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Home My WebLink About08-4789ZACHARIAH BEHRENS, Plaintiff V. HEATHER BEHRENS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - LO N CIVIL TERM 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 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, 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 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 YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, 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. ZACHARIAH BEHRENS, Plaintiff V. HEATHER BEHRENS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - q-7;-l CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Zachariah Behrens, an adult individual, who resides at 44 West Main Street, Plainfield, Cumberland County, Pennsylvania, 17081. 2. Defendant is Heather Behrens, an adult individual, who resides at 34 Westminster Court., Carlisle, Pennsylvania, 17013 3. Plaintiff and Defendant have both 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 May 15, 2004 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: Respectfully submitted, BAYLEY & MANGAN aBayley, E quire 17 West South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff ZACHARIAH BEHRENS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HEATHER BEHRENS, NO. 08 - CIVIL TERM Defendant IN DIVORCE 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 unworn falsification to authorities. Date: Q C D ? tV . Q ?.? N .ern ? Q c - cn 0 ZACHARIAH BEHRENS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HEATHER BEHRENS, NO. 08 - 4789 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint on behalf of the Plaintiff, Heather Behrens, in the above-captioned action and I certify that I am authorized to do so. x-14 - CS 8 _ _ Date Heather Behrens, amts ?'-? _ r-r ,-` ;? T ..,.t , ?{ ? T «? ', ,- > ? _ K? '/'i ti? .. ??? ?T# '"' ZACHARIAH BEHRENS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HEATHER BEHRENS, NO. 08 - 4789 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on August 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. 9 L ps Dat riah Behrens ornimmr 209 OCT -I F" 2'. 06 CXJMBEJ9 A Q WUNTY PENNNYAW ZACHARIAH BEHRENS, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW HEATHER BEHRENS, NO. 08 - 4789 CIVIL TERM Defendant IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) 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 THATT EH STATEMENTS MADE IN THE FOREGOING 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. C114 &S Date ?UW iah Behren OF 4%MrnRr 2009 OCT - I FM 2' Q 6 CUMB wli "40 CO)L M`( ZACHARIAH BEHRENS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HEATHER BEHRENS, NO. 08 - 4789 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on August 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. Dat Heather Behrens of n tAnr 2099 € CT i V 06 .. llll ?,C311M1r .AMA ZACHARIAH BEHRENS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HEATHER BEHRENS, NO. 08 - 4789 CIVIL TERM Defendant IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) 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 THATT EH STATEMENTS MADE IN THE FOREGOING 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. Dated eather Behrens of JMrwr M OCT -I 2 06 ,,#tA,tlt':"-4U-' 6 aJU Pe"YLVAW ZACHARIAH BEHRENS, Plaintiff V. HEATHER BEHRENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 08 - 4789 CIVIL TERM : 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Services was executed by the Defendant on August 14, 2008 (Acceptance of Service is attached). 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff September 9, 2009; by the Defendant September 24, 2009. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing. Date: 4.1 n !O? Mark F. Bayley, uire BAYLEY & NGAN 17 W. South St. Carlisle, PA 17013 717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff !!H Y OF THE . ? 2009 OCT -I PM 2,006 PENNSYLVANIA ZACHARIAH BEHRENS V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER BEHRENS : NO 2008 - 4789 DIVORCE DECREE AND NOW, CLh it is ordered and decreed that ZACHARIAH BEHRENS plaintiff, and HEATHER BEHRENS , 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, Att t: J. rothonotary C' fo.1' ,r le