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HomeMy WebLinkAbout09-1502 Sandra L. Meilton, ] Daley Zucker Meilt 1029 Scenery Drive Harrisburg, PA 171 (717) 657-4795 H. DANIEL V. ONEIDA H. You have be pages, you must take you and a decree of d entered against you I money or property or When the request marriage ( the Cumberland C IF YOU DO FEES OR EXPENSI THE RIGHT TO CL) YOU SHO A LAWYER OR BELOW TO FIND Miner & Gingrich, LLC com III, : IN THE COURT OF COMMON PLE S iff CUMBERLAND COUNTY PENNS V : NO. 0 - CIVIL TERM CIVIL ACTION -LAW [ant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS sued in court. If you wish to defend against the claims t forth in jr follow ?mpt action. You are warned that if you fail to do so, the c e may pr ed wi th, ?rce or annulment may be entered against you by the court. A judgmeay also any other claim or relief requested in these papers by the laintiff. u may Ii ier rights important to you, including custody or visitation your chin. ?d for the divorce is indignities or irretrievable breakdown of the marri e, you n ;ling. A list of marriage counselors is available in the Offi4e of the Pr thonotar? Court House, Carlisle, Pennsylvania. OT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, ? AWYE'. BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU Y LO 4 ANY OF THEM. TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU DO OT HA 1NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE S T FOR C WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 or 1-800-990-9108 andra L. Meilton, No. 2551 Attorney for Plaintiff DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 at 'S Sandra L. Meilton, Es Daley Zucker Meilton 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 H. DANIEL V. ONEIDA H. BEIGH, Miner & Gingrich, LLC III, : IN THE COURT OF COMMON PLE iff CUMBERLAND COUNTY PENNS NO. 0q- 1,Yo Z CIVIL TERM CIVIL ACTION -LAW t : IN DIVORCE OF THE DIVORCE CODE COUNT I: 1. Plainti is H. Daniel Beigh, III, an adult individual who is sW juris a 2300 Fox Fire Circle, echanicsburg, Cumberland County, Pennsylvania. 2. Defen t is Oneida H. Beigh, an adult individual who is sui ?uris and Woodmyre Lane, E la, Cumberland County, Pennsylvania. The presen? whereal Defendant, Oneida H. Beigh, to the knowledge of the Plaintiff, is the same. 3. Both aintiff and Defendant have been bona fide residents ' the Coi of Pennsylvania for at east six (6) months immediately previous to the filing f this Co 4. The P 'ntiff and Defendant were married on August 26, 976, in V resides s at 1 of le Pennsylvania. 5. There ave been no prior actions of divorce or for annulment tween the 6. Plainti has been advised of the availability of counseling and the right that the Court require a parties to participate in counseling. 7. The its Allies. 8. The (a) Or, in the alternative, (b) two years since 1999, is not a member of the Armed Services of the United States or anof .aintiff avers that the grounds on which the action is ba?ed are: that the marriage is irretrievably broken. that the parties hereto have lived separate and apart for a and that the marriage is irretrievably broken. COUNT II: UNDER THE DIVORCE CODE lofat h 9. Plaint're and Defendant are the joint owners as tenants by the entire following real estate hich is subject to equitable distribution by this court: 2300 Fox Fire Cirlce, Mechanicsburg, Cumberland County, PA 10. Plait furniture and house distribution by this 11. Plain investments, insura subject to equitable and Defendant are the owners of various items of persor furnishings acquired during their marriage which a e subject and Defendant are the owners of various motor vehicles, b account policies and retirement benefits acquired during the?r marriage which a ribution by this court. WHEREFO , Plaintiff requests the Court to enter a Decree: A. Dissol ing the marriage between Plaintiff and Defendant; B. Equita ly distributing all property owned by the parties hereto; and i of t1 C. For s ch further relief as the Court may determine equitable and just. li I DALEY ZUCKER WILT N MINER & GINGRICH, LLC I, By: Sandra L. Meil I.D. No. 32551 1029 Scenery Drive Harrisburg, PA 17109 717-657-4795 Attorneys for Plaintiff I verify that false statements he unworn he statements made in this Complaint are true and in are made subject to the penalties of 18 Pa.C.S. to authorities. ZZ17l/ H. Daniel Beigh, III, Dated:.9 - /Q - ©q -ct. I un erstand Omt ion 490 , relatinj to ?4 4? ?? ? ;, -'1.. 