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HomeMy WebLinkAbout08-7291JARED NEILS RASMUSSEN, Plaintiff V. EVA AGNES RASMUSSEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08- 7a-c/1 CIVIL TERM 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 will proceed without you and a decree in divorce or annulment may 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 at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 JARED NEILS RASMUSSEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08- 7?-q CIVIL TERM EVA AGNES RASMUSSEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Jared Neils Rasmussen, an adult individual, currently residing at 148R North Spring Garden Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Eva Agnes Rasmussen, an adult individual, currently residing at 5 Karl-Kuntz Weg, Mannheim, Baden-Wurttemberg, Germany 68163. 3. 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. 4. Plaintiff and Defendant were married on June 28, 2004 in Oroville, Butte County, California. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The 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, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff is a citizen of the United States of America. 9. Defendant is a citizen of The Federal Republic of Germany 10. The parties have lived separate and apart since August 1, 2007 and continue to live separate and apart as of the date of this Complaint. 11. The parties' marriage is irretrievably broken. 12. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. 13. No children were born of this marriage 14. Property was previously divided to mutual satisfaction of the parties. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree it divorce. bate' Respectfully Submitted TURO LAW OFFICES Brian O. Williams, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney ID 209610 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. 200 8 /Z / Date /arMd Neils Rasmussen CERTIFICATE OF SERVICE I, Brian O. Williams, Esquire hereby certify that I served a true and correct copy of the Divorce Complaint, by first class, International postage pre-paid and depositing same in the United States International Mail, first class certified, postage pre-paid on the / I- day of 2008, from Carlisle, Pennsylvania, addressed as follows: Eva Agnes Rasmussen 5 Karl-Kuntz Weg, Mannheim, Baden-Wurttemberg, Germany 68163 TURO LAW OFFICES Brian O. Williams, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Supreme Court I.D. No. 209610 t? ?A W TP Q V ` n n cyl 0 JARED NEILS RASMUSSEN, Plaintiff V. EVA AGNES RASMUSSEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7291 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 15, 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. 1 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. C_ _ h Date Eva Agnes Rasmussen JARED NEILS RASMUSSEN, Plaintiff V. EVA AGNES RASMUSSEN, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7291 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE QgCREE UNDER 6 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 understand that 1 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 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. W. acook Date Eva Agnes Rasmussen `s, "?,? ?y .. .+? t, JARED NEILS RASMUSSEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 7291 CIVIL TERM EVA AGNES RASMUSSEN : CIVIL ACTION - LAW Defendant. : IN DIVORCE PROOF OF SERVICE Registered No. RE334SM21S Date Stamp Reg. Fee $10• 0013 Handing Return • ID U `v Charge Receipt w ° Postage Restricted E o Delivery c m m T Received by 0m st D*.a w Domestic Insuran• based upon the Indemnity is i 17013 d s o LL T C j• mam v at y c d ? d ndm E K Gerraa9 d ° W - V C'tl e S ?0.5rr1ySS e? \ PS Form 3806, Receipt for Registered Mail Copy 1 - Customer May 2007 (7530-02-000-9051) (See Information on Reverse) For domestic delivery information, visit our website at www.usps.com JARED NEILS RASMUSSEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 7291 CIVIL TERM EVA AGNES RASMUSSEN : CIVIL ACTION - LAW Defendant. : IN DIVORCE PROOF OF SERVICE Registered No. Date Stamp Reg. Fee ?0013 Handling Return Charge Receipt 0? Postage 1114- 1% Restricted E o Delivery ty? (' CL Received by q ` U co 17013 m n T !V ~ cc G E O O C 8 ., $ U- tL r c mm mo c _ m '? d n a10im E a a U v K 6e d O c W Vll- a PS Form 38 06, RE May 2007 (7530-02-000 For domestic deliver Domestic Insurance based upon the declare Indemnity is limited. P I Registered Mail Copy 1 - Customer (See Information on Reverse) visit our website at www.usps.com Item Description R gistered Printed Recorded Delivery Express (Nature de rtide (Envoi C] Letter O Matter ? Other O (Envoi d tivraison O Mail Int( 1'envoi) recommand6) (Lettre) (Imprim6) (Autre) attest6e) national ? b' Insured Parcel Insured Value (Valeurddclar6e) Article Number 15 b O (Colis aver valeur d6clane) Office of Mailing (Bureau de d6p6t) Date of Posting (Date de d6p6t) a Addressee Name or Firm (Nom ou raison socials du destinataire) Street and No. (Rue et No.) Place and Country (Localitd at pays) This receipt must be Sued by (t) the addressee; or, (2) a person auBt fitted to sign under the regulations of the Gantry of destination; or, (3) if Vase regiAatiors so prcwide, by ft err#ayee of #* dke of desfinalion. This signed form will be reUrned to the sender by the W mail. Pastrrek d the cfficed destination (Timbre di ?. (CetarisdoitWeso parkdesbroatareoupar unepersaneyaduisEeenwifudesrfigrr?>erdsdupa)sdedestinafim,ousces Unw de destirWN rd*nff 1&cw; ItWparI*ntdubtrmdedesbnatidtefrenwyepakpertieraanie?edert>?tAe?E6teu). <o The article mentioned above was duly delivered. O t li L e i 6 i 6 dO 6 6 Date ? men vr ( nvo mentionn c -dessus a .) t . ( 0 i re of Addressee (Signature- Office of Destination Employee Signature d estinatgV) ? ?',i'??: (Signature de I 'agent du bureau du destination) 1 Q ? ? TI-E 2009 NO1124 FH 12: ?, 1 G o I JARED NEILS RASMUSSEN, Plaintiff V. EVA AGNES RASMUSSEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7291 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 15, 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. 1 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. ._ C. `) j // 2-0 Date tired Neils Rasmussen 2009 NOV 24 Fri 12: 4 7 JARED NEILS RASMUSSEN, Plaintiff V. EVA AGNES RASMUSSEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7291 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER -4 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 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 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. `I Date red Neils 'Rasmussen -,I 2009 J' cis° 12: 4? 1-7y GUN ??l-^ JARED NEILS RASMUSSEN, Plaintiff, V. EVA AGNES RASMUSSEN Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 7291 CIVIL TERM CIVIL ACTION - LAW 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. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Certified, Returned Receipt International mail delivered to Defendant on or about December 27, 2008. 3. Date of execution of Affidavit of Consent: By Plaintiff: November 20, 2009 By Defendant: October 28, 2009 4. Related claims pending: None. 5. Date the Waiver of Notice was filed with the Prothonotary: By Plaintiff: Simultaneously with the filing of this Praecipe By Defendant: November 18, 2009 Respectfully Submitted, TURO LAW OFFICES Date: November 24, 2009 Lo An ew S yder, Esq. 2 S. Pitt S arlisle 17013 717-245-9688 f il??..u '7 R Y 2069 NOV 24 \tA of ?'e "V, r )'r Lt N! ,;: JARED NEILS RASMUSSEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. EVA AGNES RASMUSSEN NO. 08-7291 DIVORCE DECREE O.T- X1 AND NOW, 200 , it is ordered and decreed that JARED NEILS RASMUSSEN plaintiff, and EVA AGNES RASMUSSEN , 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. the Court, Attest: J. j I U'Lon 4 Protho otary I 1?q id 10 1d 1p a