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HomeMy WebLinkAbout08-7392 Nichole M. Staley O'Gorman, Esquire ID #78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley@pkh.com JENNIFER WALTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA [ - 7a? ?ivil Ter?"? V. NO. MATTHEW N. WALTZ, CIVIL ACTION - LAW 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 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, 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 32 South Bedford Street Carlisle, PA 17013 (717) 245-8787 a 4 "• Nichole M. Staley O'Gorman, Esquire ID #78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley@pkh.com JENNIFER WALTZ, Plaintiff V. MATTHEW N. WALTZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0. (9g- 73 9'z CL? T? CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Jennifer Waltz, by her attorneys, Purcell, Krug & Haller, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Jennifer Waltz, an adult individual whose current address is 560 Bowman Street, Millersburg, Dauphin County, Pennsylvania 17061. 2. Defendant is Matthew N. Waltz, an adult individual whose current address is 30 Clubhouse Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on October, 18, 2003, in Millersburg, Pennsylvania. . g 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there are no children of the parties resulting from this marriage 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The marriage is irretrievably broken. 10. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. PURCELL, KRUG & HALLER By: DATE: ?' YOA Nichole . Stal 'Gorman, Esquire I D #789 6 1719 No h Front treet Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff 2 . VERIFICATION I, Jennifer Waltz , Plaintiff in the within action, hereby verify that the facts contained in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ATE : 1,&CC'h' bed ?7, ,?cx?? DATE:' -ia- 74 R* - C .) r.? R' cz? C-) ni 70 Nichole M. Staley O'Gorman, Esquire ID #78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley@pkh.com JENNIFER WALTZ, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW N. WALTZ, Defendant CIVIL ACTION - LAW NO. 08-7392 : IN DIVORCE ACCEPTANCE OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss. AND NOW, this RO day of , 2008, I, Paul J. Esposito, Esquire, hereby certify that I am authorized to accept service of the Complaint in Divorce filed on December 19th, 2008, on behalf of the Defendant, Matthew N. Waltz. Sworn and subscribed to before me this C23 Id day of , 20jj. 44?CVJ4.evl Paul J. po io, Esquire GOLDBER KATZMAN 320 Market Street Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 COMMONWEALTH OF PENN-YLVANIA Notarial Seai Sally A. Marsh, Notary City Of Harrisburg Dauphil My Commission Bores is E. ai G Member, Pennsylvania Assnci. '? a try -,,3 r r. .11'.. Nichole M. Staley O'Gorman, Esquire ID #78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley@pkh.com JENNIFER WALTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 08-7392 MATTHEW N. WALTZ, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301(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 1 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 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 unsworn falsification to authorities. Date: y 4 09 41 J *1A LTZ OF THE OTAPY 2009 APP 17 P 2: 01 Nichole M. Staley O'Gorman, Esquire ID #78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley@pkh.com JENNIFER WALTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 08-7392 MATTHEW N. WALTZ, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 19, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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. §4904 relating to unsworn falsification to authorities. Date: y a Jol CDO-X" ?- t3j-pbz? J I F ALTZ F'ILED-DrHGE OF THE P^'rt°Tl-'!)%- TARY 2009 APR 17 Pik 2= 01 ?V{I { !Vt t Paul J. Esposito, Esquire I.D. #25454 GOLDBERG KATZMAN. P.C 320 ]Market Stmt P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161;(717)234-6808 (facsimile) Cow&eJ for Defendant JENNIFER WALTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW N. WALTZ, Defendant NO. 08-7392 Civil Term CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 19, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of, the availability of marriage eeaiiseling'and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received a copy of the Complaint in Divorce on or about December 23, 2008, via Acceptance of Service executed by my counsel. Paul J. Esposito, Esquire. 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: C 9 2009 MATTHEW N. WALTZ 1 FILErl --- Z G9 APR 28 API ;'. 11 s4 VJ. '.3 ..., a _. Paul J. Esposito, Esquire I.D. 925454 GOLDBFRO KATMAN, P.C. 320 Manor Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234.4161; (717) 234-6808 (facsimile) Cowssel for Uefendoar JENNIFER WALTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW N. WALTZ, Defendant : NO. 08-7392 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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. §4904 relating to unsworn falsification to authe-rities. Date: V-K--dg , 2009 ?Tr MATTHEW N. WALTZ FILED-0 -E DF THE 20000 APR 28 Al", 11 ; 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER WALTZ, Plaintiff CIVIL ACTION -LAW V. IN DIVORCE NO. 08-7392 MATTHEW N. WALTZ, Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, _ prior to the Final Decree in Divorce, or after the entry of the Final Decree in Divorce dated hereby elects to resume the prior surname of Jennifer A. Clarke, and gives this written notice pursuant to the provisions of 54 P.S. § 704. Date: COMMONWEALTH OF PENNS COUNTY OF lPc ?` On the 22? day of ?? L , 2009, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the written document and acknowledgment that she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. wEP??m yr ??.rya,,...-...p • 1? KimbeAy S. D?Feico. NoAsry Public City of Hanl?bWy. paupMn Cauriy ??a,,,„pksJan.+7.20+s, No ary Public FIL ,L). vfi= CiE THE 2009 APR 29 PSI 2: 2 3 GENE, . ? { ' ? +? QVI I I. m Po li`MY COP a3?4I "q q?8 __1 S Nichole M. Staley O'Gorman, Esquire ID #78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley@pkh.com JENNIFER WALTZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW N. WALTZ, Defendant : CIVIL ACTION -LAW NO. 08-7392 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 the Complaint: Complaint was served by acceptance of service of counsel on January 6, 2009. 3. Complete either paragraphs (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: By Plaintiff: 4/9/09 and By Defendant: 4/15/09. (b) (1) Date of execution of the Affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b). . ?.- -ar , (a) Date and manner of service of the notice of intention to file a Praecipe to Transmit Record, a copy of which is attached (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 4/17/09; Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 4/28/09. PURCELL, KRUG & HALLER DATE: By: Wchole M. Staley tMoi ID #78966 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff , Esquire j "`"..'-s . RUED nP -1 2009 MA 7 --4 PM 3, 34 JENNIFER WALTZ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW N. WALTZ NO. 08-7392 DIVORCE DECREE AND NOW, 962 A , it is ordered and decreed that JENNIFER WALTZ , plaintiff, and MATTHEW N. WALTZ 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 tWCourt, Attest: J. Prothonotary ?- 1 r t ., D??