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HomeMy WebLinkAbout08-7363 JODI SNYDER, Plaintiff VS. MATTHEW D. SNYDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 0$ - '73(o''S Civil -I& M : CIVIL ACTION - AT 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 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 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 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 r JODI SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. d 7 3L 3( CIVIL ACTION - AT LAW - IN DIVORCE VS. MATTHEW D. SNYDER, Defendant DIVORCE COMPLAINT The Plaintiff, Jodi Snyder, by and through her attorneys, the Law Offices of Patrick F. Lauer, Jr., L.L.C., makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE §§ 3301(c) or 3301(d) 1. The Plaintiff, Jodi Synder, is an adult individual who currently resides at 705 Quaker Circle #4, Lewisberry, York County, Pennsylvania 17339. 2. The Defendant, Matthew D. Snyder is an adult individual who currently resides at 94 Oneida Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The parties were married on October 17, 1999, in Jamaica. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court enter a Decree of Divorce in this matter. COUNT II - SPOUSAL SUPPORT AND/OR ALIMONY PENDENTE LITE, AND ALIMONY 9. Paragraphs one (1) through eight (8) of this Complaint are incorporated herein by reference as if set forth specifically below. 10. Plaintiff is unable to sustain herself during the course of litigation. 11. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 12. Plaintiff requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Section 3701(a) and 3702 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Section 3701(a) and 3702 of the Divorce Code. Marlin L. ey, Esquire Law ice of Patrick F. Lauer, Jr., L.L.C. 2108 Mar et Street, Aztec Building 200Y Camp Hill, Pennsylvania 17011-4706 Date: , 2 v ID# 84745 Tel. (717) 763-1800 JODI SNYDER, Plaintiff VS. MATTHEW D. SNYDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW - IN DIVORCE VERIFICATIO 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. § 4904, relating to unworn falsification to authorities. Date: Signature: J - 6b , Jodi Snyder o cl 3 I l? n I RI F hii r .. W' !,y j.may r 1v 1rn JODI SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 08-7363 MATTHEW D. SNYDER, CIVIL ACTION - AT LAW - IN DIVORCE Defendant AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Marlin L. Markley, Esquire, verify the Complaint in Divorce has been served upon the Defendant indicated above by first class, certified mail # 7002 2410 0002 0986 0942, restricted delivery, return receipt requested, prepaid postage, pursuant to the requirements of Pa. R.C.P. 1930.4. Date: -30 -2 o a,? !Marlin L. M ey, Law O s o Patric F. Lauer, Jr., LLC 2108 arket treet, Aztec Building Camp Hill, ylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 USPS - Track & Confirm :Page 1 of 1 s Home I Help I %gn._In Track-8-Confirm FAQs -- - ---- ------------- Trek Confirm Search Results Label/Receipt Number: 7002 2410 0002 0986 0942 Status: Delivered Your item was delivered at 3:16 PM on December 23, 2008 in CAMP HILL, PA 17011. Notification Options 0. natl X Track & Confirm by email Get current event information or updates for your item sent to you or others by email. (> ) to Mao ontact Us Forms Gov't_Seryices Jobs. Privacy Policy Terms_of_use National_$ PreMier Accounts Copyright©1999-2007 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA ¦ bentptete Item. 1 2, and 3. Also complete Mnn 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Adtach this card to the back of the mailpiece, or on the front if space permits. 