Loading...
HomeMy WebLinkAbout01-4730MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0/-/ff 7._~Z5 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 will proceed without you and a decree of divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other fights 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 at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~/" zr/~°>~ CIVIL TERM 1N DIVORCE COMPLAINT IN DIVORCE NO FAULT Plaintiff is Michael P. Schneider, an adult individual currently residing at 409 Potato Road, Carlisle, Cumberland County, Pennsylvania, since December 2000. Defendant is Evonne M. Schneider, an adult individual currently residing at 92 Stanton Street, Providence, Rhode Island, since December 8, 2000. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on August 26, 1994, in Great Falls, Cascade County, Montana. There have been no other prior actions for divorce or annulment between the parties. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. Respectfully submitted, ~s qt~(~t, fi e~r Plaintiff/~it~;'oner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing docmnent 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 falsifications to authorities. MICHAEL P. SCHNEIDER, Plaintiff MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-4730 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE FOR COMPLAINT IN DIVORCE STATE-- OF RI{ODE/SI_~.%,~ A~'~D P~O~NC~ PKOVIDEN~ COL~ A--Y Si-~-R~-~ AFFIDAVIT STA.---Z OF.%F-ODE iS~-~-\'D PXOVV_D~CE, SC .C0~T C.A..--'= :2. NO. say: v ~ a De:u:y Sheriff '--crki--~ cur of h- 2rcvi-Jence Coun:y Sheriff's Office, Tea: cz :he ~ay cf A.'D. ~0 , ,aa -. 'i'- - Coun:y ~y SherSf~ Su%sc:!'oe~ z--a s.c.--:" _ :o befo:e =e :his /~7~ ~ay cf ~ Co~-. F-xp.: -- -- ' MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-4730 CIVIL TERM : IN DIVORCE If you wish to deny any of the statements set forth in the attached affidavit, you must file a counter-affidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER §3301(d~ OF THE DIVORCE CODE The parties to this action separated since April 5, 2000, and have continued to live separate and apart since that time. 2. The marriage is irretrievable broken. 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. I verify that the statements made in the foregoing document 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 falsifications to authorities. MICHAE~ P. SCHNEID~D-ERTPIaintiff MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-4730 CIVIL TERM : IN DIVORCE PRAECIPE TO THEPROTHONOTARY: Please reinstate the Divorce Complaint filed in the above captioned action. Date: squire vt hS IE & ASSOC TES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 MICHAEL P. SCHNEIDER, Plaintiff VS. EVONNE M. SCHNEIDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - LAW : NO. 01-4730 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE Sta___te of Rhode Island and Providence Plantations Washington County Sheriff 4800 Tower Hill Road Wakefield RI 02879 I ~.0/2;> ~ '(---' , being duly sworn, de se and sa Action, am over 21vears of ~ a,,~, ............... .po ~ y that l am not a patty to the _ aoe, _.,~ ,~m a ~-'~v,~2, ~nenrr ot washington county, State of R.I. On the-~y of~ n ~ ,200_~_at ~d.~/~*,~e./o ,,/[,~ ,!~2c~'77 I served a true and attested copy of the attach~i w~it(along with copies of any accompany~ g Complaint and/or other documents} uport ~/~,,~ r~. ~ x,~/~ Mt t '~ ¢ ~ The defendant or one of the defendants her~in named in the followiag manner. Bydaliveringacopyofthewritto ~-v'*,,r~e_ ~ "J'~-~.n'~t~e-,~' ~'~'~ly~~ ~tlaouVis;g received permission from plaintilFs att~ney, i left a copy of the% at defendant ,s dwelling -- with a ner.~n of suitable Age and discretion residing therein, to ~ ~ - ~ wit,.., uthotiz~v ~vbeYnl~sW to~.ve By delivering a copy of the writ to an agent a appointment, or by law to ve se Process, namel Further nofic, e~re~ ' trice of ollows Y utred was Sworn to before me thi~2'''~ day olde. 20 0 ~. AD Fees Plaintiff V. EVONNE M. SCHNEIDER, Defendant : CLrMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LATM : NO. ~/- ~'7-Y~ 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 will proceed without you and a decree of divorce or annulment may be entered against :- · you for any 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 at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF MARITAL PROPERTY, LAWYER'S FEES OR EX?ENSES BEFORE A DIVORCE OR ANNIJI,MENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF TI-IEM. FIt,,ED 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. Zumberland County Bar Association Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 MICHAEL P. SCHNEIDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW EVONNE M. SCHNEIDER, NO. 01-4730 CIVIL TERM Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in the attached affidavi ~'~ou m~st a counter-affidavit within twenty days after this Affidavit has been served o~you2-?or t~ statements will be admitted. -~ ~'~ -~ - AFFIDAVIT UNDER §3301(d) OF TI:[E DIVORCE CODE The parties to this action separated since April 5, 2000, and have continued to live separate and apart since that i/me. 2. The marriage is irretrievable broken. I'understand ~at I may lose rights concerning alknony, division of property, lawyer's . fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in the foregoing document are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating tO unswom falsifications to authorities. DATE: MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 014730 CIVIL TERM : IN DIVORCE .,COUNTER AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ~ (a) I do not oppose the entry of a divorce decree. ~ (b) I oppose the entry of a divorce decree because (Check either (i), (ii), or both) (i) The parties to the action have not lived separate an apart for a period of at least two (2) years. --. