The URL can be used to link to this page

Home My WebLink About08-0426n Steven A. Trayer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Martha S. Trayer, : NO. 08 - y,-2 CIVIL TERM Defendant : IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselor is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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. 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. h Steven A. Trayer, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 08 - V a 4, CIVIL TERM : INDIVORCE V. Martha S. Trayer, Defendant COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Steven A. Trayer, an adult individual, who resides at 141 Trayer Ln., Carlisle, PA 17013. 2. Defendant is Martha S. Trayer, an adult individual, who resides at 53 East Penn St., Carlisle, PA 17013. 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 August 30, 2003 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. M WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. -[ (??' Respectfully submitted, Date: BAYLEY & MANGAN UA?? Mark F. Bayley, EsqilW 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff Steven A. Trayer, Plaintiff V. Martha S. Trayer, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Oll- CIVIL. TERM IN DIVORCE VERIFICATION I verify that the statements made in this 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 unsworn falsification to authorities. Date: //V6 Steven A. Trayer, Plain ?i `I co -rri NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 97380 10 WEST HIGH STREET CARLISLE FA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT STEVEN A. TRAYER, Plaintiff V. MARTHA S. TRAYER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008 - 426 CIVIL TERM IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Please enter the appearance of NATHAN C. WOLF, ESQUIRE, as attorney for the Defendant, MARTHA S. TRAYER in this matter. Z--'1 FEBRUARY -1.5, 2008 THANR.-WOLF, ESQUIRE WOLF VWOLF 10 We,?f/High Street Carlisle, PA 17013 717-241-4436 SUPREME COURT ID NO. 87380 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT STEVEN A. TRAYER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARTHA S. TRAYER, : NO. 2008 - 426 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, attorney for defendant, do hereby certify that I have served a copy of the foregoing Praecipe for Entry of Appearance upon the following individual by postage prepaid mail, addressed as follows: FEBRUARY, 2008 Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 HAN C. LF, ESQUIRE WOLF & W LF 10 West High Street Carlisle, PA 17013 717-241-4436 SUPREME COURT ID NO. 87380 ? -s1 -r? ? ,,,,? ' X? *..i ? .y { ? d 3 ? ' , w? M1. t ? ? 'C? ??'?? ..r+ ?„.? ?-i ..?„ ? . Steven A. Trayer, Plaintiff V. Martha S. Trayer, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 08 - 426 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Martha S. Trayer, in the above-captioned action and I certify that I am authorized to do so. ate BY: A" ? 1 ?J"fi.4 Martha . Trayer, Defend 4t C.) 2-? Z rte- -a cn? Qc --z ? p y° CZ) _ o-n =C) w C) --irn CD i[7 STEVEN A. TRAYER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARTHA S. TRAYER, NO. 2008 - 426 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on or about January 18, 2008 and Defendant accepted service of the same on February 7, 2008, see acceptance of service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. f L?5o Date Steven A. TraYer c? c x:), rn? zM z? cn? C) ?,- -vrn o ? s--n (-q oM STEVEN A. TRAYER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA V. : CIVIL ACTION - LAW MARTHA S. TRAYER, : NO. 2008 - 426 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) OF THE DIVORCE CODE I . 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 FOREGOING 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. 4 3-l 1/ Date Steven A. Trayer c a c ? r Z <o -v ?c° ? MC) s 4-C saz n `' ° . NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT STEVEN A. TRAYER, Plaintiff V. MARTHA S. TRAYER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008 - 426 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about January 18, 2008 and served upon defendant on February 7, 2008, see acceptance of service. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. duuAy-, 2011 4- 4 -Ur t Martha S. Trayer m te x 'n rn- ar- r - -O r m cj ? q A? S 01-n Dz C4 CD CA STEVEN A. TRAYER, Plaintiff V. MARTHA S. TRAYER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - 426 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(Cl OF THE DIVORCE CODE 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. 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 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. QAab-?/-, 2011 MARTHA S. TRAYER C a MC ` zrn C- 4 AQ cl? w a 4 FILED-OFFICE BAYLEY & MANGAN OF THE PROTHONOTARY Mark F. Bayley, Esquire Attorney I.D. #: 87663 2011,JUL - I PM 3: 01 17 West South Street Carlisle, PA 17013 CUMBERLAND COUNTY (717) 241-2446 PENNSYLVANIA STEVEN A. TRAYER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW MARTHA S. TRAYER, NO. 2008-426 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Filed on January 18, 2008 and Defendant accepted service of the same on February 7, 2008 (a copy of Defendant's executed acceptance of service is attached). 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff on June 30, 2011 (original is attached); by the Defendant on June 28, 2011 (original is attached). 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing (original is attached). Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing (original is attached). Date: Mark F. Bayley, Es ire BAYLEY & MANGAN 17 W. South St. Carlisle, PA 17013 717) 241-2446 Supreme Court I.D. # 87663 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN A. TRAYER, V. MARTHA S. TRAYER NO. 2008 - 426 Civil Term DIVORCE DECREE AND NOW, -I- (?4 & , ?V , it is ordered and decreed that 1%r - STEVEN A. TRAY R, plaintiff, and MARTHA S. TRAYER , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") By the Court, Attest: l J. 7 / Prothonotary . ?. ?? ????- Cod ,mae I? ? 24a ifs' d ? ? x, 10,6 G? ? ?Py ma?.lL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Steven A. Trayer Plaintiff FILE NO. 2008-426 20 VS. IN DIVORCE ' ZM C: rn- Martha S. Trayer = CD Defendant *? -t? -r- C.) mac.`- C3 NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter , having been granted a Final Decree in Divorce on the 6th day of JU1y, 2011 , hereby elects to resume the prior surname of Martha S. Hay and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: cJ ?'L zot Signature Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS. On the f 1 day of 6)q. , 20 // , before me, a 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. In Witness Whereof, I have hereunto set my hand and official COMMONWEALTH OF PENNSYLVANIA Notarial Seal Nathan C. Wolf, Notary Public Carlisle Boro, Cumberland County My Commission Expires April 19, 2012 Member, Pennsylvania Assocletion of Notares Public 4- !I•oo pt ATTY WOLF cr 319.2 P-*a40 1&&a