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Home My WebLink About04-0803AMY C. BERKHEIMER PLAINTIFF Vs. STEVEN M. BERKHEIMER DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA No. - o a3 CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. lfyou 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 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: Office of the Prothonotary Cumberland County Court House One Courthouse Square Carlisle, Pennsylvania 17013-3387 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 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 17013-3387 717-249-3166 AMY C. BERKHEIMER PLAINTIFF Vs. STEVEN M. BERKHEIMER DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA : No. o&2 ._ : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE COUNT I AND NOW, comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows: Plaintiffis AMY C. BERKHEIMER, who currently resides at 1375 William Grove Road, Mechanicsburg, PA 17055. Defendant is STEVEN M, BERKHEIMER, who currently resides at 1375 William Grove Road, Mechanicsburg, PA 17055. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on September 29, 2000. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 2 AMY C. BERKHEIMER PLAINTIFF Vs. STEVEN M. BERKHEIMER DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA : No. : : CIVIL ACTION - LAW : IN DIVORCE Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the right to request that the Court require the parties to participate in counseling, and after being so advised, Plaintiff does not desire counseling. WHEREFORE: Plaintiff requests the Court to Enter a Decree in Divorce. Respectfully submitted, DATE By ~xJAMES M. BACH A¥orney ~It Law Attorney I.D.# 18727 352 S. Sporting Hill Rd. Mechanicsburg, PA 17050 (717) 737-2033 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein made are subject to penalties of 18 PA. C.S. §4904, relating to unswom falsification to authorities. DATE: ~ - ~ ~ - o t~ ~JAMY C. BERKHEIMER (PLAINTIFF) AMY C. BERKHEZMER Plaintiff VS. STEVEN M, BERKHETMER Defendant ~'N THE COURT OF COMMON PLEAS OF CUMBERLANID COUNTY, PENNSYLVANI'A NO. 04-803 CTVt'L TERM CIVIL ACTION - LAW IN DIVORCE CERTTFICATE OF PERSONAL SERVICF I, .1AMES M. BACH, being duly sworn according to Law, say that ! personally served: SI'EVEN M. BERKHETMER AT 352 S. SPORTt'NG HILL ROAD MECHANt'CSBURG, PA 17050 by handing to him a copy of the following document: NOTICE TO DEFEND AND CLAIM R~GHTS AND COMPLAINT IN DIVORCF on the 24th day of February, 2004, at 3:10 p.m. DATE: February 24, 2004 SIGNATURE: ES M. BACH Amy C. Berkheimer Plaintiff VS. Steven M. Berkheimer Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 04-803 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE (1) A Complaint in Divorce under §3301(c) of the,, Divorce Code was filed on 2-24-04 (2) (3) (4) (5) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce, without formal notice of the intention to request entry of divorce decree. I understand that I may lose fights conceming alimony, division of property, lawyer's fees or expenses, ifI 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 inunediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are tree 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. May 24, 2004 DATE ~Mnx~. Bcrkheimer PLAINTITF Amy C. Berkheimer Plaintiff VS. Steven M. Berkheimer Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. .. : NO. 04-803 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE (t) A Complaint in Divorce under §3301(c) of the Divorce Code was filed on 2-24-04 (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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, without formal notice of the intention to request entry of divorce decree. (4) 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 divome 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. I verify that the statements made in this affidavit are true mid 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. Hay 24, 2004 DATE Steven M. Berkheimer DEFENDANT AMY C. BERKItEIMER Plaintiff VS. STEVEN M. BERKItEIMER Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 04-803 _. : : CIVIL ACTION - LAW · ' 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: GROUNDS FOR DiVORCE: Irretrievable breakdown under Section (X) 3301(c) or ( ) 3301(d)(1) of the Divorce Code. (Check applicable section.) 2. DATE AND MANNER of service of the Complaint: By personal service on the 24th day of February 2004. 3. COMPLETE EITHER PARAGRAPH (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff May 24~ 2004; by Defendant May 24~ 2004. 1. Date of execution of the Plaintiff's Affidavit required hy Section 3301(d) of the Divorce Code 2. Date of service of the Plaintiff's Affidavit upon the Defendant: 4. RELATED CLAIMS PENDING: NONE 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, a copy of which is attached, if the Decree is to be entered under Section 3301(d)(1)(I) of the Divorce Code: DATE: May 24, 2004 J M. BACH, ESQUIRE Attorney I.D.# 18727 Attorney for Plaintiff 352 S. Sporting Hill Rd. MECHANICSBURG, PA 17050 (717)737-2033 IN THE COURT OF COIVlMON OF CUMBERLAND COUNTY STATE OF ~ PENNA. PLEAS BERKHEIHER ......................... ........................... ~lain~$~C ....... Versus .S?EVENMo..BERKHEI~ER ........................ ...... De~endan~ .... No.o4-8o3 ........................ DECREE IN DIVORCE AND NOW ................. ..~?~/....Z..'~., 2D134., it is ordered and decreed that . .~.~. c,. ]~,RKHEZ~m~ ............................ plaintiff, and . S~.EVEN .M.. aRRKm~It4Ea. ................................ defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the follawing claims which have been raised of record in this action for which a final order has not yet been entered; NONE By T/aXe Court/:/ / { ~ ~ Prothonotary