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Home My WebLink About04-1234COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL DIVISION - LAW NATASHA M. STRINE, : NO. 20vg ,v. CIVIL TERM 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 divome 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 grounds 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 Prothonotary's Office 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 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL DIVISION - LAW NATASHA M. STRINE, : NO. 200/g-/~J~ CIVIL TERM Defendant : IN DIVORCE COMPLAINT AND NOW, comes the Plaintiff, by and through his attorney, Bronjos & Gilroy, P.C., and sets forth the following: l. Plaintiff is Corey A. Strine, who currently resides at 3576 Ritner Highway, Newville, Cumberland County, Pennsylvania. 2. Defendant is Natasha M. Strine, who currently resides at 1158 Centerville Road, Newville, Cumberland 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. The parties were married on August 28, 1998 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the pasties in this or any other jurisdictinn. 6. Plaintiff has been advised that cotmseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. WHEREFORE the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. March 23, 2004 ,~ ~ ~ --~~~~- ~xJohn ~I. Broujos, Esquire No~ 06268.) 3~,o]:fiey for Plaintiff ~ BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717-243-4574; Fax: 717-243-8227 I verify that the statements made in this pleading 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 unswom falsification to authorities. COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL DIVISION - LAW : NATASHA M. STRINE, : NO. 2004-1234 CIVIL TERM Defendant : : IN DIVORCE AFFIDAVIT OF SERVICE I, John H. Broujos, Esquire, being duly sworn according to law, do depose and state that a copy of the Complaint and Notice to Plead filed in the above referenced matter was served on Defendant Natasha M. Strine by U.S. First Class, Certified Mail, on March 24 at the address below. The Return Receipt is attached. Natasha M. Strine ~ 1158 Centerville Road / Newville, PA 17241 April 1, 2004 '.~,ohn H. ~roujos, Esquire No.X'0268 A'tto~mey/for Plaintiff BRO1J-IOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 (717) 243-4574 (717) 243-8227 FAX Sworn and subscribed before me this 1st day of April, 2004 ~ A ' r-~tct~PublicC~'~-- _ ~f ~ C~..~} I' Notarial Seal Bridget Ann Co~r~mn Notary Public Carlisle Bom, Cumberland County My Commission Expires Jun~ lO, 2006 Member, Psnnsyfvanta Assoc, iation of Notaries · Co~nplete items 1, 2, and 3. Also complete iter~ 4 if Restricted D~ve~ is dellired. ~>~ ~ . · Pflr~ your name aid adl~laa on tba revame so l~at we can retum~the card to you. ".-J · Attach this card to the back of the mailplece, [] Agent or on the front if space permits. COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : V. : NO. 2004-1234 CIVIL TE?dV[ : NATASHA M. STRINE, : CIVIL ACTION-LAW Defendant : 1N DIVORCE NOTICE TO PLEAD TO: Corey A. Strine c/o John H. Broujos, Esquire Broujos & Gilroy 4 North Hanover Street Carlisle, Pennsylvania 17013 You are hereby notified that you have twenty (20) days m which to plead to the enclosed Answer and Counterclaim or a Default Judgment may be entered[ against you. ~/J '64~ L/ David A. Baric, Esquire Date: 7 I.D. #44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 COREY A. STRINE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2004-1234 CIVIL TERM : NATASHA M. STRINE, : CIVIL ACTION-LAW Defendant : IN DIVORCE ANSWER AND COUNTERCLAIM NOW, comes Defendant, Natasha M. Strine, by and through her attorneys, O'BRIEN, BARIC & SCHERER, and files the within Answer and Counterclaim and, in support thereof, sets forth the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. To the extent these averments are conclusions of law, no response is required. To the extent a response is required, the averments are denied. WHEREFORE, the Defendant requests that the Court not issue a degree in divorce. COUNTERCLAIM 10. Defendant, Counter-Plaintiff, incorporates by reference her answers to paragraphs one through seven as though set forth at length. 11. The parties have acquired personal property, including automobiles, bank accounts and other items of miscellaneous personalty during the course of their marriage, some of which is marital property. WHEREFORE, should this Court decide to enter a degree of divorce Counter-Plaintiff requests this Court to enter a decree which effects an equitable distribution of marital property. Respectfully submitted, David A. Baric, Esquire I.D. 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Defendant/Counter-Plaintiff dab.dir/domestic/strine/answer&counterclaim.pld VERIFICATION I verify that the statements made in the foregoing Answer and Counterclaim are true and correct to the best of my knowledge, information and belief. This verification is signed by David A. Baric, Esquire, Attorney for Defendant and is based upon the statements provided by Defendant as well as documents reviewed by the undersigned as attorney for Defendant. This verification will be substituted and ratified by a verification signed by the Defendant who is presently unavailable to sign said verification. