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HomeMy WebLinkAbout09-6185CHARLES R. STEUBER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. r??? ?l vl 1 -TJ I`/yj JOANNE BRICKLEY, formerly JOANNE STEUBER., Defendant IN DIVORCE NOTICE TO DEFEND 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 the Cumberland County Court House,' Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 or 800-990-9108 FLOWER ? LEVDSAY V15BEKAr uw 26 West High Street Carlisle, PA SAIDIS, FLOWER &,LTNDSAY ry Carol J. LinZ7 6 :r6quire Attorney Id. ,446 3 26 West Hi treet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff CHARLES R. STEUBER, Plaintiff V. JOANNE BRICKLEY, formerly JOANNE STEUBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07- G Ps' _ ew• IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Charles R. Steuber, an adult individual, residing at 151 Ken-Lin SAIDIS, LEND5Y 26 West High Street Carlisle, PA Drive, Carlisle, Cumberland County, Pennsylvania 17015. 2. The Defendant is Joanne Brickley, an adult individual, residing at 518 Mill Street, Williamston, Michigan 48895. 3. The Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 28, 1973 in Darby, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in his/heir favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, FLOWER & LINDSAY Carol J. Lindsay, quire 1 Attorney Id. 44606 1 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and I correct. I understand that false statements herein are made subject to the penalties of 1$ Pa. C.S. §4904, relating to unsworn falsifications to authorities. Charl R. Steub r Date: C? ///Q7 FLOWER & LINDSAY 26 West High Street Carlisle, PA ? Fll.L-t} .(') PCE C 'Vp ,-r, t)TARY 2009 SEP ! PH 3: 13 ftnnt r+ f ?t t,?li(j II I, 1! r ? 1 CHARLES R. STEUBER, Plaintiff V. JOANNE BRICKLEY, formerly JOANNE STEUBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 4I, &lgS- IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in 1976 or 1977 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. §49104 relating to unsworn falsification to authorities. Dated: 6r(11(01 ytt - / / - J7" 00 /,-' Charles R. Ste er + FLOWER ? LINDSAY ATIOMIS•AT Uw 26 West High Street Carlisle, PA OF THE Pp(-)FL', 'VOTARY 2004 SEE PM 3: 14 CL?,f CHARLES R. STEUBER, Plaintiff V. JOANNE BRICKLEY, formerly JOANNE STEUBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0-6#5- 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 to the lbest of my FLOWER & LINDSAY ATIOWILIMAT LAW 26 West High Street Carlisle, PA knowledge, information and belief. 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: Charle R. Steube OF TH ?'f?T?t?,C'NARY k 2099 SEP I I PM 3, ! Ty