6? ? ", r (n. r 9J ? ? '? ?? cz? a ? ?, ? ? °,,,. ,? ?. ?L f ?w Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 H. DANIEL BEIGH, III, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-1502 CIVIL TERM 2009 ONEIDA H. BEIGH, CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF DAUPHIN ) AND NOW, this 24th day of March, 2009, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Gloria M. Rine, paralegal to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on March 11, 2009, she mailed a certified copy of a Complaint in Divorce to Oneida H. Beigh, 21 Woodmyre Lane, Enola, PA 17025 by certified mail no. 7004 2890 0001 3910 5083, restricted delivery, return receipt requested, and the same was received by her on March 23, 2009, as indicated by the return receipt card which is attached hereto. / r Gloria M. Rine Sworn to and subscribed before me this 24th day of March, 2009. NOTARK MAL PATRICK A. PATTON, No" Public Lower Paxton UP., fto in CW* Mfr CwwJsaon Expi?es June 20, 20 0 (SEAL) l r CONO l t" t 2. wad & A%* ai rI s p t p w mo wA ademw?antM nwwm IiMa 4 0 d O riadw4?d. RdWommy soowwomn AM tMandfoyow M,I#Ad't&mdfa*AU* off* IN** ar an #m *m* M gwoa pwnft Da. Af, MS. Q1EILIA H.. BEIGH 21 WOr M LANE IA PA 178--- 1 gy o 13 9"m MW o ftwm ftrO R..YR.1. i 2 7004 HOW 0001 3910 5083 Pd FMn *M t sollmMwftow m .a (--FR-TIFIFD MAIL REC-L-il- 0 m OFFICIAL Q v- G m Poshpe s a C3 CerMW Fae p t-G -„ C3 Ham- C3 ru 11 ?Q 9 N lbtel Postaps & Fees In . ONEMA H BEI r` :, ':. mss'Si"i,3 °pA _.... ---------------------------- EMIA, 17025 mo ? l t? ..a rJl FILED-OFFICE OF THE PROTPONO.T?,,R-y, Quint'na M. Laudermilch, Esquire DEC -? P? [? , Dale Zucker Meilton Miner & Gingrich, LLC • 20 1029 Scenery Drive Harrisburg, PA 17109 CUMBERLAND RLAND COUNTY (717) 657-4795 PENNSYLVANIA tlaudennilchna.dzmmglaw.com H. DANIEL BEIGH, III, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-1502 CIVIL TERM ONEIDA H. BEIGH, CIVIL ACTION -LAW Defendant : IN DIVORCE PRAECIPE TO WITHDRAW ECONOMIC CLAIMS Prothonotary: Plaintiff hereby withdraws Count II for Equitable Distribution of Marital Property under the Divorce Code, which was filed on March 11, 2009 in the above-captioned matter. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC < l ' Date: r1 / l1 D By: tina M. Laudermilch, Esquire Supreme Court I.D. # 94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff Quintina M. Laudermilch, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 FILED-OFFICE OF THE PROTHONOTARY 2010 DEC -3 PM 4: 20 C H. DANIEL BEIGH, III, IWVWT&MIOF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-1502 CIVIL TERM 2009 ONEIDA H. BEIGH, CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT I . A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on March 11, 2009. 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 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. §4904 relating to unworn falsification to authorities. L?ry? Date: l/ v? f -- /D t H. Daniel Beigh, III, Plaintiff O THONOTARY CF THE PR 2010 DEC -3 PM 4: 21 SMIGEL, ANDERSON & SACKS, LLP /( CUMBERLAND COUNTY Susan E. Good, Esquire ID #93295 '" PENNSYLVANIA 4431 North Front Street, 3 Fir. Harrisburg, PA 17110-1778 (717) 234-2401 sgood(gsasllpcol Attorney for Defendant H. DANIEL BEIGH, 111, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-1502 Civil Term ONEIDA H. BEIGH, DEFENDANT CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 11, 2009. 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 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: //"-'w q • l 6 FILED-OFFICE, OF THE PROTHONOTARY 2010 DEC -3 Ph 4: 21 Susan E.,G od, Esquire 1D #932grUMBERLAND COUNTY 4431 North Front Street, 3" Mr. PENNSYLVANIA Harrisburg, PA 17110-1778 (717) 234-2401 sgoodL"asllp.com Attorney for Defendant H. DANIEL BEIGH, 111, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-1502 Civil Term ONEIDA H. BEIGH, DEFENDANT CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND §3301(d) 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:/ -C;?1 1/D 1 CFILED-OFFICOF' TNT' PROTHONOTAp Quintina M. Laudermilch, Esquire Daley Zucker Meilton Miner & Gingrich, LLC DEC 1029 Scenery Drive ?3 P' 2 Harrisburg, PA 17109UfBtRi.1FG COUNT" (717) 657-4795 PSY?-?'?H?t daudermilch(a,dzmmglaw.com H. DANIEL BEIGH, III, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-1502 CIVIL TERM ONEIDA H. BEIGH, CIVIL ACTION -LAW Defendant : 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: A true and correct certified copy of the Divorce Complaint was served on Defendant, Oneida H. Beigh, via Certified Mail, Restricted Delivery, having been received by her on March 23, 2009. An Affidavit of Service was filed on March 24, 2010. 3. As required by Section 3301(c) of the Divorce code, Plaintiff executed his Affidavit of Consent on November 29, 2010 and Defendant executed her Affidavit of Consent on November 29, 2010. The Affidavits are being filed contemporaneously herewith. 4. Related claims pending: None. S 5. As required by Section 3301(c) of the Divorce Code, Plaintiff executed his Waiver of Notice of Intention to Request Entry of Divorce Decree on November 29, 2010 and Defendant executed her Waiver of Notice of Intention to Request Entry of Divorce Decree on November 29, 2010. The Waivers of Notice are being filed contemporaneously herewith. Respectfully submitted, Date: DALEY ZUCKER MEILTON MINER & GINGRICH, LLC By: G - Quintina M. Laudermilch, Esquire Supreme Court I.D. #94664 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorneys for Plaintiff H. DANIEL BEIGH, III, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ONEIDA H. BEIGH, DIVORCE DECREE AND NOW, O e.G em?A Bf 'WO , it is ordered and decreed that H. DANIEL BEIGH, III, plaintiff, and ONEIDA H. BEIGH, , 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. NO. 09-1502 CIVIL TERM By the Court, 1~ Attest: -? • ? ? J. q/t CeaA . (S P7 A?4,t a "ccJv?t L?, COP Y - A,4Y S° Gmek