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HomeMy WebLinkAbout09-1951Charles R. Beidel, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Linda L. Beidel, Defendant : NO. 09- CIVIL TERM 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Charles R. Beidel, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Linda L. Beidel, Defendant : NO. 09- CIVIL TERM DIVORCE COMPLAINT The plaintiff, Charles R. Beidel, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa C S 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Charles R. Beidel, who currently resides at 238 A Street, Carlisle, Cumberland County, PA 17013, since June 2008. 2. 3. 4. 5. 6. 7. Defendant is Linda L. Beidel, who currently resides at 28 Regency Woods North, Carlisle, Cumberland County, PA 17015, since November 1995. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on November 5, 1995 at Shiremanstown, Cumberland County, Pennsylvania. Plaintiff and Defendant have lived separate and apart since March 1999. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Defendant is not a member of the armed forces. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Sarah Rosko Certified Legal Intern e 76? ROBE INS THOMAS PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date 3 -0?l - 65 Plainti 4sCh R. Beidel (?, i.) lC7 ^? Charles R. Beidel, Plaintiff V. Linda L. Beidel, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 09- r9Sl CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Charles R. Beidel, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 3/0q-7/0? Respectfully submitted, Sarah Rosko Certified Legal Intern ROBE INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 -5 Ta Charles R. Beidel : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Linda L. Beidel Defendant : NO. 09 - 115??? CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about March 1999, and have continued to live separate and apart for a period of at least 2 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 unsworn falsification to authorities. Date 3-;27-d9 Plaintiff Char . Beidel '?) r.,,? " f _ +=_? =a ,_`, ??-cs --.. ?+ 7 1 ? -. _Ij ? ?3 ? I ' ?.I r?` , .'a ?., ? .: . ;'t ? ?i C?"_ -a7 Charles R. Beidel, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Linda L. Beidel, Defendant NO. 09 - 1951 CIVIL TERM CERTIFICATE OF SERVICE I, Sarah Rosko, Certified Legal Intern, Family Law Clinic, hereby certify that I served a s true and correct copy of the Divorce Complaint on Linda L. Beidel, residing at 625 Bosler Avenue, Lemoyne, PA 17043 by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Linda L. Beidel, on the 17th day of April 2009 as evidenced by the attached green card. 0 C3 am L-A E-' 0 O 0 0 L_j 0" L-4 Q^ Ul 0 -n Sarah Rosko Certified Legal Intern ROBE INS THOMAS . PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 OF THE 2009 APR 23 b!l 10: 5J' Charles R. Beidel, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA. V. CIVIL ACTION-LAW DIVORCE Linda L. Beidel, Defendant NO. 09 - 1951 CIVIL TERM AFFIDAVIT OF SERVICE I, Sarah Rosko, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Notice of Intention to Request Entry of § 3301(d) Divorce Decree and Defendant's Counter-Affidavit under § 3301(d) of the Divorce Code on Linda L. Beidel, residing at 625 Bosler Avenue, Lemoyne, PA 17043 by depositing a copy of the same in the United States mail, first class on May, 14 2009. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. 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: Sarah Rosko Certified Legal Intern FILFCs JF THE 2009 Hil'i i` 14 PI' 12: 2? Charles R. Beidel, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Linda L. Beidel, Defendant NO. 09 - 1951 CIVIL TERM AMENDED CERTIFICATE OF SERVICE I, Sarah Rosko, Certified Legal Intern, Family Law Clinic, hereby amend the Certificate of Service dated April 23, 2009. I certify that I served a true and correct copy of the Divorce Complaint as well as a copy of the Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code on Linda L. Beidel, residing at 625 Bosler Avenue, Lemoyne, PA 17043, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Linda L. Beidel, on the 17t` day of April 2009 as evidenced by the green card attached to the Certificate of Service dated April 23, 2009. a( Date: 22 _j?2d?aA Sarah Rosko Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 2339 f IIt Y 28 Al'i I I. 1 D Charles R. Beidel, Plaintiff V. Linda L. Beidel, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW : DIVORCE NO. 09 - 1951 CIVIL TERM 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 and separation for two years under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: United States mail, certified, restricted delivery, return receipt requested, postage prepaid addressed to Linda L. Beidel at 625 Bosler Avenue, Lemoyne, PA 17043 on April 17, 2009. 3. (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: March 27, 2009. (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on March 27, 2009 and served April 17, 2009. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: Service by first class mail on May 14, 2009. Date -6 26-20 -?- Sarah Rosko Certified Legal Intern ?T Robert . Rains, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire Megan Riesmeyer, Esquire Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Charles R. Beidel, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Linda L. Beidel, Defendant NO. 09 - 1951 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after June 5, 2009, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. FlLE"*I WGE OF THE PRr,7F.DNOTARY 2009 JUN -5 Aid 10* 4 6 ?J:Ui?TY PMSYLVAN Charles R. Beidel IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Linda L. Beidel NO. 09 - 1951 DIVORCE DECREE AND NOW, 71 .ter7 ` to , )_a o!J , it is ordered and decreed that Charles R. Beidel plaintiff, and Linda L. Beidel , 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 the Court, ,?