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
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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.
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Date
Eva Agnes Rasmussen
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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
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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
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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
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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
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2069 NOV 24
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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.
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