Loading...
HomeMy WebLinkAbout09-4676DAVID KREITZER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACT UN - LAW LOIS KREITZER, NO. 09 -CIVIL TERM 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 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, 17013. 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 I FORAMTION 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, 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. DAVID KREITZER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LOIS KREITZER, NO. 09 - CIVIL TERM Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is David Kreitzer, an adult individual, who resides at 190 Alters Rd., Carlisle, Pennsylvania, 17013. 2. Defendant is Lois Kreitzer, an adult individual, who resides at 18 Mountain View Terrace, Newville, Pennsylvania, 17241. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 29, 1989 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as maybe just and appropriate. Respectfully submitted, BAYLEY & MANGAN Date: ILA ock mwc Mark F. Bayley, Esq re 17 West South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff DAVID KREITZER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LOIS KREITZER, NO. 09 - CIVIL TERM Defendant IN DIVORCE VERIFICATION 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 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 7 - /-3 -O Y David Kreitzer, Plaintiff iOF T- 200nj J, u'._ 14 Ai 1 9. L Ofd 4 33,v sti P#? ay3a- oe 0 as-75q Q AUG, 0 r 2009 DAVID KREITZER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LOIS KREITZER, NO. 09 - 4676 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint Under Section 3301(c) of the Divorce Code on behalf of the Defendant, Lois Kreitzer, in the above-captioned action. and I certify that I am authorized to do so. ? -QLG Date B 41 Z Qo6isKretizer, Plaintiff FILE' 4' 1 r THE ARY KC09 i' UG 10 F l 1: G J- I !?.? I ???._+r why David Kreitzer, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION CIVIL ACTION - Divorce Lois Kreitzer, Defendant No. 09-4676 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Lois Kreitzer, the Defendant, in the above captioned matter. August 19, 2009 Rachel Allen Certified Legal Intern onald-Fox Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 OF TIJ2 P",;,'` `!f Nl-)TAPY 2009 AUG 19 AM 11: 5 3 UC j 0 2009 JAMES PETER SCHREIER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2009-4674 CIVIL ACTION LAW LILLIAN MARIE SCHREIER Defendant IN CUSTODY ORDER AND NOW, this 15th day of October, 2009 , the conciliator, having been notified that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. The custody conciliation conference scheduled for October 20, 2009 is canceled. FOR THE COURT, A&4 2U-? / - Dawn S. Sunday, Esquire y? Custody Conciliator t 209 OCT 2C FN 2: 4 6 David Glenn Kreitzer, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Lois A. Kreitzer, Defendant : NO. 09- 4676 CIVIL TERM C ~ ;ry;-~ ~. ~-' ~_.~ AFFIDAVIT OF CONSENT - ~ -~. f=.= ~:ti:> . 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed only ,, g { 2009. 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 of 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 David Glenn Kreitzer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Lois A. Kreitzer, Defendant : NO. 09- 4676 CIVIL TERM h f N C -° c, ~`i WAIVER OF NOTICE OF INTENTION TO REQUEST - ~`~ `~ T{4. -,,;~ ENTRY OF A DIVORCE DECREE UNDER ' : ~ `= &3301(c) OF THE DIVORCE CODE ~ ~ `~ ~ (:__ 3 - ~ ~;~ ~~ ~ ;,:.. `` a ~< 1. I consent to the entry of a fmal 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 aze 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 ~'~l ~ C o ~- ~c~r~ CERTIFICATE OF SERVICE I, Daniel Puskar, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of Defendant's Affidavit of Consent and Waiver of N tice on the following person by first class U.S. Mail, postage prepaid, this Zd day of K 2010: Mark Bayley, Esq. ~ ~; _ Bayley & Mangan c ~;, `-r, 17 West South Street t,, r .~ C_._ ,.T~ -„ Carlisle, PA 17013 ' ~ ~ r- ~~ ~ r-- <' c; .rS ~.~',:.. Ga `i7 ~ ~ ~ _ _ .._. Daniel L. Puskar Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 David Glenn Kreitzer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Lois A. Kreitzer, Defendant NO. 09-4676 AFFIDAVIT OF CONSENT CIVIL TERM w 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on July 14, 2009. 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 of 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 - 3 t9 a.L' 74-ems--- David G. Kreitzer, Plaintiff David Glenn Kreitzer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Lois A. Kreitzer, Defendant : NO. 09 - 4676 CIVIL TERM c WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 3 w 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 herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date 2,30-16 z -- David G. Kreitzer, Plaintiff David G. Kreitzer IN THE COURT OF COMMON. PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Lois A. Kreitzer NO. 09 - 4676 DIVORCE DECREE AND NOW, (JG~ ~G! ~, v201o , it is ordered and decreed that David G. Kreitzer plaintiff, and Lois A. Kreitzer ,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, Attest: J: !~a ~; ~ 1~_ /3u ~1l , Pro onota ~~~ ~ ~ ~. ~ ~~~~ ~ /© `~ `1 L~