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Home My WebLink About09-0039 HAROLD 6. IRWIN, tll, EsgU1RE ATTORNEY ID NO. 29920 64 SOUTH PITT sTREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF ADAM M. HOROWITZ, Plalntlff v. MARIANNA L. HOROWITZ, D~hndant IN TM! COURT OF COMMON PLlAS OF CUMBlRLAND COUNTY, PlNN3YLVANIA CIVIL ACTION -LAW NO. 2009 - ~ ~ CIVIL TlRM IN DIVORC! NOTICE 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 in 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 M ADAM M. HOROWITZ, PlaintiM v. MARIANNA L. HOROINITt, Dahndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2009 - 3 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION SS01 c OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is ADAM M HOROWITZ, an adult individual residing at 75 Chester Street,. Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is MARIANNA L. HOROWITZ, an adult individual whose mailing address is P. O. Box 242, Madisonville, Tennessee 37354. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on April 14, 2008, in Carlisle, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is-based that the marriage between the parties is,irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. January 2, 2009 v A AM M. H RO ,Plaintiff HAROLD S. IRWIN, 11 Attorney for Plainti 64 South Pitt Stn3et Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 ADAM M. fNOROWITZ, PlalntlA v. MARIANNA L. HOROWITZ, pendant IN TN! COURT OF COMMON PLlAS OF CUMBlRLAND COUNTY, PlNNSYLVANIA CIVIL ACTION -LAW NO. 2009 - CIVIL TlRM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. January 2, 2009 laintiff ADAM . HORO ITZ, ~ W ~ W '~ , ~ \ ~ d ~ ~ ~ 1 F A ' _. ~ ~ ; a `xr ..~ t~ ~ ---~ " ~ ` -r r ~~ r r r rn ~ .y w lb ADAM M. HOROWITZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-0039 MARIANNA L. HOROWITZ, CIVIL ACTION - LAW ? Defendant : IN DIVORCE -? = -? rn 00 m te =C ? -- T - a= Z)M -C T' N C: DEFENDANT'S AFFIDAVIT OF CONSENT ; co zo 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 6, 2009. 2. The marriage of the 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 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: J1 •i a L. rQ o ?f ADAM M. HOROWITZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVAN A V. : NO. 2009-0039 .a3 r1g r yam. 111 -.c ' ?- ' MARIANNA L. HOROWITZ, : CIVIL ACTION - LAW a rte- Defendant : IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST EN°3 I' Q A;,- DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE COME °° ' 1 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, lawyers' 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 Waiver 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: y 25 - 0 Oar owitz ADAM M. HOROWITZ, Plaintiff V. MARIANNA L. HOROWITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION • LAW : NO. 2009 - 0039 CIVIL TERM : IN DIVORCE rn z? U, r- ..,;4 C=3 CX) r? x r- -o= ? co -n ?j PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about January 23, 2009, defendant was served with a copy of the divorce complaint (see Affifavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: July 20, 2009 By the defendant: April 25, 2011 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: July 20, 2009 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 28, 2010 6. There has been no prior action for divorce or annulment between the parties other than this action which commenced on January 6, 2009. April 28, 2011 HAROLD S. IRWIN, III Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADAM M. HOROWITZ V. MARIANNA L. HOROWITZ NO. 2009 - 0039 DIVORCE DECREE n? 'I ? 3:3,A10-Al. AND NOW, "? , ??? , it is ordered and decreed that ADAM M. HOR WITZ ,plaintiff, and MARIANNA L. HOROWITZ , 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 th rt, Attest: J. Prothonotary s? rr- &r+ &PY n w'led 1 Irwin Nofibe + Copy ma, led -& a=y Pyko?sll