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Home My WebLink About09-4995ANGELA S. MARTIN, Plaintiff V. SCOTT W. FERTENBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Oq - W995 a-wit-Fix-M 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. A list of marriage counselors is available in the Office of the Prothonotary at: Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 ANGELA S. MARTIN, Plaintiff V. SCOTT W. FERTENBAUGH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. &P- y 9 9S %?..- IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Angela S. Martin, who currently resides at 498 Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania, since March, 2009. 2. Defendant is Scott W. Fertenbaugh, whose current address is unknown. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 18, 2008 at Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Neither Plaintiff nor Defendant is an active member of any of the branches of the United States Armed Services; therefore, neither party enjoys the protections of the Soldiers and Sailors Civil Relief Act of 1940, as amended. 8. 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. 9. Plaintiff requests the court to enter a decree of divorce. 0 /? 4 VCCAID I W I I D thony T. Mc th, E Attorney for P i tiff 407 North Fr t t., First Floor Harrisburg, PA 17101 (717) 238-3686 Supreme Court I.D. 53729 VERIFICATION I, Anthony T. McBeth, am attorney for the Plaintiff in the captioned action. I am verifying the attached document for the Plaintiff in that she is outside the jurisdiction of this Court and her verification cannot be obtained by the time this Complaint needs to be filed. I verify that the facts set forth in the attached document are true and correct to the best of my knowledge, information and belief. I so state subject to the penalties of 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities). e FLEC O =SCE OF THE ?'". ' P:I-I OT AIqY 2009 JUL 23 PM 1: 4 3 4-33S. 50 PO ATTY (x * 858( fo ous3lolo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 09-4995 AFFIDAVIT OF SERVICE Angela S. Martin vs. Scott W. Fertenbaugh Commonwealth of Pennsylvania County of Dauphin So. I, Erin Johnson, a competent adult, being duly sworn according to law, depose and say that at 10:52 AM on 07/30/2009, I served Scott W. Fertenbaugh at Knight Security Systems, 5879 Avis Lane, Harrisburg, PA 17112 in the manner described below: ? Defendant(s) personally served. ? Adult family member with whom said Defendant(s) reside(s). Relationship is ? Adult in charge of Defendant(s) residence who refused to give name and/or relationship. ? Manager/Clerk of place of lodging in which Defendant(s) reside(s). ? Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. ® Other: Served Bernie Bare. Operations Manager of Knight Security Systems a true and correct copy of Notice to Defend and Claim Rights; Complaint Under Section 3301(c) or Section 3301(d) of the Divorce Code issued in the above captioned matter. Description: Sea: Male - Age: 40 - Skin: White - Hair: Black - Height: 6' 02" - Weight: 185 X Sworn to and subscr' ed before me on this Erin ch r. day of ??u 200. ShinkowsTidge Investigations 316 Fawn North Harrisburg, PA 17110 (800) 276-0202 NOT PUBLIC Atty File#: - Our File# 8225 Law Firm: Anthony T. McBeth, Attorney at Law Address: 407 North Front Street, First Floor, Harrisburg, PA, 17101 Telephone: (717) 238-3686 COMMONWEALTH OF PENNSYLVANIA Notarial Seal John F. Shinkowsky, Notary Public Susquehanna Twp., Dauphin County MY Commission Expires Sept. 28, 2010 Member, Penr»ylvrnla acsuc;gt;Qn of Notaries T, ! art 4;?. ';TY ANGELA S. MARTIN, Plaintiff V. SCOTT W. FERTENBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4995 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 23, 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the divorce. 1 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. Wffl-M 2009 Date Scott W. Fertenbaugh, Defendant 2009 NOV --5 Phi 12: 4, 1 ANGELA S. MARTIN, Plaintiff V. SCOTT W. FERTENBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4995 Civil Term IN DIVORCE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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 falsifications to authorities. 3, 2009 Date colt W. Fedenbaugh, Defen nt r?c 'NOTARY 2059 NO`I -5 PIS 12: 41 P .r 41 ?? Ll AN,,!A ANGELA S. MARTIN, Plaintiff V. SCOTT W. FERTENBAUGH, Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4995 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 23, 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the divorce. 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. MTWER 3, 2009 1 MV 1A A? mum Date nge a S. Martin, Plaintiff FILOU .C`S: Ap O THE IJ;1(?T- ,INO;FAPY 2009 NOV -5 PM 12= 4 i CUm'!D p`nNtVS r LW'; \qA ANGELA S. MARTIN, Plaintiff V. SCOTT W. FERTENBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4995 Civil Term IN DIVORCE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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 falsifications to authorities. 1UMCER 3, 2009 N A W 1,k Ix P(\? Date gala . Martin, Plaintiff 2009 NOV -5 Phi 12: 4 ! Pt NV?-?'t'LVANGa ANGELA S. MARTIN, Plaintiff V. SCOTT W. FERTENBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4995 Civil Term IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of complaint: July 30, 2009 via personal service (substantiated by an Affidavit of Service filed of record). 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: November 3, 2009 By Defendant: November 3, 2009 4. Related claims pending: None. 5. Date of Waiver of Notice was filed with the Prothonotary: By Plaintiff: Contemperaneously filed herewith this filing, projected to be November 5, 2009. By Defendant: Contemperaneously filed herewith this filing, projected to be November 5, 2009. I 7A JA ony T. McB sq. Attorney for Plai ti 407 North Fron t., irst Floor Harrisburg, PA 1 1 (717) 238-3686 Supreme Court I.D. # 53729 P PIP.. T, . ;,10TARY 2009 NOV -5 PM 12: 42 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ANGELA S. MARTIN V. SCOTT W.FERTENBAUGH NO. 09995-CIVIL TERM DIVORCE DECREE AND NOW, OW16 J^ it is ordered and decreed that ANGELA S. MARTIN plaintiff, and SCOTT W.FERTENBAUGH 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 th urt, Attest: J. 4-DW Prothonot ry 2" Ato( ? 4 5,0 e