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Home My WebLink About09-6361JONATHAN R. FRITZ, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. NO. 04 - ?3? 0t v`L`T???t AMANDA J. FRITZ, DIVORCE Defendant 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 Minor 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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. MidPenn Legal Services 213-A North Front Street Harrisburg, PA 17101 Telephone: (800) 932-0356 Date: September 17, 2009 By: I.D. #57365 t V 2320 North Second Street P. O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 F:\Home\KKNIGHT\DOCS\FRITZ.JONATHAN\Complaint. WPD JONATHAN R. FRITZ, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. NO. 0 9- L 3 G l C.(d m-t 7e-4,o,- AMANDA J. FRITZ, DIVORCE Defendant COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Jonathan R. Fritz, by and through his counsel, Cunningham & Chernicoff, P.C., and seeks to obtain a Decree in Divorce from the Defendant, Amanda J. Fritz, and support thereof avers as follows: COUNT I - DIVORCE 1. The Plaintiff, Jonathan R. Fritz ("Plaintiff'), currently resides at 5850 Spring Tree Court, Enola, Cumberland County, Pennsylvania 17025. The Plaintiff is a citizen of the United States of America. Plaintiff's Social Security Number is 198-66- 3067. 2. The Defendant, Amanda J. Fritz, ("Defendant"), currently resides at 5850 Spring Tree, Enola, Cumberland County, Pennsylvania 17025. The Defendant is a citizen of the United States of America. Defendant's Social Security Number is 206-66-0753. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on May 20, 2000 in Cumberland County, Pennsylvania. 6. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that Defendant may have the right to request that the Court the parties to participate in counseling. WHEREFORE, Plaintiff, Jonathan R. Fritz, hereby respectfully requests this Honorable Court to enter a Decree in Divorce from the bars of matrimony. By: Date: September 17, 2009 F:\Home\KKNIGHT\DOCS\FRITZ.JONATHAN?Complaint. WPD Respectfully sytlSmi 'PA Supfeme Court I.D. ##7365 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 Attorneys for Plaintiff, Jonathan R. Fritz VERIFICATION I verify that the statements made in the foregoing 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 unworn falsification to authorities. Date: 2009 JONA R. FRTTZ CJ)I OF T?ir- 2009 SEEP 24 Pl" I v cup. IV 1138.r6 C k=zf- Yt.4.4. ? a23 16 L S" AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ss; COUNTY OF I, JONATHAN R. FRITZ, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to SWORN and Sub ed to Bef re me this /S day of I' 2009 `A .?-,Ay .Al O ARY PUBLIC F:\Homc\KKNIGHT\DOCS\FRITZ.JONATHAN\3301(c) sig forms.wpd WONWEALI?i Of PEf?MIBYL tVTANAL WEAL YVONNE M. WALKER, NoWy Ptd& Prnbroolc Bono, 00*W cc" * CW ffft*n 90W 8ap1?nh 22, =2 OF THE FR 2099 SEP 24 PH I ` 2 '1 aq - 4.31.1 AFFIDAVIT OF NON-N HXFARY SERVICE COMMONWEALTH OF PENNSYLVANIA ss' COUNTY OF The Plaintiff, being duly sworn according to law, deposes and says that he is the Plaintiff in the above captioned matter and that he personally knows that the Defendant is over the age of eighteen (18) years. The Plaintiff further avers that the Defendant is not in the Military Service or in any branch of the Armed Forces of the United States of America or its Allies or otherwise within the provisions of the Soldier's and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. SWORN and Subs to Befo me this day of 2009 C.? TARY PUBLIC JONAVIAN R. FRITZ Iru OF tl , NOTARNL SEAL YVONNE M. WALKER. Nary Poo Prabroolt ft% DSOM 0w* Y!?fbrrnriMou E*84po"at ow FUE r} cu? . aJ 1 7 IL a JONATHAN R. FRITZ, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. NO: 09-6361 AMANDA J. FRITZ, DIVORCE Defendant CERTIFICATE OF SERVICE I, Julieanne Ametrano, Legal Secretary for the law office of Cunningham & Chernicoff, P.C., do hereby certify that a true and correct copy of the Complaint in Divorce was served on October 5, 2009 in the above-captioned matter as evidenced by the Acceptance of Service attached hereto as Exhibit "A" on the following: Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, PA 17043 CUNNINGHAM & CHERNICOFF, P.C. Byf232. ?? ?- ieanne Ametrano 0 North Second Street Box 60457 Harrisburg, PA 17110 Date: October 7, 2009 Telephone: (717) 238-6570 F:\Home\KKNIGHT\DOCS\FRITZ.JONATHAMCOS.Acceptance of Service.wpd EXHIBIT `A' JONATHAN R. FRITZ, Plaintiff V. AMANDA J. FRITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-6361 DIVORCE ACCEPTANCE OF SERVICE I, Samuel L. Andes, Esquire, accept service of the Complaint in Divorce in the above- captioned action on behalf of Amanda J. Fritz and certify that I am authorized to do so in accordance with Pa. R.C.P. 402. By: amuel L. Andes, Esquire 525 North 12th Street Lemoyne, PA 17043 Date: oc F:\fiome\KKNIGHT\DOCS\FRITZ.JONATHAN\Acceptance of Servicempd FiLEG-,?, -r-?- 0F TFF ;" ^"NARY 2 009 0CT --8 1-; 11 : a JONATHAN R. FRITZ, Plaintiff v. AMANDA J. FRITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-6361 CIVIL TERM DIVORCE C ° ~ s ° i ~~ z`~ ~ ~ ~~ - ~~ N o ~ ~.:. c: cn , -x-. ~ ~ , .... .. ~"a -.c ~ AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 24, 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: ~ aO~ ~~' -~~ _ Jonath3 R. Fritz JONATHAN R. FRITZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. ~ (~ c NO: 09-6361 CIVIL TERM C c, AMANDA J. FRITZ, -r3 ~ ' a C1FT; t • DIVORCE z ~~ ~ Defendant `` `~ cNn L'~ ~ ~ ~.- 3c WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY ~'~ == OF A DIVORCE DECREE UNDER $3301(c) OF THE DIVORCE CODE x.. 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 divprced until a Divorce Decree is entered by the Court and that a copy of the peclse will be $ent to me implediately 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: ~ ~~ /U ~~ Jonatha .Fritz ~~ ~,~ C5 ~'. JONATHAN R. FRITZ, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA ~ a v. ~ NO. 09-6361 CIVIL TERM ``' ~:: 3" ~ AMANDA J. FRITZ, ~ i; N ' DIVORCE ~ c:.~ Defendant ~ ~ ~ AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 24, 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: Q ~.. ;' ~' ~ ;:~.nr~ n~~~~~ Amanda J. Fritz JONATHAN R. FRITZ, Plaintiff v. AMANDA J. FRITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA n c r'' ° 0 NO: 09-6361 CIVIL TERM ~~ ~ DIVORCE -;.~ C.. ~~ ~ ~ N cn ~~ '`(S 6 ~~' _. ~, E_ C .. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY ~" OF A DIVORCE DECREE UNDER §3301(c) OF THE llIVORCE 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 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: ~. ~ 7• ~~ ~~~ ~" :~~ Amanda J. Fritz ,`,~i}^ t~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JONATHAN R. FRITZ . V. AMANDA J. FRITZ NO 09-6361 DIVORCE DECREE AND NOW, ~ ~. a (~ , it is ordered and decreed that JONATHAN R. FRITZ plaintiff, and AMANDA J. FRITZ ,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, Nrotnonotary y Sr~ l O ~~-~'--~ CoQ ~rna~ I e..d Ll ~ ~s ~ t o /l~o'r cam. rc~, t ~a -~ -~ p ~ ~} M ~-it0.rtp ~l-Nta f~Y1o~~S. .. - ~J