1. Arecte Addressed to: Maf4e o sn yde?2 On e i do` Ct,.tY1 P? 1 ?, -1-)A- B. Regfeived by Track & Confrm Enter Label/Receipt Number. ? Agent O AddtMNt! C. Date of DOIKWy is delivery address different from Item 17 ? Yes If YES, enter delivery address below: ? No Certified Mail ? Express Mail 3. ice I Registered ? Retum Receipt for Merchr 0 ? insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. ArWe Number (ow"ArtrCrn..rIinimteq 7222 2410 01022 0986 2942 Phi Dorm 3811, Fsbnury 2004 t7ornwYc tMlurtt A.orrtpt tasa? r?ts?o http://trkcnfrml .smi.usps.com/PTSIntemetWeb/InterLabelInquiry.do 12/?n??nnQ JODI SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 08-7363 Civil Term C-) r-I MATTHEW D. SNYDER, CIVIL ACTION - AT LAW - IN D WC19 Defendant c i-- pa _<> _J -a MC) NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN TI4IS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated sometime in May of 2005, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. § 4904 relating to unswom falsification to authorities. Date: Z JC4? J Jady Snyder, Plaintiff JODI SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 08-7363 Civil Term MATTHEW D. SNYDER, CIVIL ACTION - AT LAW - IN DIVORCE Wd Defendant rr, - m ` F PRAECIPE TO WITHDRAW COUNT -?- `n TO THE PROTHONOTARY: Please withdraw Count II - Spousal Support and/or Alimony Pendente Lite, and Alimony. Date: June 4, 2012 Respectfully , Marlin L. T 3920 Mar. Camp ID# 84 45 harkley, Jr., Esquire ;t Street, Suite 303 Pennsylvania 17011 Tel. (717) 635-9538 ?, V A? ( JODI SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 08-7363 Civil Tenn MATTHEW D. SNYDER, CIVIL ACTION - AT LAW -1N DIVORCE Defendant r?j CO -.- NOTICE OF INTENTION TO REQUEST ENTR w: OF § 3301(d) DIVORCE DECREE: TO: MATTHEW D. SNYDER, Defendant c/o G. Patrick O'Connor, Esquire 3106 Old Gettysburg Road Camp Hill, PA 17011 Jodi Snyder intends to file with the court the attached Praecipe to Transmit Record on or after May 24, 2012 requesting that a final decree in divorce be entered. Respectfully Marlin a cley, Jr., Esquire 3920 Mark Street, Suite 303 Camp Hil , Pennsylvania 17011 Date: April 30, 2012 ID# 847 5 Tel. (717) 635-9538 J AM 0: li `. 111 JODI SNYDER,Elt?a?i"''1°' : IN THE COURT OF COMMON PLEAS OF Plg`i? SYLVAN 1 A : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 08-7363 MATTHEW D. SNYDER, CIVIL ACTION - AT LAW - IN DIVORCE Defendant AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Marlin L. Markley, Esquire, certify the Notice of Intention to Request Entry of § 3301 (d) Divorce Decree has been served upon the Defendant's Counsel on April 30, 2012, by first class U.S. Mail addressed as follows: G. Patrick O'Connor, Esquire 3106 Old Gettysburg Road Camp Hill, PA 17011 Respectfully Marlin kley, Jr., Esquire 3920 Mar t Street, Suite 303 Camp Hi , Pennsylvania 17011 Date: June 4, 2012 ID4 847 5 Tel. (717) 635-9538 JODI SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 08-7363 Civil Term MATTHEW D. SNYDER, CIVIL ACTION - AT LAW - IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: ?. . ' Transmit the record, together with the following information, to the Court for Fpl-q a divorce decree: - ", 1. Ground for Divorce: Irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and Manner of service of the Complaint: Certified U.S. mail. Complaint was signed for on December 23, 2008. The Affidavit of Service was filed with the prothonotary's office on January 2, 2009. 3. (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by the Plaintiff by the Defendant (b) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: April 24, 2012 ; Date of filing of the Plaintiffs affidavit: April 27 2012 ; Date of service of the Plaintiffs affidavit upon the respondent: April 30, 2012 4. Related claims pending: None (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, April 30, 2012, by first class mail to defendant's counsel ; (b) Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: Respectfully `f Marlin L•? 3920 Mar Camp 1 Date: June 4, 2012 ID# 84 45 ?dey, Jr., Esquire ,t Street, Suite 303 Pennsylvania 17011 Tel. (717) 635-9538 IN THE COURT OF COMMON PLEAS OF JODI SNYDER CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW D. SNYDER NO. 08-7363 Civil Term DIVORCE DECREE AND NOW, _ h. Kt I R jL it is ordered and decreed that JODISNYDER plaintiff, and MATTHEW D. SNYDER bonds of matrimony. defendant, are divorced from the 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, Attest: - Prothonotary .? c ljvhce ry