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HomeMy WebLinkAbout09-19551.~ ~ ~ IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, v. Todd Joseph Trautz .DEFENDANT. CIVIL ACTION-LAW DIVORCE NO: O9- ~~s~ C~vl~ NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 YOU CHILD(REN). WHEN THE GROUNDS FOR DIVORCE ARE 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 (um~~,y~. C.o. Ca.~c=~lna,~ . Gn.~ I~.e,,•s ,crFi ~ (~ r~; ~ , PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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. `/1``- `LAWYERS REFERRAL SERVICE WIVE \f~..~ ~o~n~u~~~s5or~«-ha~• Telephone: ~~~ - 2-~ .. ?,~~ .~~ J ca-Lynn Trautz, Plaintiff Pro Se 13 Concord Place Hatboro, PA 19040 215-802-4411 Notice to Defend and Claim Rights Page 1 of 1 r t ., IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, CIVIL ACTION-LAW v. Todd Joseph Trautz DEFENDANT. COMPLAINT IN DIVORCE Count I-Divorce Plaintiff, Jessica Lynn Trautz, pro se, respectfully represents: DIVORCE NO: ©q-~~s`s ~~ll 1. Plaintiff, Jessica Lynn Trautz, currently resides at 13 Concord Place, Hatboro, PA 19040. 2. Defendant, Todd Joseph Trautz, currently resides at 2905 Wynchester Drive Apt 511, Camp Hill, PA 17011. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on 05/26/2008, in Bryn Athyn, PA. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 6. The parties have no minor or legally dependent children. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, fees and costs. 9. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 10. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. Complaint in Divorce Page 1 of 2 r a 4~ WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code. J s' a Lynn Trautz, Plaintiff Pro Se VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. J ss ca Lynn Trautz, Plain iff Pro Se Date: 3J2Cs ~ ~`~ Complaint in Divorce Page 2 of 2 r IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, v. Todd Joseph Trautz DEFENDANT. CIVIL ACTION-LAW DIVORCE NO: 6 9- l~ 5 Spa,,; l AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) } SS: COUNTY OF ~ C/ ~ ) Before me, the subscriber, a Notary Public in and for said Commonwealth and County, personally appeared Jessica Lynn Trautz, who being duly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his/her knowledge, information, and belief, and that he/she is authorized to make this Affidavit. ~---- j - J ca Lynn rautz, Plaintiff Pro Se 13 Concord Place Hatboro, PA 19040 215-802-4411 o and day ~v NOTARIAL SEAL public DONNA LYNNE ROMANO, Notary Warminster Twp:. Bucks Co~a~mn Affidavit 20~l Page 1 of 1 .. . n N c' :.x C` c~ f a.a~ ^ 7 ray g-,~ , ~:~. ~~' r _r - ~ Cnl :,:1J _ I ~7 ~ ~ n ~ - } ~ ~ (/ ~~ j ....C IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, v. CIVIL ACTION-LAW DIVORCE Todd Joseph Trautz DEFENDANT. NO: QC - ~~ ~ S ~; v~ l PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and 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 SECTION 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 Irroperty, 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 are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: S / ~ /~_ r---- J ~ a Lynn Trautz, Plaintiff I'ro Se Plaintiff s Affidavit of Consent Page 1 of 1 ~ er +.h s ZQ09 >.3~'.. 17 ~'~' ~ ~ 3 °-tir-„I ~ :~~,i~r IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, CIVIL ACTION-LAW v. DIVORCE Todd Joseph Trautz : DEFENDANT. NO: ~C =/~5~ ~~v~ DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 3 / 30 / 2oa 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and 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 SECTION 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 are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: 4 / z ~ l z~y ~~~ Todd Joseph Trautz, efendant Pro Se Defendant's Affidavit of Consent Page 1 of 1 ~°It.~vGJ '~YI~ ~.' t `" ~ ~ r 2u09 ~'iJ~., I ? Fs'''r ~ IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, v. CIVIL ACTION-LAW DIVORCE Todd Joseph Trautz DEFENDANT. NO: ~~ ~ q S ~ cw: l MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this y+" day of M , 20 ° y , between PLAINTIFF, Jessica Lynn Trautz, residing at 13 Concor Place, Hatboro, PA 19040, and Defendant, Todd Joseph Trautz, residing at 2905 Wynchester Drive Apt 511, Camp Hill, PA 1701 l . WITNESSETH WHEREAS, the parties were married on OS/26/2~08; WHEREAS, the parties filed for 3301(c) Divorce on 3 /3~/aaoq ; WHEREAS, the parties hereto desire to settle their property rights; WHEREAS, both parties agree to relinquish any and all claims which either may have against any property now owned or belonging to the other or which may hereinafter be acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants, and agreements contained herein; and, WHEREAS, both parties each have had an opportunity to seek the benefit of competent and independent legal advice by separate counsel. NOW, THEREFORE, the parties, intending to be legally bound, do covenant, and agree as follows: 1. INCORPORATION OF RECITALS The recitals on Page 1 of this Agreement are incorporated herein as if set forth in full. Each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 2. APPLICABLE LAW Marital Property Settlement Agreement Page 1 of 4 This agreement shall be construed under the laws of the Commonv~~ealth of Pennsylvania. 