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HomeMy WebLinkAbout04-0810LISA M. EHMANN, Plaintiff V. JOSEPH T. EHMANN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO. ~q ~ oC>l {5 CIVIL TERM 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 breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. 1F 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 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 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. You must attend the scheduled conference or hearing. LISA M. EHMANN, Plaintiff V. JOSEPH T. EHMANN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : NO. CIVIL TERM The plaintiff, Lisa M. Ehmarm, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. §§3301(c) and 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Lisa M. Ehmann, who currently resides at 583 Gmhms Woods Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Joseph T. Ehmann, who currently resides at 83 MicNan Drive, Middletown, Dauphin County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 8, 1992 in Jersey City, New Jersey. 5. Plaintiff and Defendant have lived separate and apart since November 17, 2003. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiffhas been advised that counseling is available and that Plaintiffmay have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Date udock Certified Legal Intern mo~s ¥. PL^CE LUCY IOHNSTONoWALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2368 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 unswom falsification to authorities. Date LISA M. EHMANN, Plaintiff V. JOSEPH T. EHMANN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. Oq-.Pl~ CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Lisa Ehmann, Plaintiff, to proceed in fotura pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Alys~. L~fHudock ~ Certified Legal Intern THOMAkff M//PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 LISA M. EHMANN, Plaintiff JOSEPH T. EHMANN, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 04-810 CIVIL TERM ACCEPTANCE OFSERVICE I, Jordan D. Cunningham, Cunningham & Chernicoff, P.C., attorneys for Defendant, Joseph T. Ehmann, hereby accept service of the Divorce Complaint in the above matter. Dated: .:~//¢ f~'~ Respectfully submitted, CUNNING ~E~ , By~~ I.ODrda~. Cunningham, Esquire · ~23144 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 P.e. CERTIFICATE OF SERVICE I do hereby state that on the 16th day of March 2004, I served a true and correct copy of the foregoing in the above captioned matter, by placing the same in the United States mail, first- class, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Alysia L. Hudock Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 'U~r{stine-A. Zarin~-LegaCs sistant / LISA M. EHMANN, Plaintiff : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH T. EHMANN, Defendant CIVIL ACTION - LAW 1N DIVORCE : NO. 04-810 CIVIL TERM CERTIFICATE OF SERVICE I, Amy L. Kneel, hereby certify that on this 13th day of September 2004, I am serving a true and correct copy of the Affidavits of Consent and Waivers of Notice upon Defendant's counsel, Jordan D. Cunningham, by depositing a copy of the same in the United States mail, postage prepaid, at the following address: Jordan D. Cunningham, Esquire CUNNINGHAM & CHERNICOFF, P.C. P.O. Box 60457 Harrisburg, PA 17106 Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 LISA M. EHMANN, Plaintiff JOSEPH T.EHMANN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION IN DIVORCE : NO. 04-810 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§3301(c) and 3301(d) of the Divorce Code was filed on February 25, 2004. 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 after service of notice and intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I tmderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to tmsworn falsification to authorities. Lisjt 1~i. Ehmann, Plaintiff LISA M. EHMANN, Plaintiff JOSEPH T. EHMANN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION : IN DIVORCE : : NO. 04-810 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c~ OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. 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. 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 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 unswom falsification to authorities. LISA M. EHMANN, JOSEPH T. EHMANN, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : 1N DIVORCE : : NO. 04-810 CIVIL TERM AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301(c) of the Divorce Code was filed on February 25, 2004. 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 Divome after service of Notice of Intention 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. LISA M. EHMANN, Plaintiff JOSEPH T. EHMANN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : NO. 04-810 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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 finalized. 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. §4904 relating to unswom falsification to authorities. LISA M. EHMANN, : Plaintiff : JOSEPH T. EHMANN, : Defendant : To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 2004-810 CIVIL TERM PRAECIPE TO TRANSMIT RECORD Please transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: Consensual no-fault divorce under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant's counsel, Jordan D. Cunningham, by U.S. mail, first class, postage prepaid, Service was complete upon receipt by Jordan D. Cunningham on March 16, 2004. 3. Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code by Plaintiff- August 17, 2004; by Defendant - September 7, 2004. 4. Related claims pending: None. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: September 13, 2004. Date Defendant's Waiver of Notice was filed with the Prothonotary: September 13, 2004. Date q/a lo Cenified Legal Intern ANN~ MACDONALD-FOX LUCY JOHNSTON-WALSH ROBERT E. RA1NS THOMAS M. PLACE Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~.~~ PENNA, _Lima M. ~hmann NO. ~_~ ~ VERSUS -J~eph T Mhmann Defendant PLEAS CivJ 1 AND NOW, DECREED THAT DECREE IN DIVORCE , PLAINTIFF, AND Jo~eoh T. ~hmann ,DEFENDANT, 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; None. PROTHONOTARY