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HomeMy WebLinkAbout09-34500 Benjamin D. Andreozzi ATTORNEY FOR PLAINTIFF P.O. BOX 534 CAMP HILL, PA 17001 717-926-1192 Ben@midstatelaw.com S. NOSS, THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY PENNSYLVANIA VS. NO: 0 Y. 3 ydb ? -774..- JEFFREY L. NOSS Defendant DIVORCE 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 annuhmnt 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 at: 1 Courthouse Square Suite 100 Carlisle, PA 17013 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, 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 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 Benjamin D. Andreozzi P.O. BOX 554 CAMP HILL, PA 17001 717-926-1192 Ben@midstatelaw.com JENNIFER S. NOSS, Plaintiff, VS. ATTORNEY FOR PLAINTIFF THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO: 0,7- 3 IIso C? ?-- JEFFREY L. NOSS Defendant. DIVORCE AND NOW, comes the Plaintiff, Jennifer Noss, by her attorney, and seeks Final Decree in Divorce alleging: 1. The Plaintiff is Jennifer Noss, who resides at 6842 Wertzville Road, Enola, Pennsylvania, 17025. 2. The Defendant is Jeffrey Noss„ who resides at 205 Birch Lane, Carlisle, Pennsylvania, 17102. 3. The Plaintiff and the Defendant have been residents of the Commonwealth of Pennsylvania for six (6) months prior to the filing of this Complaint. 4.- The Plaintiff and the Defendant were married on August 28, 1999, in Mechanicsburg, Pennsylvania. 5. There have not been any prior actions by Plaintiff or Defendant for divorce or annulment of this marriage in this or any other jurisdiction. 6. The Plaintiff further avers that the marriage between the parties is irretrievably broken. 7. The Plaintiff has been advised that she is entitled to marriage counseling and has the right to request the same in this proceeding. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a Final Decree in Divorce. Date: May `? , 2009 By: D. P.O. 554 CampIlill, PA 17001 (717) 926-1192 Counsel for Plaintiff I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. §4904, relating to unworn falsification to authorities. ;4-11-09 Date: Jennifer Noss (k) (=J',_s 0D9 ri!,`' 26 P' - ' 3 * 33 c.i,-- 13c.o d??.., a1 a 5L 7l Benjamin D. Andreozzi ATTORNEY FOR PLAINTIFF P.O. BOX 554 CAMP HILL, PA 17001 717-926-1192 Ben@midstatelaw.com JENNIFER S. NOSS, THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO: 09-3450 CIVIL TERM JEFFREY L. NOSS DIVORCE Defendant. ACCEPTANCE OF SERVICE I, Jeffrey L. Noss, certify that Iaccept/accepted service of the Complaint in the above captioned matter on the following date: ~~ Je ey Noss c~/3~~~ ~? Int.- .j _~; ~f.. ~Lliv' ~ a~ Benjamin D. Andreozzi P.O. BOX 554 CAMP HILL, PA 17001 717-926-1192 Ben@midstatelaw.com ATTORNEY FOR PLAINTIFF JENNIFER S. NOSS, THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO: 09-3450 JEFFREY L. NOSS DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on ,~~ 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 in 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: b ~~~ ~ ®-'.1-~~ (Jennifer S. Noss, PLAINTIFF) . i - ., '.Fi 7 Ic~ G~ tiJ s i r _~, . . Benjamin D. Andreozzi P.O. BOX 554 CAMP HILL, PA 17001 717-926-1192 Ben@midstatelaw.com JENNIFER S. NOSS, Plaintiff, vs. ATTORNEY FOR PLAINTIFF THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO: 09-3450 JEFFREY L. NOSS Defendant. DIVORCE 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Date: (Jennifer S. Noss, PLAINTIFF) ~.,. ,. .., .,, ~ v; ~. . r~~,.~ 7 _., ~ . JENNIFER S. NOSS, THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO: 09-3450 JEFFREY L. NOSS DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on S J a.~ ~ 6~ 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 in 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: ~~-~i-o9 (Jeffrey L. Noss, DEFENDANT) !-i' I .. ,._ .- - ~~ J~ ((~'s1 ?•~+y? `t (ti :., yrs. ~' °" ~..' ~_:. THE COURT OF COMMON PLEAS JENNIFER S. NOSS, OF CUMBERLAND COUNTY Plaintiff, PENNSYLVANIA vs. ~ NO: 09-3450 JEFFREY L. NOSS ~ DIVORCE Defendant. 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of l8 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Date: JO.- ~ ~_(,~ y (Jeffrey L. Noss, DEFENDANT) :i...: _.... ."