3. PROPERTY TO BE RETAINED BY WIFE. Husband and Wife agree that, unless otherwise indicated in this Agreement, the Wife shall keep all of her personal clothing and effects; and that the following property shall also be retained by Wife: none 4. PROPERTY TO BE RETAINED BY HUSBAND. Husband and Wife agree that, unless otherwise indicated in this Agreement, the Husband shall keep all of his personal clothing and effects; and that the following property shall also be retained by Husband: none 5. DEBTS TO BE PAID BY WIFE. Husband and Wife agree that the Wife shall pay the following debts and will not at any time hold the Husband responsible for them: none 6. DEBTS TO BE PAID BY HUSBAND. Husband and Wife agree that the Husband shall pay the following debts and will not at any time hold the Wife responsible for them: none 7. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL MARITAL RIGHTS. Each of the parties hereto release the other from subsequent claims for alimony, alimony pendente lite, or spousal support, except as set forth as follows: No spousal maintenance shall be awarded to either party. 8. JOINT DEBTS. Husband and Wife warrant and certify to each other that there are no individual or joint marital obligations outstanding, other than those listed in paragraphs 5 and 6. Marital Property Settlement Agreement Page 2 of 4 9. DIVORCE. Husband and Wife agree that the marriage is irretrievably broken and will proceed with said Divorce under 23 Pa. C.A. Section 3301(c). 10. NAME CHANGE. The Wife requests the court to restore her prior name, to wit: Jessica Lynn Stanley. 11. TAX ADVICE. The transfers set forth herein may result in income, inheritance, estate, and other tax consequences to the parties. The parties specifically acknowledge that no attorney involved in the negotiating or drafting of this Agreement has provided any tax advice Marital Property Settlement Agreement Page 3 of 4 regarding the dispositions contained herein. The parties have been advised to seek separate tax counsel concerning the Divorce distributions. IN WITNESS HEREOF, the parties have hereunto set their hands and seals the day and year first written above. ~_ es ica Lynn Trautz, PLAINTIFF On this ~ day of ~y1~~{ 20~ before me, a Notary Public, the undersigned officer, personally appeared Jessica Lynn Trautz, Plaintiff, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he or she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARY PUBLIC NO'1'A1tIAL SEAL 3owr !1. nroomer, Not*ey Fc~blk City o[ Me~baB, C~baiud rAr7' My oa~on expina Febraiq l!, 7013 ~~ Todd Joseph Trautz, DE ANT On this ~ ~{' day of ! ~' ' ~~ 20~, before me, a Notary Public, the undersigned officer, personally appeared Todd Joseph Trautz, Defendant, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he or she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARY PUBLIC NoTAxrAL seal. Sn~n s. Bnoon~ rtotars F~blic City of ~ Cnmba~oa d..t~ iVJy commission ~ Febtmq 1!,2913 Marital Property Settlement Agreement Page 4 of 4 f~IL.L.i_,.._~ - _ ~~ ~ •,T! ~~( ~G ~"L . ~,~,; 2C~'i .;'~~L 9 7 ~''~ ~ r c i`' is v; s .._`~1 ~''~ _.. ,:; IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, : CIVIL ACTIC>N-LAW v. DIVORCE Todd Joseph Trautz DEFENDANT. NO: X'i" ~~i SS C ~~t PLAINTIFF'S ACKNOWLEDGMENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ~ /~ }~/ c~ I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlement Agreement documentation. .~~. Jes ica Lynn rautz, Plaintiff Pro Se On this Q~' day of rn ~ y 20 ~ 9, before me, a Notary Public, the undersigned officer, personally appeared Jessica Lynn Trautz, Plaintiff, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS W(H~EREOF, I hereunto set my hand and official seal. J° NOTARY PUBLIC riarAw~t. sue. 3neeo B. Brnome~ Nopn~ P~6rc Clly d M~abmr~. C~mbai~ed Ca~q My oommbrion acpiea 14~'OL1 Plaintiff s Acknowledgment Page 1 of 1 f=i~;:ir ,~a=: ,yl~~ dl`i~ '..~~i't'~I -. ~, I; F i .c IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jessica Lynn Trautz PLAINTIFF, .CIVIL ACTION-LAW v. : DIVORCE Todd Joseph Trautz DEFENDANT. NO: d~-~~SS Ci~~` DEFENDANT'S ACKNOWLEDGMENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 3 / 3.~ /~oo~_. I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlement Agreement documentation. Todd Joseph Trautz, Defen ant Pro Se On this ~ ~' day of M ~~ 20 ~g , before me, a Notary Public, the undersigned officer, personally appeared Todd Joseph Trautz, Defendant, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. v NOTARY PUBLIC rtarnitw, sue. Smm B. BraomeG Notes Pie pq of lYtodmdcab~. Gr^b~el~d ~! ~~~~~ Defendant's Acknowledgment Page 1 of 1 i. _t. ~~ ~-tt~. Z~~9 JJ~. i 7 ~`~'': ~ ~ 4' ,' ~'r_~i (,~u _. _ ~~ ~,~~ .Rt+~;