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Home My WebLink About09-2635F:\F1LES\C1ients\9437 Diehl\9437.8.dcom Created: 9120/04 0:06PM Revised: 4/16/09 9:55AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MICHAEL C. DIEHL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09- CIVIL ACTION - LAW BROOKE E. DIEHL, Defendant 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 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. 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 Telephone (717) 249-3166 MICHAEL C. DIEHL, Plaintiff V. BROOKE E. DIEHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- -2 G -35' a :1 Te,, CIVIL ACTION - LAW IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. Plaintiff is Michael C. Diehl, who currently resides at 4 East High Street, Suite B, Carlisle, PA 17013. 2. Defendant is Brooke E. Diehl, who currently resides at 7 Joseph Drive, Boiling Springs, PA 17007. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 21, 1999. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage between Plaintiff and Defendant. MARTSON LAW OFFICES Date: April , 2009 By / Jenni . Spears, Esquire 10 Eas igh Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 1 0 • VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Michael C. Diehl AR 5 3 3 8'..s v PA a- H1 cfi.?0 9 7 ,? 21/ 3t?/ ` a F:\FILES\Chents\9437 Dieh1\9437.8.aos Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MICHAEL C. DIEHL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-2635 CIVIL ACTION - LAW BROOKE E. DIEHL, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Brooke Diehl at 26 Netherby Lane, Carlisle, PA 17015 on May 4, 2009, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Brooke Diehl"and dated May 11, 2009. Je if L. Spears, Esquire Sworn to and subscribed before me this 15 day of May, 2009. ??Ag Av?? Not ublic COMMONWEALTH OF PENNSYLVANIA Shelly Brooks, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 5, 2009 Member, Pennsylvania Association of Notaries ¦ Complete items 1, 2, aril 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 beck of the mailplece, or on the front If space permits. I .. fArdticip Addreess?ed to: ' ` ill z???:y' -`- DA-7bis A Signature X O Agent ? Addressee B. eceived by (A ted Name) C. of Delivery D, is delivery address different from Item 1? 0 Yes If YES, enter delivery address below: 0 No 3 Type (( Certified Matt 0 F?µxeas Mall 0 Registered 0 Retum Receipt for MerdwKilse 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? Pft Fee) es Artl?eeNumber 7003 3110 0004 5772 8512 (Trraufsfer f m swVkO tabol Ps Form 3811, Febamy 2004 Darmsuc ftelurn it?2ssso3 M a5aa GFRTIF IF( (Domestic Mail C rU r ` uu u: uu Ln Postage $ ° CertW Fee 0 ° = (End ) M Restricted Delivery Fee (Endorsement Required) r9 m Total Postage 8 Fees $ m Q o aADBartYa ??D ?st-E p P ?`' P. 'o U He $4. 4 w CO it. 22 ?F,?O1 2009 MAY 19 Pty 2: 4 4 MICHAEL C. DIEHL, ) Plaintiff ) vs. ) BROOKE E. DIEHL, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2635 CIVIL ACTION -LAW IN DIVORCE ~ °- `-ii ~~ -,~ ~,_- ~ __ _- : ~'~ '~~ = ~, NOTICE TO RESUME PRIOR SURNAME ~, f _ ra ..2 i .y '-`~ J '1 NOTICE IS HEREBY GIVEN that BROOKE ELIZABETH DIEHL, Defendant in the above matter, [select one by marking "x": prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of BROOKE ELIZABETH DAGEN, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: ~ ` ~ - l rJ ROOKE ELIZABETH DIEHL Signature of name be' resumed BROOKE ELIZABETH DAGEN COMMONWEALTH OF PENNSYLVANIA ) ( SS.. COUNTY OF CUMBERLAND ) On the J day of IYt ~+~ , 2010, before me, the undersigned officer, personally appeared BROOKE ELIZABETH DIEHL, known to me (or satisfactorily proven) to be the person whose name is signed to the within Notice to Resume Prior Surname and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~~ ~ 7L y ~ ~= 3~~ ~ c ~~a~ ~ota00~N+~tb4VWEALTH OF PENNSYLVANI NOTARIAL SEAL DEBORAH A. RAILING CARLISLE BOROUGH, CUMBERLAND CO