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Home My WebLink About09-1652 46 LINDSEY MEANS-DEIHL Plaintiff V. BRIAN L. DEIHL Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09 - I {off CIVIL TERM CIVIL ACTION - 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 will proceed without you and a decree in divorce or annulment may 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 LINDSEY MEANS-DEIHL Plaintiff V. BRIAN L. DEIHL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - /G Y-7- CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Lindsey Means-Deihl, an adult individual who resides at 146 Kerrs Road, Carlisle, PA 17013; however, at the time, Lindsey is currently in the United States Air Force and is stationed in Spendqlem, Germany. 2. Defendant is Brian L. Deihl, an adult individual who resides at 34 Roxbury Road, Newville, PA 17241; however, at the time Brian L. Deihl is currently in the United States Air Force and is stationed in Spendqlem, Germany. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 22, 2007, in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is a member of the Armed Forces of the United States of America. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since November 26, 2008, and continue to live separate and apart as of the date of this Divorce Complaint. 10. The parties' marriage is irretrievably broken. 11. Property and debts is to be divided and disbursed as agreed by the parties. 12. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully Submitted, TURO LAW OFFICES , 5! a Date Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. ,,-rnor! o q Date z???.aitiiv? w? n..ti..n w /'? S!/?li?..l Lindsey Means-Deihl AF W SE,i ?7 ? r-??r 00 LINDSEY MEANS-DEIHL : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 09 - 1652 CIVIL TERM BRIAN L. DEIHL : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy the Plaintiffs Notice to Defend and Claim Rights under the Divorce Code, by certified mail, return receipt, postage pre-paid on the 23rd day of March 2009, from Carlisle, Pennsylvania, addressed as follows: Brian L. Diehl 34 Roxbury Road Newville, PA 17240 TURO LAW OFFICES Talen R. Waltz, Esqu 28 South Pitt Ste Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff 0._,. 1J ?'.L BFI . LINDSEY MEAN Plaintiff V. BRIAN L. DEIHL Defendant To the Prothonotc- Plez 1652 in order to p D IHL : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 1652 CIVIL TERM CIVIL ACTION - LAWN IN DIVORCE ECIPE TO REINSTATE D NT reinstate the Divorce Complaint filed at the above Caption Doc. 09- ?ct the Sheriffs Service of the Complaint on the Defendant. Respectfully Submitted, len R. Zaltez?,?Ee ire ,Sqi Attorney I.D. # 39789 28 South 'Pitt Street Carlisle, PA 17013 Attorney for Plaintiff FIM-OFFICE 2090 APR _3 AM 10 3Q PE; NSYI3/ANtA /?q - evpw ?4 Gl' l 7,? Sheriffs Office of Cumberland County R Thomas Kline 4 it of 4ulubrEdward L Schorpp Sheri Solicitor J Ronny R Anderson Jody S Smith Chief Deputy OFFICE of rr: s"ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/09/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states April 9, 2009 at 1330 hours this Complaint in Divorce upon defendant Brian L. Diehl is returned not served per request from attorney Galen R. Waltz. SHERIFF COST: $33.42 SO ANSWERS, April 09, 2009 R THOMAS KLIN , SHERIFF 2009-1652 LINDSEY MEANS-DEIHL VS BRIAN L. DEIHL RLED-OF FiC:E OF THE PROTHONOTARY 2009 APR 13 AM 8.5 7 CWH wJNtY Sheriffs Office of Cumberland County R Thomas Kline ';sr of Edward L Schorpp Sheri Solicitor Ronny R Anderson Chief Deputy OPPlZE,;PT?EVIERIrr Jody S Smith Civil Process Sergeant Lindsey Means-Deihl vs. I Case Number Brian L. Deihl 2009-1652 SHERIFF'S RETURN OF SERVICE 06/19/2009 07:34 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 19, 2009, at 1934 hours, he served a true copy of the within Affidavit of Consent and Waiver of Intention to Request Entry of a Divorce Decress Under 3301(C), upon the within named defendant, to wit: Brian L. Deihl, by making known unto Brian L. Deihl personally, at 134 Roxbury Road, Newville, Cumberland County, Pennsylvania, 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $38.80 June 22, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sheriff LINDSEY MEANS-DEIHL Plaintiff V. BRIAN L. DEIHL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 1652 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCECPTANCE