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
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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
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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 - .,
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_~, . .
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)
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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)
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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...: _.... ."