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ~ (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses ifI do not claim them before a divome is granted. ~ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divome decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in the foregoing document are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: EVONNE M. SCHNEIDER, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER AFFIDAVIT. MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-4730 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on August 9, 2001, resinstated on May 24, 2002, and served on June 5, 2002. 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 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. DATE: MI'QHAEq~P. S ~'~[N'Eq-t;IF.,~ai nt iff MICHAEL P. SCHNEIDER, Plaintiff EVONNE M. SCHNEIDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01-4730 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 divorce 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 files with the Prothonotary. 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. DATE: MI~(~flAEL~P. SCHNEIDER, l~laintiff MICHAEL P. SCHNEIDER Plaintiff, EVONNE M. vs. SCHNEIDER Defendant. iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-4730 CIVIL TERM IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statement will be admitted. The parties to this action separated on April 5,2000 and have continued to live separate and apart for a period of at least two years. o The marriage is irretrievably broken. 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. 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.A. 4904 relating to unsworn falsification to authorities. Date: Evonne M. Schneider, Defendant MICHAEL P. SCHNEIDER : Plaintiff : V. : EVONNE M. SCHNEIDER : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-4730 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE A~FIDAVIT OF CONSENT ~ WAIVER OF COUNSELING 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 9, 2001, reinstated on May 24, 2002 and served on Ju~e 5, 2002. 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 of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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. A rS: Schneider, Defendant MICHAEL P. SCHNEIDER, Plaintiff V. EVONNE M. SCHNEIDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-4730 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. I consent to a final decree without notice. 2. I understand that I may )ose 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 irmmediately 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 unsworn falsification to authorities. Evonne M. Schneider, Defendant ) IN THE COURT OF COMMON PLEAS OF MICHAEL P. SCHNEIDER ) CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, ) ) NO. 01-4730 CIVIL TERM VS. ) ) CIVIL ACTION - LAW ) EVONNE M. SCHNEIDER ) Defendant. ) IN DIVORCE PRAECIPE TO TRANSMIT RECORD UNDER SECTION 3301(d) OF THE DIVORCE CODE TO THE PROTHONOTARY: Kindly transmit the record and the following information for entry of a Divorce Decree. 1. Ground for divorce: Irretrievable breakdown under Section 3301(d) (1) of the Divorce Code. 2. Date and manner of service of Complaint: Complaint was filed on August 9, 2001, reinstated on May 24, 2002 and served upon Defendant 3. Date of execution of the affidavit required by 3301(d) of the Divorce Code: May 2, 2004; Date of filing and service of the Plaintiff's affidavit upon the respondent: Affidavit filed May 19, 2004 and served on May 21, 2004. 4. Related claims pending: None. file Praecipe Notice served Plaintiff via 2004. Date and manner of service of the Notice of Intention to to Transmit Record, a copy of which is attached: upon Bradley L. Griffie, Esquire, counsel for U.S. First Class mail postage pre-paid on May 21, Gre~or C. Katshir, Esquire Atto~y for Defendant MICHAEL P. SCHNEIDER Plaintiff, vs. EVONNE M. SCHNEIDER Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-4730 IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Michael P. Schneider Evonne M. Schneider, Defendnat, intends to file with the court the attached Praecipe to Transmit Record on or after, I~-~ IO,~, 2004. Requesting that a final decree in divorce be entered. IN THE COURT OF COMMON MICHAEL P. SCHNEIDER Plaintiff OF CUMBERLAND COUNTY STATE OF .~. PENNA. N o. 01-A730 VERSUS EVONNE M SCHNEIDER Defendant PLEAS DECREE iN DIVORCE ,~7~ IT IS ORDERED AND DECREED THAT Michael P Schneider , PLAINTIFF, aND Evonne M Schneider , 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; by TH ~ · P R OT/-t-fOTA r Y