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Home My WebLink About03-6665 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER D. PFAHL, .. .. Plaintiff .. CIVIL ACTION-LAW .. .. .. NO. 2003- /.,~i:5 vs. .. CIVIL TERM .. .. .. SARAH J. SWITZER, .. IN DIVORCE .. Defendant .. .. NonrF TO DFFFND AND rT.AIM 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, P A 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CHRISTOPHERD. PFAHL, Plaintiff CIVIL ACTION-LAW vs. NO. 2003- CIVIL TERM SARAH J. SWITZER, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Christopher D. Pfahl, who currently resides at 1020 North Pitt Street, Carlis]e, Cumberland County, Pennsylvania. 2. Defendant is Sarah J. Switzer, who currently resides at 89 De]ano Street, Pulaski, New York. 3. Plaintiff is a bona fide resident in the Commonwealth ofPennsy]vania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on June 24,2000, at Watertown, New York. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken, 7. P]aintiffhas been advised that counseling is available and that P]aintiffmay 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. Date: December 22, 2003 ~ ;~\ =---=-~ Steven J. Fishman, ID#16269 95 A]exander Spring Road, Suite 3 Carlisle, PA ]7013 (7] 7) 249-6333 3 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. Cons. Stat. Ann. ~4904, relating to unsworn falsification to authorities. ~~' Christopher D. Pfahl 2 ;>- ~ LU() 0'<: IIO 1.J......:I: O'~' ; C) Oil" ~O: tcUJ iE u~ o ':'? c g ~ L:.C- ::r V ~ d:~ ~: 6~ ~." .......,:: C'? (...J Lw t.::) ~., C::) -= '" ::J U IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CHRISTOPHER D. PFAHL, Plaintiff CIVIL ACTION-LA W vs. NO. 2003-6665 CIVIL TERM SARAH J. SWITZER, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Ste'"en J. Fishman, Esquire, do hereby certifY that a copy of the Divorce Complaint in the above-captioned matter was mailed to the Defendant, Sarah J. Switzer, via first-class, certified, return receipt, restricted delivery mail service, at her last known address of 89 Delano Street, Pulaski, New York 13142-4202. Attached hereto is the post office return receipt signed by the Defendant, date of delivery March 11,2004. .~~) Steven J. Fis man, Esquire Salzmann, Hughes & Fishman, P.C. 95 Alexander Spring Road, Suite 3 Carlisle, P A 17013 (717) 249-6333 Attorney for Plaintiff Notarial Seal . Tricia L. Bailey, Notary Pubhc South Middleton Twp., .Cumberland CO~~6 L My Commission ExplrcS Sept. 24, "- rn IT" nJ ::r .-'l U"J nJ Postage $ j..; (;;:;:n-~:;' 1I(HI Certified Fee rn c c c RetumRecaiptFee (Endorsement Required) Postmark H,", Restricted Delivery Fee (Endorsement ReqUired) ~".'." (') ".,) ~::.'" c-:;~ "'- CI -1'"1 :~J ['<1 :1J ,-'- ~'i)nl -,)CJ 1'-' : _:~!Ci -:;2~~ ;,"')rn :-:=-1 ~~ w ,-0 .; ..r;- CHRISTOPHER D. PFAHL Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 03-6665 CIVIL TERM v. SARAH J. SWEITZER Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT, AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3103(C) OF THE DIVORCE CODE. 1. A Complaint in divorce under Section 3103 (c) ofthe Divorce Code was filed on December 31, 2003. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property I lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 7. 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. Date: A-vr ;r;.z.oet- "~:-' 1" : /) o r- c.~; ( .' CHRISTOPHER D. PFAHL Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 03-6665 CIVIL TERM v. SARAH J. SWEITZER Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3103(C) OF THE DIVORCE CODE. 1. A Complaint in divorce under Section 3103 (c) of the Divorce Code filed on December 31, 2003. 2. Defendant acknowledges receipt and accepts service of the Complaint on March 11, 2004. 3. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 4 I consent to the entry of a final decree in divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyers 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Date:-,~ /8;La:>lf ~ ~. SA H J. SWITZER ... . ~~; r:::::J 0--" ---I (.,:: , ' ~,~ . c c C \t1r!5\v~~ D. ~~Vt) IN THE COURT OF COMMON PLEAS VS. ~~ '3. ~ It-"2.et'"' CUMBERLAND COUNTY, PENNSYLVANIA ..2 oo3-'~ CIVIL DIVISION NO. CIVIL TERM 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 ~3301 (c) 330 1 (d) (1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Cc: riff' L" ~ Hc....d ?J/I/(ot( 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 k~.. 21. l..ook. ; by defendant .4",-, IS, '2...00'1 (b) (1) Date of execution of the affidavit required by ~3301 (d) rJ l it- of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: NoN 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 of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: ~q" I~ 2-DO L the Prothonotary: Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with 5c.;>t I ~ z.-eiX. _ ~ .---- ~ S~ Attorney for Plaintiff I D~fQr:ldar:lt i~j," :~J"'l ~~-, c-' C) "'''' '" ~'" '" '" '" "'''' '" '" '" '" "'''''''''' '" "'''''''~ "''''~~~'''~'''~~'''~~~~'''~ ~"'~~"''''~~'''~ ~ IN THE COURT OF COMMON PLEAS ~ ~ OFCUMBERLANDCOUNTY : ~ ~ STATE OF PENNA. ~ ~ ~ ~ ~ C -hr"'~~~ 1> -=2~h) 4" "1>~~~ I/- VERSUS No. ':<D~- '''~ CI t/, J DECREE IN DIVORCE AND ~yr~ .ht- CJ, ~JSf.ofh:r ~ .p~ t, / ~h J. ~l.Vli-~r , DEFENDANT, AND NOW, , ,edt'''', IT IS ORDERED AND DECREED THAT , PLAINTIFF, 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; I'-J 011 e J. ROTHONOTARY "~;!!;!!;!!ff. ff.ff.ff. ff.'" ff. '" ff. ff.'" ".,"'.,ff.ff. ff.ff.ff."'ff. ff. ff.ff. ff. ff.ff. ff. ~"""'''ff.''ff.ff.ff.''''''''ff.ff. .~ % ~ ~ ")?- Je-~ ~p~j'~4ip-FP 9d./-e'~ . . ~