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HomeMy WebLinkAbout01-6869LISA ANN ANDREWS, : Plaintiff : : V. ; CHARLES STANLEY ANDREWS,: Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW 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. 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 240-6200 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siquientes, usted tiene veinte (20) dias de plazo al partir de lag fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abagado y archival en la corte en forma excrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si ustted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABAGADO INMEDIATAMENTE. SI NO TIENE ABAGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCURENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 240-6200 LISA ANN ANDREWS, Plaintiff V CHARLES STANLEY ANDREWS,: Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 I-Co (.0q ^CT ON- LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF TIlE DIVORCE CODE 5. 6. 7. 8. Plaintiff is Lisa Ann Andrews who has resided at 32 Nathan Drive, Enola, Cumberland County, Pennsylvania, since June 1997. Defendant is Charles Stanley Andrews who has resided at 11 East Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania, since November 1, 2001. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on April 24, 1987. There have been no prior actions of divorce or for annulment between the parties. Neither of the parties in this action is presently a member of the Armed Forces. The Plaintiffand Defendant are both citizens of the United States. Plaintiffhas been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. There are two minor children children bom of the marriage to wit Charles A. Andrews, age 11 years, and Alexander L. Andrews, age 5 years. 10. The Plaintiff avers that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court enter a decree of divorce. Respectfully submitted, By: HOFFMAN LONG LLP , SQUIRE Sup. Ct. I.D. #79152 105 North Front Street P.O. Box 11475 Harrisburg, Pa. 17108-1475 (717)233-1112 EMILY LONG HOFFMAN, ESQUIRE Sup. Ct. I.D. # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108-1475 (717)233-1112 AFFIDAVIT Lisa Ann Andrews, being duly sworn according to law, deposes and says that the facts contained in the foregoing Complaint in Divorce are m~e and correct to the best of her knowledge, information and belief. Lisa ~nn Andrews LISA ANN ANDREWS, Plaintiff CHARLES STANLEY ANDREWS, Defendant IN THE COURT OF COMMON PLEAS Coo, 6~r~,~',l~- COUNTY, PENNSYLVANIA NO. 01-6869 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 4, 2001. 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. Section 4904 relating to unsworn falsification to authorities. Date: LISA ANN ANDREWS Social Security # ;2,05' 85510 I LISA ANN ANDREWS, Plaintiff CHARLES STANLEY ANDREWS, Defendant IN THE COURT OF COMMON PLEAS Cu~O~'~0. COUNTY, PENNSYLVANIA NO. 01-6869 CIVIL CIVIL ACTION - LAW IN 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 ifI 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 thi~ 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: LISA ANN ANDREWS LISA ANN ANDREWS, Plaintiff CHARLES STANLEY ANDREWS, Defendant IN THE COURT OF COMMON PLEAS Co,',, ~_.~.~1~ COUNTY, PENNSYLVANIA NO. 01-6869 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT "~: m '< ~d A Complaint in Divorce under Section 3301(c) of the Divorce Code was on December 4, 2001. 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. Section 4904 relating to unsworn falsification to authorities. Date: Social Security # lq?- gr~/- 71g / F 85510 1 LISA ANN ANDREWS, Plaintiff CHARLES STANLEY ANDREWS, Defendant IN THE COURT OF COMMON PLEAS ¢& t~fi~ COUNTY, PENNSYLVANIA NO. 01-6869 CIVIL CIVIL ACTION - LAW IN 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 ifI 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. ! understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: CHARLES STANLEY(_~T)REWS LISA ANN ANDREWS, Plaintiff CHARLES STANLEY ANDREWS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6869 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Emily Long Hoffman, hereby certify that I served a true and correct copy of the divorce complaint filed in the above-m~tte~ on the defendant on December 13 2001 as ~r~'~w.