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unswom falsification~to authorities. ~ Dated: 04'/Jx-~/0~ David A. Baric, Esquire CERTIFICATE OF SERVIC[} I hereby certify that on April ['-~ , 2004, I, David A. Baric, Esquire of O'Brien, Baric & Scherer, did serve a copy of the Answer and Counterclaim, by first class U.S. mail, postage prepaid, to the party listed below, as follows: John H. Broujos, Esquire Broujos & Gilroy 4 North Hanover Street Carlisle, Pennsylvania 17013 David A. Baric, Esquire COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL DIVISION - LAW : NO. 2004-1234 CIVIL TERM NATASHA M. STRINE, : Defendant : IN DIVORCE ANSWER TO DEFENDANT'S COUNTERCLAIM Plaintiff; through his attorney John H. Broujos of Broujc, s & Gilroy, P.C., sets forth the following answer to counterclaim: 10. No pleading required. 11. Admitted. { ~ WHEREFORE, Plaintiff agrees to equitable dist~ · Date: April [(~, 2004 Jo~h-H<~. Br! ~ujos, Attorney for Plaintiff 4 N. Hanover Street Carlisle, PA 17013 717/243-4574; FAX 243-8227 PaBar 06268 c: Attorney David Baric I verify that the statement made herein is true and c.o/~ ~best of my knowledge, information, and belief as attorney for Ulaintiffrelyih~J ff~n st~~by Plaintiff to attorney for Plaintiff. . x,x~~~ Date: April I/~ , 2004 n H. Brnujos, Esquire CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Answer to Defendant's Counterclaim on the following person, by U.S. First Class Mail, on April/~__, 2004: David A. Baric, Esquire ~-- O'Brien, Baric & Scherer I ~~~- 19 W. South Street Carlisle, PA 17013 ~ i. Broujos, Esquire COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL DIVISION - LAW : NO. 2004-1234 CIVIL TERM NATASHA M. STRINE, : Defendant : IN DIVORCE PLAINTIFF'S COMBINED AFFIDAVIT OF CONSENT AND WAIVER UNDER PaRCP 1920.73 OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 23. 2004. 2. Defendant acknowledged receipt and accepted service of the Complaint on or about March 31. 2004. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to thc entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's tees or expenses if I do not claim them betbre a divorce is granted. 6. I understand that I will not be divorced until a Divorce Decree is ente~xl by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the ProthonotaD'. 7. I have been advised of the availability of marriage counseling and understand that ! may request that the Court require counseling. I do not request that the Court require counseling. 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. ~ Date: ~'~,"~ O, C.~'" COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL DIVISION- LAW : NO. 2004-1234 CIVIL TERM NATASHA M. STRINE, : Defendant : IN DIVORCE DEFENDANT'S COMBINED AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE, AND WAIVER UNDER PaRCP 1920.73 OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code svas filed on March 23, 2004. 2. Defendant acknowledges receipt and accepted sen, ice of the Complaint on March 31. 2004. 3. The marriage of the Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of the filing o£1he Complaint. 4. I consent to the enl~' of a final decree of divorce without notice. 5. 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. 6. ! 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. 7. I have been advised of the availability of marriage counseling and understand that i may request that the Court require counseling. I do not request that the Court require counseling. 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. N~atas"~a ~1. Strine COREY A. STRINE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ; v. : CIVIL DIVISION- LAW : NO. 2004-1234 CIVIL TERM NATASHA M. STRINE, : Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Conrt for entry, of a divorce decree: 1. Ground for Divorce: Irretrievable breakdox*~ under Section 3301{c) of the Divorce Code. 2. Date and manner of service of the Complaint: March 24. 2004 by U.S. First Class. Certified Mail. Return receipt and Affidavit of Service filed with Prothonotary. on April 5. 2004. 3. Date of execution ofthe Affidavit of Consent and Waiver of Notice required by Section 3301(c) of the Divorce Code: by Plaintiff: _~.'~e~ by Defendant: ~. 4. Related claims pending: none. 5. Date PlaintitYs Waiver of Notice in §3301(c) of the Divorce Code was filed with the Prothonotary: . Date Defendant's Waiver of Notice in §3301(c) of the Divorce Code was filed with the Prothonotary.: ~ ~~ui re 6268 BROUJOS & GILROY. P.C. 4 North Hanover Street Carlisle. PA 17013 Date: IN THE COURt Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~ PENNA. COREY A. STRINE NO. 2004 - 1234 VERSUS NATASIiA M. STRINE DECREE IN DIVORCE j- AND NOW,~ , it iS ORDERED AND DECREEOTHAT CORE¥ t. STRINE ,PLAINTIFF. AND NATASflA H. STRINE , 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 A3-rEST: J. ~'ARY