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HomeMy WebLinkAbout08-7319IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No.6S - 731p Civil Term Plaintiff Civil Action - Law VS. Steven D. Nehf 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 divorce or annulment may be 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 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No. O$ - 7319 Plaintiff Civil Action - Law VS. In Divorce Steven D. Nehf Defendant COMPLAINT UNDER SECTION 3301 OF DIVORCE CODE 1. (,,.,Lc- Plaintiff is Laurie L. Nehf, an individual, who currently resides at 111 South Prince Street, Apt. B-5, Shippensburg, Cumberland County, Pennsylvania, since June 1, 2008. 2. Defendant is Steven D. Nehf who currently resides at 89 Stoney Lane, Newburg, Cumberland County, Pennsylvania, since October 15, 2007. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on December 12, 2007 at Washington County, Hagerstown, Maryland. V 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Wherefore Plaintiff requests that she be granted a divorce from the bonds of matrimony. Respectfully submitted. H. Anthony A ams, s Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 . w I verify that the statements made in this Complaint 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: ?a Laurie L. Nehf K "r pr 1 c T W J G°? f71 r=- cr) a M V i c: 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No. 08-7319 Plaintiff : Civil Action - Law VS. Steven D. Nehf Defendant : In Divorce AFFIDAVIT OF SERVICE 5 co J m z N A t iu m N E H. Anthony Adams, Esquire state that a complaint in divorce was mailed to Steven D. Nehf, of 89 Stoney Lane, Newburg, Pennsylvania, 17240, by certified mail, return receipt requested on, December 18, 2008 and was accepted on delivery by Steven Nehf, on December 19, 2008. N ZZ6 3 3 m O Ln L-j m ti a 0 0 0 Ln n- w W Ln Ltl ru H. Anthib` kttams, squire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this day of anuL 20 U Notary Public My Commission Expires: COMMONWEALTH OF Pi_ iNSYLVANIA NOTARIAL SEAL MICHELE R. DURF, Notary Public Boro of Shippensburg, Cumberland County My Commiswon Expires July 16, 2012 J n L • C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No. 08-7319 Plaintiff : Civil Action - Law VS. Steven D. Nehf Defendant : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 16, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. y ff Date: Laurie L. Nehf OF T, 2 O9 APR 24 All 11: 31 CUB - ; , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No. 08-7319 Plaintiff : Civil Action - Law VS. Steven D. Nehf Defendant : In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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, 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 immediately 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. Section 4904 relating to unsworn falsification to authorities. Date: b ?? l zn?o / -?-q - Laurie L. Nehf Plaintiff UEs. E3 E 2009 APR 24 AM I I ; u # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No. 08-7319 Plaintiff : Civil Action - Law VS. Steven D. Nehf Defendant : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 16, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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:. 12-0,9 Steven D. Nehf F11ED--a,F E OF THE PR H0,','0TAR 2009 MAY 14 PH 1= 57 VVY/? .. ,r/` r!1 IN IV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No. 08-7319 Plaintiff : Civil Action - Law VS. Steven D. Nehf Defendant : In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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, 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 immediately 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. Section 4904 relating to unsworn falsification to authorities. ,ra Date: Steven D. Nehf Defendant RLED-OFFICE OF THE FARO11_1,NOOTARY 2009 MAY 14 PM 1: 57 Kjf/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Laurie L. Nehf : No.08-7319 Civil Term Plaintiff Civil Action - Law VS. In Divorce Steven D. Nehf Defendant 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 the complaint: Service was made by Certified Mail Return Receipt Requested on December 18, 2008 and was accepted by Defendant on December 19, 2008. An Affidavit of Service has been filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff, April 18, 2009; by Defendant, May 12, 2009. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice was signed on April 18, 2009 and was filed on April 24, 2009 and Defendant's Waiver of Notice was signed May 12, 2009 and is filed herewith. k r-. _ H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 RLED-a::,rFICE OF THE P ^" HONOTARY 2009 MAY 14 P1i 1= 58 LAURIE L. NEW V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN D. NEHF : NO 08-7319 DIVORCE DECREE AND NOW, rn a.., 1?` , a Q09 , it is ordered and decreed that LAURIE L. NEHF , plaintiff, and STEVEN D. NEHF , 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 By the Court, Z,4 ?-Y, J. v 26onotary a l `C9