OF SERVICE ¦ Complete sterns 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: Brian L. D(;i?hl 134 Roxbury Road Newville, PA 17240 A- Sign are ' X ;> /y 13 Apn ? Addressee B. Received by (Printed Name) C. Date of Delivery D. Is delivery address dnrererlt from Rem 1? ? Yes AIX,XES, errter delivery address below: ? No G1 r' r- ! t mail ? Eegress Mall MZIP ? Registered ? Retum Receipt for Merchandise ? Insured mail ? C.o.D. 4. Restricted Delivery? (Extra Fee) ? yes 2. Article Number 7008 3230 0002 8007 6505 (der Som swvice 196 _ PS Form 3811, February 2004 Dwmtic Return Receipt 102595-02-M-1540 ¦ Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is deshed. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: gfl,rGfpi f` ?r ti I 1 3 L, ?vXb ??r 120ad !V-ew?r (fie P{? -/7d YU A. Somiure 13 Agent ? Addressee B. Received by (Printed Name) C. Date of Delivery D. Isydelivl neat from item 1? ? yes If Gr erftrdN, ress below: ? No tp GO ;. 11 13• Sw^?l" 7 L ?/ ? Express Mall ? Registered ? Retum Receipt for Merchandise ? Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. ArtkleNurnber 7008 3230 0002 8007 6529 Marrow from servtoe Mbe? PS Fort 3811, February 2004 Dorrwtlc Retum Receipt 102595-02-M-1540 ?i OF THE t,?, ir!IY 2009JUL -6 PM 2: ;-4 P CUMr?:.J?. ..%Ui Y lrSr LINDSEY MEANS-DEIHL Plaintiff V. BRIAN L. DEIHL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 1652 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Plaintiffs Notice to Defend and Claim Rights under the Divorce Code filed in the above captioned case upon Brian L. Deihl, by Certified Return Receipt service to: Brian L. Diehl 134 Roxbury Road Newville, PA 17240 I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, 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. TURO LAW OFFICES r ? ? as Date and time of Service (717) 245-9688 Attorney for Plaintiff FiLEE'-o'=.E OF RIE PiP0'-: r";!r?TARY 2009 JUL -6 PM 2: ',, CUMrL : .. °" Ui?I"Y LINDSEY MEANS-DEIHL : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09 - 1652 CIVIL TERM BRIAN L. DEIHL : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 16, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. -(0/9/09 Date o.z?"g Lindsey Means-Deihl FILED 6=. a +.?.? "?'Y OF T H 2009 JU' -6 PM c: ',; I Cum£?^:?'.. LINDSEY MEANS-DEIHL Plaintiff V. BRIAN L. DEIHL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 -1652 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 3301(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 I 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 THE FOREGOING 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. Cp /(D°) Date Lindsey Means-Deihl OF THE i'. l.• l ?.?? 2009 JUL -6 Pr7 2: 1 I umf :,i.. LINDSEY MEANS-DEIHL : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09 - 1652 CIVIL TERM BRIAN L. DEIHL : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 16, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. Z13 /0 9- Date Brian L. Deihl 2009 JUL -6 PIN 2: l LINDSEY MEANS-DEIHL Plaintiff V. BRIAN L. DEIHL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 1652 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(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 c± property, lawyer's fees or expenses if I 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 THE FOREGOING 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. //;,AC)cq Date Brian L. Deihl OF THE 2009 SIJ; -' N"I 2: t; i LINDSEY MEANS-DEIHL Plaintiff V. BRIAN L. DEIHL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 1652 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONORTARY: 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: by Certified Return Receipt on or about April 8, 2009. 3. Date of the execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: By Plaintiff: June 9, 2009 By Defendant: July 3, 2009. 4. Related claims pending: None. 5. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: July 6, 2009 By Defendant: July 6, 20D9 Galen R. Waltl"squi Attorney for Plaintiff 2 0 0 9 4j, ' - 5 Ft", 2: IL i ?I ?. ?. U Lindsey Means-Deihl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Brian L. Deihl NO. 09-1652 DIVORCE DECREE AND NOW, , ~~ , it is ordered and decreed that Lindsey Means-Deihl Brian L. Deihl bonds of matrimony. plaintiff, and 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 Attest: ~ ~i / J. ~. '~ ," .v .x.. ~. ~. `: ,, ~, ,, .. ~. . ~, ;~'', ~v~ ,:a