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Home My WebLink About08-4033 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr., Plaintiff VS. Erin French Kissinger Diehl Defendant :No. - 110.3 Civil Action - Law : 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 in divorce or annulment may be 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 the custody or visitation rights 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOUR 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, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr., Plaintiff VS. Erin French Kissinger Diehl Defendant COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Glenn A. Diehl, Jr. who currently resides at 614 Shippensburg Road, Shippensburg, Cumberland County, Pennsylvania-,' since June 24, 1996. : No. O.F U633 ?.! 7.L-. Civil Action - Law In Divorce 2. Defendant is Erin French Kissinger Diehl who currently resides at 471 East King Street, Shippensburg, Cumberland County, Pennsylvania, since March 23, 2008. 3. Defendant has been a bona fide resident 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 December 23, 2005 at Episcopal Church, Shippensburg, Cumberland County, Pennsylvania. 4k 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 that he be granted a divorce from the bonds of matrimony. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 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. Section 4904 relating to unsworn falsification to authorities. Date: -AA GI n A. Diehl, Jr. w a w W (i? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr., : No. 08 - 4033 Civil Term Plaintiff Civil Action - Law vs. In Divorce Erin French Kissinger Diehl Defendant AFFIDAVIT OF SERVICE N S2 CD 3 3 a w 00 ter N pO A S 0 0 Ln L-j 03 ti O 0 O O Cn Q- w w Ln N 3 a H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Erin French Kissinger Diehl, of 471 E. King Street, Shippensburg, PA 17257 by certified mail on July 9, 2008 and was accepted on delivery by Erin F. Diehl, on July 11, 2008. -- ?5* 0 Anthony Adams, Esquire Cn -? k a A ; Attorney for Plaintiff CD _ 49 W. Orange Street, Suite 3 d - Z am am Shippensburg, PA 17257 E; 0 v' 7c. CL o N (717)-532-3270 Sworn to and subscribed this .tz9 day of , 2009. Notary Public My Commission Expires: -?q COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH WARREN, Notary Public Shippe,isburg Twp., Cumberland County My Commisalon Expires Nov. 8, 2009 D-OFRCE OF THE PROTHONOTARY 209 MAY -6 PM 1: 27 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr. : No. 08-4033 Civil Term Plaintiff : Civil Action - Law vs. Erin French Kissinger Diehl Defendant : In Divorce AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. Section 4904 relating to unsworn falsification to authorities. Date: J 5 O? ?.... Glen A. Diehl, Jr. FlUD-OFrIGS OF THE F s7HON!flTARY- 2009 MAY -b PH 1: 2 `I p., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr. Plaintiff : No. 08-4033 Civil Term VS. Erin French Kissinger Diehl Defendant : Civil Action - Law : In Divorce 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 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 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 falsification to authorities. Date: GI n A. Die I, Jr. OF THE fiRQ' NOTA Y 2009 MAY -6 PM 1: 27 CUM. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr. : No. 08-4033 Civil Term Plaintiff vs. : Civil Action - Law In Divorce Erin French Kissinger Diehl Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. Section 4904 relating to unsworn falsification to authorities. Date:-41%10q 'ah a 't ' 11 nn Kissinger D ehl Defendant RED-OFFICE OF THE PPOTH-!nN TARY 2N9 M AY -6 PM 1:27 PENNSYLVANA, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr. : No. 08-4033 Civil Term Plaintiff : Civil Action - Law vs. : In Divorce Erin French Kissinger Diehl Defendant 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 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 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 falsification to authorities. Date: 10q in French Kissinge DDefendant FILED-- F 1CE OF THE PPOT l TARP 2009 MAY -6 PM I: 27 CUtv". b ?-,f 4 p r: ED ON P, : A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Glenn A. Diehl, Jr. : No.08-4033 Civil Term Plaintiff . Civil Action - Law VS. : In Divorce Erin French Kissinger Diehl Defendant 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) of the Divorce Code. 2. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on July 9, 2008 and was accepted by Defendant on July 11, 2008. An Affidavit of Service is being filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff May 5, 2009; by Defendant April 28, 2009. 4. Related claims pending: None. 5. Plaintiffs Waiver of Notice was signed on May 5, 2009 and is filed herewith and Defendant's Waiver of Notice was signed April 28, 2009 and is filed herewith. H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 FILED-CIFFIQE OF TFE € THONUI 'ARY 2009 MAY -6 Pik i *. 2 8 Glenn A. Diehl, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Erin French Kissinger Diehl NO. 08 - 4033 Civil Term DIVORCE DECREE AND NOW, it is ordered and decreed that Glenn A. Diehl, Jr. plaintiff, and Erin French Kissinger Diehl , 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 e By the- Court, Wv Attest: J. Prothonotary &A4"4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Glenn A. Diehl. Jr. Plaintiff Vs File No. _ 2_008 - 04033 - IN DIVORCE Erin French Kissinger Diehl _ .-----?------- ? Defendant NOTICE TO RESUME PRIOR SURNA. Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated 05/12/2009 hereby elects to resume the prior surname of Kissinger and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date:, L?a COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF Franklin ) On the 3 ?S+ day of 2009 before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary Public COMMONWEALTH_ OF PENNSYLVANIA Notarial Seal rest N. Myers, Notary Public ?!ppsnsburg LMySh Boro, Franklin C,,ounMMIssion Expir es Dec. 19, , 2069 f fell... ; .: ,i(DE OF THE F'-V?- ? ,! }TRAY 2009 AUG 21 AM 9-- 02 FIN' iYUPPA