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Home My WebLink About09-6571FELICITY M. ERNI, Plaintiff ) VS. ) CSABA STEPHEN ERNI, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 61- O'5yl 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 foregoing 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 in 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 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 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 Telephone: (717) 249-3166 FELICITY M. ERNI, Plaintiff VS. CSABA STEPHEN ERNI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. FELICITY M. ERNI, ) Plaintiff ) VS. ) CSABA STEPHEN ERNI, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. U 1- G 5"71 ez;?f -rte,,, IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, FELICITY M. ERNI, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is FELICITY M. ERNI, an adult individual who currently resides at 3814 Candlelight Drive in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is CSABA STEPHEN ERNI, an adult individual who currently resides at 3814 Candlelight Drive in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 7 October 2000 in Latrobe, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. 1- WI) 0 C-Qx--4:h& 4 -MbIl A 490 Sa 1 L. es Attorney for Plaintiff Supreme Court ID # 17225 525 North 126' Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unworn j falsification to authorities). Date: l ?' 0 1 FELICITY M. EFNI OF 7HE PROT ,ONOTAFty 2909 OCT -2 AM 11: 16 f EV,S i ' V&%i C i OA ?3? S0 ?? R31?b N/k/ YVYUS FELICITY M. ERNI, ) PLAINTIFF ) VS. ) CSABA STEPHEN ERNI, ) DEFENDANT ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-6571 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, CSABA STEPHEN ERNI, hereby accept service of the original Complaint in Divorce and acknowledge receipt of a copy of the Complaint. Date: y- CSABA STEPHEN E I i D-J ;'ikri_ OF- THE P- TARY 2009 OCT 15 i C'i 2. 14 S r ?. ?@ G FELICITY M. ERNI, Plaintiff ) VS. ) CSABA STEPHEN ERNI, ) Defendant ) TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 09-6571 Civil Term IN DIVORCE PRAECIPE Please withdraw the Complaint in Divorce previously filed by the Plaintiff in the above matter. Date: \ . zvo amuel L. des Attorney for Plaintiff Supreme Court ID # 17225 525 North 12' Street P.O. Box 168 Lemoyne, Pa 17043 (717) 761-5361 The undersigned, Plaintiff in the above matter, hereby consents to the withdrawal of her Complaint in Divorce. ,r Date: A .cam- Felicity M. Erni