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HomeMy WebLinkAbout04-0286WALTER T. REMMERT, : IN TI:[E COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW 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 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 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 fights 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 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 T,~KE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE ~ OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 71%249-3166 WALTER T. REMMERT, : 1N THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : TRICLA D. REMMERT : NO. 0 ~ - ~ ~ ~ Defendant : : IN DIVORCE COMPLAINT AND NOW COMES the above-named Plaintiff, by his attorney, William A. Duncan, Esquire, and makes the following Complaint in Divorce: t. Plaintiff, Walter T. Remmert, is an adult individual currently residing at 420 S. Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Tricia D. Remmert, is an adult individual currently residing at 32 Longstreet Drive, Carlisle, Cumberland County, Pennsylvania 17241. 3. Both Plaintiffand Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing ofttds Complaint. 4. The Plaintiffand Defendant were married on August 14, 1998 in Columbus, Georgia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers, in accordance with Section 3301(c) of the Divome Code, the marriage between the parties is irretrievably broken. 7. Plalntiffhas 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. Defendant herein is not a member oftbe armed forces of the United States of America. WHEREFORE, Plaintiffprays this Honorable Court enter a decree dissolving the marriage between the parties. Respectfully Submitted, Attorney for Plaintiff Duncan, Hartman & Douglas, P.C. 1 Irvine Row Carlisle, PA 17013 (717)249-7780 I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904, relating to unswom falsification to authorities. - ......... ~-- ~ Walter T. Remme~t t)ate: &~ z~;~ zcc7/ WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW TRICIA D. REMMERT : NO. Defendant : : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant 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 3301(e) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relation 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 the list. All necessary arrangements and the cost offcounseling sessions are to be bom by you and your spouse. If you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; TRICIA D. REMMERT : NO. Defendant : : IN DIVORCE AFFIDAVIT Waiter T. Remmert, Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I 0~O/DO NOT) request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 4. I realize that if the divorce is brought under section 3301(c) of the Divorce Code, then counseling must be completed within ninety days al~er the filing of the complaint. If the divorce is brought under section 33.01 (d) of the Divorce Code, then counseling must be completed within one hundred and twenty days after the filing of the complaint. I understand that raise statements herein are made subject to the penalties off 18 . Pa.C.S.4904 relating to unsworn falsification to authorities.,./ ,J 6,,~( ) j~ ") Walter t~. Remmert WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : TRICIA D. REMMERT, : NO. 2004-286 CIVIL TERM Defendant : IN DIVORCE COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF CUMBERLAND : ACCEPTANCE OF SERVICE I, MARCUS A. McKNIGHT, III, ESQUIRE, attorney for the defendant, Tricia D. Remmert, hereby agree to accept service of the Complaint in Divorce, Docket Number 2004-286 Civil Term, which was filed on January 22, 2004. // / Att6mey fi>r Defendant Date: February 17, 2004 Subscribed and sworn to before me this 17th day of February, 2004. 1~~b~'~ mt~l | ~ c / ~c~.~ ~ / ~,~~ I WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW .. TRICIA D. REMMERT, : NO. 2004-286 CIVIL TERM Defendant : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the defendant, TRICIA D. REMMERT, in the above captioned case. Respectfully submitted, IRWIN & ~NI~GH~_~.~. By: ,~/~~' Marcus ~. Mc .K~,igh~, Esq. 60 Westfomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for defendant Date: February 17, 2004 WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW .. TRICIA D. REMMERT, : NO. 2004-286 C1VIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Marcus A. McKnight, 1~, Esquire, hereby certify that a copy of attached Praecipe for Entry of Appearance was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: William A. Duncan, Esquire Duncan, Hartman & Douglas, P.C. One Irvine Row Carlisle, PA 17013 IRWIN & McKNIGHT By: M~rcus A. ~IcKnight,'~, Esq. ~ 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25;476 Date: February 17, 2004 WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : : 2004-286 CIVIL TERM TRICIA D. REMMERT, : Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 22, 2004. 2. The marriage of plaintiff and defendant is irrethevably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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 unswom falsification to authorities. WALTER T. REMMERT WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : : 2004-286 CIVIL TERM TRICIA D. REMMERT, : Defendant : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 22, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry ora final decree in divorce. 4. 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. 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 unswom falsification to authorities. TR/CIA D. REMMERT WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW .. : 2004-2116 CIVIL TERM TRICIA D. REMMERT, : Defendant : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothunotary% Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. / ...... ~', "'~ TR1CI~ D. REMMERT WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA ., v. : CIVIL ACTION - LAW : : 2004-286 CWIL TERM TRICIA D. REMMERT, : Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3, Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. 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. WALTER T. REMMERT WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW ; : 2004-286 CIVIL TERM TRICIA D. REMMERT, : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST 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! 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. ! 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 unswom falsification to authorities. Plaintiff WALTER To REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION ~ LAW : 2004-286 CIVIL TERM TRICIA D. REMMERT, : Defendant : IN D/VORCE 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 fights concerning alimony, division of property, lawyer's fees or expenses ifI 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. ! 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.,,,, S~tion.~. 4904 relating to unsworn falsification to authorities. Date: July 16, 2004 TR/CIA~I~Clq~E i~IME RT Defendant WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW ; TRICIA D. REMMERT : 2004-286 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. Ground for divorce: irretrievable breakdown under Seetion 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: by acceptance of service by Marcus A. McKnight, 1II, Esquire 3. (1) Date of execution of the affidavit of consent requ'tred by Section 3301 (c)of the Dirvore Code by plaintiff July 16, 2004; by defendant July 16, 2004. 4. Related claims pending; none 5. Date Plaintiffs Waiver of NOtice in 3301 (c) Divorce was filed with the Prothonotary: July 27, 2004. 6. Date Defendants Waiver of Notice in 3301 (c) Divorce was filed with Prothonotary: July 27, 2004 William A. Duncan, Esquire WALTER T. REMMERT, : IN THE COURT OF COMMON PLEAS OF Plaintiff ~ CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : TRICIA D. REMMBRT, : NO. 2004-286 CIVIL TERM Defendant : IN DIVORCE COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF CUMBERLAND : ACCEPTANCE OF SERVICE I, MARCUS A. McKNIGHT, III, ESQUIRE, attorney for the defendant, Tricia D. Remmert, hereby agree to accept service of the Complaint in Divorce, Docket Number 2004-286 Civil Term, which was filed on January 22, 2004. Date: February 17, 2004 Subscribed and sworn to before me this 17th day of February, 2004. ~'. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ST^TE or ~ PENNA. ...~ ~.. ~? ............ DECREE IN * DIVORCE ~ ^~ ~ow, ........ ~ ~ .... .,~'t ~ //'.ca.,~.,a . ~ ......... - ..... , it is ordered and /i decreed that ~aua-~ T. ~? ...................... . plaintiff, and ~CZA p.. ~e~ .......................... , defendant, are divorced from the bonds of matrimony. .. The court retains jurisdiction of the following claims which have ~ been raised ao! record in this action for which a final order has not yet been entered, (~