I deposited in the United States Mail, Harrisburg, Pennsylvania, by regular surface mail, an article of mail, a clocked-in copy of the Notice of Intention To Request Entry of Divorce Decree along with Defendant's Counteraffidavit Under Section 3301(d) of the Diw)rce Code attached thereto, addressed to: Louis A. Ulrich, 207 S. Sporting Hill Road, Mechanicsburg, PA 17050. Dated: June 1~, 2003 BATUR1N & BATURIN By: Han'y M. Baturin, Esquire Attorney I.D. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 (Attorney for Plaintiff) MARTHA A. ULRICH, ) Plaintiff : ) VS. : ) LOUIS A. ULRICH, : Defendant ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION m LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 5, 2001. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed fi.om the date of fi].ing and service of the Complaint. I consent to the entry of a Final Decree in Divorce after service of notice of intc'ntion 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: ,"~-/-O ~ (SEAL) MARTHA A. ULRICH, Plaintiff vs. LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM 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 1. I consent to the entry of a Final Decree of Divorce without notice. I understand that I may lose rights concerning aliLmony, division of property, lawyer's fees and expenses ifI do not claim them before a divome is granted. 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 1N THIS AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE TO THE PENALTIES OF 18 PA.C.S. §4904 TO UNSWORN FALSIFICATION TO AUTHORITIES. LOUIS A. ULRICH DATE: 7--/-~_~ (SEAL) MARTHA A. ULRICH, Plaintiff VS. LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 01-6284 CIVILTERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divome decree: 1. Ground for divorce: 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). Complaint In Divorce was served by Certified 2. Date and manner of service of the complaint: Mail, Return Receipt Requested - Restricted Delivery on November 9, 2001. Amended Complaint In Divorce was served by Certified Mail Re~tmn Receipt Requested - Restricted Delivery on May 23, 2003. 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 ; by defendant (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: May 13, 2003 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Date of filinq was May 21,2003 and date of service was May 23, 2003 4. Related claims pending: No,,olaims pending 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 aRached: Date of service - June 18, 2003, by regular surface mail, postage prepaid (b) Date of plaintiff's Waiver of Notice in {}3301 (c) Divorce was filed with the Prothonotary: Date: July 8, 2003 Date defendant's Waiver of Notice in {}3301 (c) Divorce was filed with the Prothonotary: BATURIN & BATURIN Harry M. BaturinA~o~~ MARTHA A. ULRICH, ) Plaintiff : ) VS. : ) LOUIS A. ULRICH, : Defendant ) TO: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE D:ECREE; Louis A. Ulrich 207 S. Sporting Hill Road Mechanicsburg, PA 17050 YOU HAVE BEFN SUED IN AN ACTION FOR DIVORCE. You have failed to answer the Complaint or file a Counteraffidavit to the Plaintiffs Affidavit. Therefore, on or after July 8, 2003, the Plaintiff can request the Court to enter a Final Decree In Divorce. If you do not file with the Prothonotary of the Court an ans~ver with your si~maature notarized or verified or a counter-affidavit by the above date, the Court can enter a Final Decree In Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. A Counteraffidavit which you may file with the Prothonotary of the Court is attached to this Notice. 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 Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Dated: June 18, 2003 BATURIN & BATURIN Harry M. Baturin, Esquire 717 N. Second Street Harrisburg, PA 17102 (717) 234-2427 (Attorney for Plaintiff) MARTHA A. ULRICH, Plaintiff V$, LOUIS A. ULRICH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-6284 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE DEFEND2MNT'S COUNTERAFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): __ (a) I do not oppose the entry of a divorce decree. __ (b) I oppose the entry ora ddvorce decree because (Check (i), (ii), or both: (i) The parties to ttfis action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Chgck either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. __ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I VERrFY THAT THE STATEMENTS MADE IN THIS COUNTERAFFIDAVIT ARE TRIFF AND CORRECT. I UNDERSTAND THAT FAI,SE STATEMENTS HEREIN ARF MADE SUBJECT TO THF PENALTIES OF 18 PA C.S. SECTION 4904 RELATING TO l J'NSWORN FAI.SITICATION TO AUTHORITIES. DATE: LOUIS A. ULRICH, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTERAFFDAVIT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of PEN NA. MARTHA A. ULRICh, Plaintiff N O. 01-6284 LOUIS A, ULRICh, Defendant AND NOW, DECREED THAT DECREE IN DIVORCE LOUIS A. ULRIC~ 2003 Civil Term IT IS ORDERED AND , PLAINTIFF, BY THe COURT'* · PROTHONOTARY ? · 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; ARE DIVORCED FROM THE BONDS OF MATRIMONY. AND , DEFENDANT,