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HomeMy WebLinkAbout08-6994MELINDA WINTER Plaintiff V. MICHAEL WINTER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUN Y, PENNSYLVANIA C9- 099 Uiv l Term NO. CV DV CIVIL ACTION 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. A list of marriage counselors is available in the office of the Prothonotary on the first floor of the Cumberland County Courthouse, Carlisle, Cumberland County, PA. 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 LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 The Court of Common Pleas of Cumberland County 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 the Court Administrator at (717) 780-6624. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. MELINDA WINTER Plaintiff V. MICHAEL WINTER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.6g -Gqq CV DV CIVIL ACTION IN DIVORCE COMPLAINT UNDER & 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Melinda Winter, by and through her attorney, Melanie L Erb, Esquire and The Law Offices of Darrell C. Dethlefs, who brings this Divorce action and avers as follows: 1. Plaintiff is Melinda Winter, an adult individual, who currently resides at 114 Sgrignoli Lane, Enola, Cumberland County, Pennsylvania, 17025 since March 2008. 2. Defendant is Michael Winter, an adult individual who currently resides at 82 Linda Drive, Lot #8, Mechanicsburg, Cumberland County, Pennsylvania, 17050 since June 2008. 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 Plaintiff and Defendant were married on September 1, 2007, at Enola, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. This marriage is irretrievably broken. 8. 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. 9. Defendant has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully Submitted, 17 A/ /Alr Date: ela}(ie rb Attorney ID # 84445 2132 Market Street Camp Hill, PA 17011 (717)975-9446 Attorney for Plaintiff Page 4 of 4 VERIFICATION I, Melinda Winter, verify that the statements made in this Petition 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: y O &k&?& Melinda Winter http:f/mail.google.com/trail/?ui=2&ik=b8c4d746f5&view=att&th=11 d9c0a7223a0e88&attid=0. I &disp=... 11/14/2008 Coupons - BYs Wholesale Club Page I of ' Cam ; 1l p r;t a S - c} z ' r,.C () ? - I- r- .7. "? MELINDA WINTER Plaintiff V. MICHAEL WINTER Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6994 Civil Term CIVIL ACTION IN DIVORCE ACCEPTANCE OF SERVICE I, Michael Winter, on the this 4t` day of December, 2008, do hereby accept service of the Complaint in Divorce in this matter. ? Q Date C`? o ? ` C ? r i MELINDA WINTER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.08-6994 MICHAEL WINTER .: CIVIL ACTION Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 26, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elaspsed 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. Section 4904, relating to unworn falsification to authorities. Date: (p 71 rv 1 t'r? ?, e f MELINDA WINTER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ' NO. 08-6994 MICHAEL WINTER : CIVIL ACTION Defendant IN DIVORCE 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, lawyers' 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. Section 4904, relatin-a to unsworn falsification to authorities. Date: 0 cz MAP "'Y ?T? MELINDA WINTER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-6994 MICHAEL WINTER •: CIVIL ACTION Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1 A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 26, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elaspsed 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. Section 4904, relating to unsworn falsification to authorities. Date: 9 Melinda Winter, Plaintiff ? rv MELINDA WINTER Plaintiff V. MICHAEL WINTER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6994 CIVIL ACTION IN DIVORCE 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, lawyers' 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. Section 4904, relating to unsworn falsification to authorities. Date: Melinda inter, Plaintiff ?- 2't - f fy `T1 MELINDA WINTER Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-6994 MICHAEL WINTER ' Defendant 'CIVIL ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for e decree: ntry of a divorce 1. Ground for divorce: irretrievable breakdown under Section (x) 3301 C the Divorce Code. () 3301 D of 2. Date and manner of service of the complaint: By Acceptance of Service on December 4, 2008, a copy of which is filed simultaneously with this Praeci e. 3. Date of execution of the affidavit of consent required by Section 3301 (C) of divorce code. By plaintiff March 6 2009 and filed with the Prothono () the simultaneous) with this Praeci e; by defendant March 6 2009 and filed with the Prothont simultaneousl with this Praeci e. 4. Related claims pending: None 5. Plaintiffs Waiver of Notice in § 3301 (c) Divorce was filed with this Praecie 6. Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with this Prae cape. Respectfully Submitted, Attorney Identification No. 84445 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff na °rr - , + f m ? IT IN THE COURT OF COMMON PLEAS OF MELINDA WINTER : CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL WINTER NO. 08-6994 DIVORCE DECREE AND NOW, 61 it is ordered and decreed that MELINDA WINTER , plaintiff, and MICHAEL WINTER , 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. Prothonotary Attest: J. ,oi i .`62 -d/-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA M , t ., A 00-10?r Plaintiff Vs BzCbo-&-A V AMAI-cam -' Defendant File No. 02 " k0't 9 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] X_ prior to the entry of a Final Decree in Divorce, or after the entry of 4 Final Decree in Divorce dated hereby elects to resume the prior sdi'name of , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: 13 2 CQIC 9 '?!,-=?-..? .! Signature Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF C L, -. L- On the & day of ra , 200 before me, the Prothonotary or the notary public, personally appeared the above aff ant 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. COMMONWEALTH OF PENNSYLVANIA f IV Notary Public Notarial Seal Bryan W. Shook, Notary Public Camp Hill Boro, Cumberland t) n d County My Commission Expi Member. Pennsylvania Association of Notaries 4 y .!: 4,C7 " t' I - - fw.3 r?T -.. fir. ...?,.