~l below. ~ 4if R~rk='ted Delivery is desired. · P~ your name and address on the reverse ao fl~ we can m~rn the c~d to you.. · ~ ~is c~d to ~e back ~ ~e m~piece, o~ on tho fl'ont if ~o~co permits. 1. Affic~ ~d~d ~: Charles S. Andrews 11 East Simpson Street N~chanicsburg PA 17055 [] Addreaeee addmssd~m~om'~l? [] Yes , acldm~* be~)w: [] No Form ~11, M~ 2001 [] Reg~temd [] R~um Rece~ for Merch~ [] In.md Mail [] C.O.D. 4. i~ed D~ive~ ~ Fee) ~J~Yes ~ ~ ~1-M-1424 Sup. Ct. ID #66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 Attorney for Plaintiff (717)233-1112 Date: 3/29/2002 CERTIFICATE OF SERVICE I hereby certify that a tree and correct copy of the attached document was served on the person below on this day by First Class U.S. Mail addressed as follows: Mr. Charles S. Andrews 11 East Simpson Street Mechanicsburg, PA 17055 Respectfully submitted, By: Emily Long Hoffman, Esquire Sup. Ct. ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 4/2/02 DORINE A. BOLLINGER, Plaintiff D. TIMOTHY BOLLINGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-5368 CIVIL ACTION-LAW DIVORCE DEFENDANT'S RESPONSE TO PETITION TO ENFORCE PROPERTY SETTLEMENT AGREEMENT AND NOW, comes Defendant, D. Timothy Bollinger, by and through his attorneys, Hoffrnan Long LLP, and hereby responds to Plaintiff's Petition as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. The Agreement speaks for itself. 5. Admitted. 6. Denied. The payment has been paid. 7. Denied. It is denied that Plaintiff's counsel provided Defendant's counsel with her support calculations on January 16, 2002. 8. Admitted. 9. The Agreement speaks for itself. WHEREFORE, Defendant has paid the amount due under the agreement and Plaintiffhas scheduled a support conference in addition Defendant demands proof in the fees to prepare this matter as the fees are excessive. Respectfully submitted, Emily Long Hoffman Sup. Ct. I.D. # 66307 P.O. Box 11475 105 N. Front Street Harrisburg, PA 17108-1475 717-233-1112 Date: 4/2/2002 CERTIFICATE OF SERVICE I hereby certify that a tree and correct copy of the attached document was served on the person below on this day by First Class U.S. Mail addressed as follows: Sandra L. Meilton, Esquire Tucker, Arensberg & Swartz P.O. Box 889 Harrisburg, PA 17108-0889 Respectfully submitted, Emiiy'Lo~offman, Esquire Sup. Ct. ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 4/2/2002 LISA ANN ANDREWS, Plaintiff CHARLES STANLEY ANDREWS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6869 CIVIL ACTION - LAW 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 the Complaint: Defendant accepted service of the complaint on 12/13/01. 3. (a) Date of execution of the Plaintiffs Affidavit of Consent: 3/21/02; Defendant's Affidavit of Consent: 3/22/02. 4. Related claims pending: None. 5. Date of filing of Plaintiff's Waiver of Notice: 4/2/2002. Date of filing of efendant s Wmver of Notxce: 4/2/2002. Respectfully submitted, Emily L~~ng' o~ffm[ ~,X~E squire Sup. Ct. ID # 66307 105 North Front Street Harrisburg, PA 17108 (717)233-1112 Attorney for Plaintiff Date: 3/29/2002 CERTIFICATE OF SERVICE I hereby certify that a tree and correct copy of the attached document was served on the person below on this day by First Class U.S. Mail addressed as follows: Mr. Charles S. Andrews 11 East Simpson Street Mechanicsburg, PA 17055 Respectfully submitted, By: ~~-q 1,3 -('~ Emily Long Hoffman, Esquire Sup. Ct. ID # 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 (717)233-1112 Date: 4/2/02 DIVORCE INFORMATION SHEET PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1,2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DOCKET NUMBER: DATE OF MARRIAGE: IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. ......... LISA..ANN__ANDR£~S ..................................... ..................................... Pla-inti-f.f ........................ Versus CHARLES STANLEY ANDREWS, Defendant No. ~.~85~ ................. 19 CIVIL ACTION - LAW IN DIVORCE DECREE IN AND NOW,. I ]~ .2002 it is ordered and decreed that .... .A.N.N..A.N.D.R.E.W.5 ................... plaintiff, and CHARLES STANLEY ANDREWS .............................................. defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered;