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HomeMy WebLinkAbout08-3783J:\F[LFS\Clicnu\13073 Beck\13073.1.complaint Crested: 9/20/04 0:06PM Revised: 6/26/08 9:49AM Katie J. Maxwell, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 206018 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff CRAIG S. BECK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08- 37r3 CIVIL ACTION - LAW NATALIE ANN BECK, 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 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CRAIG S. BECK, V. Plaintiff NATALIE ANN BECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08- 3??3 CIVIL ACTION - LAW IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Craig S. Beck, who currently resides at 219 Westview Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Natalie Ann Beck, who currently resides at 538 Bedford Court, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 6, 2005, in Beaver County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 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 of divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage between Plaintiff and Defendant. MARTSON LAW OFFICES By atie J. Max e TI, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: Jun Attorneys for Plaintiff e, 2008 YM FICATiON The foregoing Divorce Complaint is based upon inf nation which has been gathered by my counsel in the preparation of the lawsuit no language of the document is that of counsel and not my own. I have read the document and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if I make knowingly false averments, t may be subject to criminal penalties. Comy -.8 13ewk Craig S. Beck FuazMaMMMINn B"I3MI.VMWK CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Complaint in Divorce was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Linda Clotfelter, Esquire 5021 East Trindle Road Mechanicsburg, PA 17050 MARTSON LAW OFFICES sy v? ricia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: Ulu c? (t I a 00 Y n N "Fl tp\ ,j =4 v 'v Y to V y? I A Q s F:1FII..ES\C6eats113073 Beck\13073.1.AOS Created: 4120104 0:06PM Revived: 6/26/08 3:43PM Katie J. Maxwell, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 206018 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff CRAIG S. BECK, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NATALIE ANN BECK, Defendant : NO. 08-3783 : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, Linda A. Clotfelter, Esquire, accepted service of the Complaint in Divorce on behalf of Defendant, Natalie Ann Beck, on June Wl , 2008, and certify that I am authorized to do so in accordance with Pa. R.C.P. 402. Dated: (,e 140' O L3 Inda A. Clotfelter, Esquire Afty I•D. 74463 5021 E.. Tvn'?---A c. FU4 P-1 0 Wclh&kv ? t 5 b PA 1-105D Oo) -I9to-- t130 tZ'1-PLC a '' Cr' F:\F1LES\C1ients\13073 Beck\ 13073, Laomon Created: 9/20/04 0:06PM Revised: 12/18/08 10:51 AM Katie J. Maxwell, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 206018 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff CRAIG S. BECK, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NATALIE ANN BECK, Defendant NO. 08-3783 CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on June 26, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 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. ! l ! fa?? Date: ? Natalie Ann Beck, Defendant " 0 Katie J. Maxwell, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 206018 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff CRAIG S. BECK, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3783 CIVIL ACTION - LAW NATALIE ANN BECK, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301(d) 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. 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 waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: -l < o206> &W?- Zaiaie Ann Beck, Defendant A et f a NATALIF A.. BE( K, Plaintiff VS. CRAIG S. BECK, Defendant IN THE CO[ RT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3783 CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit C ? ca c rour r? GO © you must fi le a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will he admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE I . The parties to this action separated on June 10, 2008, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fee,, or expenses if I do not claim them before a divorce is granted. I verifv 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 filsifcation to authorities. 77 / Dal- NATALIE A. BECK, Plaintiff Y ~ CRAIG S. BECK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 08-3783 a ~ c ~ ~ NATALIE A. BECK, :CIVIL ACTION -LAW a ~~ ..~ ~-~ ~ Defendant : IN DIVORCE ~rr~ ~~ ~~ ro vn r ~ mac? NOTICE OF INTENTION TO REQUEST ENTRY OF ~ ~' -° `_ ; ~' DIVORCE DECREE ~-°~ ~ ~ w °+-~ ^ ~ ~ TO: Craig S. Beck, Plaintiff c/o Katie Maxwell, Esquire Defendant, Natalie A. Beck intends to file with the court the attached Praecipe to Transmit Record on or after November 19, 2010 requesting that a final decree in divorce be entered. LAW FIRM OF LINDA A. CLOTFELTER Date: ~ D ~u~ i mast i nnaie xoaa, rune i uu Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile CRAIG S. BECK, Plaintiff vs. NATALIE A. BECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3783 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: Divorce Code. The ground for divorce is irretrievable breakdown under Section 3301(d)(1) of the 2. The Complaint was filed on June 26, 2008. The Complaint was served by Acceptance of Service of counsel for Defendant, the undersigned, on June 30, 2008 with same having been filed of record August 1, 2008. 3. (a) The affidavit required by § 3301(d) of the Divorce Code was executed August 17, 2010. (b) The affidavit required by § 3301(d) was filed August 30, 2010 and it was served upon Defendant by first class mail postage prepaid directed to his counsel of record on September 2, 2010, as evidenced by the Certificate of Service filed November 1, 2010. 4. There are no related claims pending. 5. (a) The notice of intention to request entry of section 3301(d) divorce decree, a copy of which is attached, was served upon Defendant by first class mail postage prepaid direct to his counsel of record on October 28, 2010, as evidenced by the Certificate of Service filed November 1, 2010. (b) The Plaintiffs waiver of notice was signed by Plaintiff December 29, 2008 and was filed with the Prothonotary December 30, 2008. Date: p (~ Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Mechanicsburg, PA 17050 (?17) ?96-1930 (Telephone) (717) 796-1933 (Facsimile) { CRAIG S. BECK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 08-3783 NATALIE A. BECK, :CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 28th day of October, 2010, the undersigned hereby certifies that a true and correct copy of the foregoing NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (D) DIVORCE DECREE and copy of PRAECIPE TO TRANSMIT RECORD, was served upon the opposing party by first class mail, postage prepaid, addressed as follows: Katie J. Maxwell, Esquire 10 East High Street Carlisle, PA 17013 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER L da A. Clotfelter, Esquire orney ID No. 72963 021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile b NATALIE A. BECK, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA . r., ~ v -n ~ vs. : NO. 08-3783 _~ ~ z-n . ~,~ ~ ~~ CRAIG S. BECK, :CIVIL ACTION -LAW ~,~ , ~~? Defendant : IN DIVORCE --<p _ -'° O J ^O 'z't ~'n ~ ~~ ~' © W y ~ ~ ~;~ry y' - -i ~ ~ ~ ~ CERTIFICATE OF SERVICE AND NOW, this 2nd of September, 2010, the undersigned hereby certifies that a the Notice and Affidavit under section 3301(d) of the Divorce Code executed by Plaintiff, Natalie A. Beck, filed on August 30, 2010, and aCounter-affidavit Under Section 3301(d) of the Divorce Code were served upon the opposing party by United States first class mail, postage prepaid, addressed as follows: Katie J. Maxwell, Esquire 10 East High Street Carlisle, PA 17013 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER By: Li da A. Clotfelter, Esquire A orney ID No: 72963 21 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile CRAIG S. BECK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NATALIE A. BECK : NO. 08-3783 DIVORCE DECREE AND NOW, _30 , 4000 , it is ordered and decreed that CRAIG S. BECK plaintiff, and NATALIE A. BECK 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.") NONE. By the Court, I h Attest: J. rothonotary Oafj.r R4 ? L. e 1.4 VeL4v-x-