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Home My WebLink About09-8005 Jennifer L. Myers N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- &' tTV t? CIVIL TERM Daniel G. Charney Defendant 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 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, Cumberland County Courthouse, 1 Courthouse Square, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 1 w, Jennifer L. Myers Plaintiff V. Daniel G. Charney Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : NO. 09- F 00 Z CIVIL TERM IN DIVORCE COMPLAINT UNDER 43301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Jc?inrl? t?ir ?.. • 01 r s , who currently resides at UYd?, 1CS d 1 :1CQ ?O r ItaWUS (CUrn ba IG nd cf? Cumberland County, Pennsylvania. 2. Defendant is n? 'IL h0a Q A , who currently resides at tc3+l Fairview dr. Cadtde Qa I'7NA 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on deC Iq r,cc\R at 5. The marriage is irretrievably broken, and the parties separated on jan 6 ACCA 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. //Ih Date Plainti , Pro e I, e ?. M(lelS , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unswom falsification to authorities as provided in 18 Pa. C.S. §4904. Date: Plai ff, Pro Assisted by: Tabetha A. Tanner, Esq. Tanner Law Offices 1300 Market St., Suite 6 Lemoyne, PA 17043 (717) 731-8114 ZD@9 ?tpy 18 AN 10: 17 cumapq;- 11-1 ;?6A? Jennifer L. Myers IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.09- ?'vp ? CIVIL TERM Daniel G. Charney Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, _ Jennifer L Myers Plaintiff, to proceed in forma au ris. I, Tabetha A. Tanner, attorney for the party proceeding in forma Russ certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. -1? 'to, G?lfila /'I Tabetha A. Tannerney, Esquire Attorney for Plaintiff Tanner Law Offices 1300 Market St., Suited) O Lemoyne, PA 17043 (717) 731-8114 OF 'M O 209 NOV R 8 AM 10: 17 ?a4°?iY?i..?jJp???"v?IJAVIy? ? Jennifer L. Myers IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- k v 6' CIVIL TERM Daniel G. Charney Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ". 0 of nf P rARr 2069 NOV 18 AM 1017 +' DASYLVAM, Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone (717) 731-8114 Fax (717) 731-8114 JENNIFER L. MYERS, Plaintiff v. DANIEL G. CHARNEY, Defendant ~ AE..E~t--rirr=r^E C F"n~~-~tP?~ `J ~ ~' ?NARY 201Q~~R-9 A~~(#~ 13 i~ ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8005 IN DIVORCE CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To the Prothonotary: Please reinstate the Complaint in the above-referenced matter. A copy of the Complaint is attached hereto. ~~ Datc .3 ' ~~ ~-~ Tabetha A. Tanner, Esquire Attorney for Plaintiff FI~.EC)--% -~iF ~r' i ~,., Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 ttanner@tanner-law.com ZOID JUL - i P~ 12~ U2 CUt~~~ ~ , ~i;Y ~~i`,~ti`~, ~V:a;~l~ JENNIFER L. MYERS, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA v, § NO. 09-8005 CIVIL TERM DANIEL G. CHARNEY, § CIVIL ACTION - IN DIVORCE Defendant § AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on November 18, 2009 and reinstated on March 9, 2010. 2. The marriage of the 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 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. Section 4904 relating to unsworn falsification to authorities. :; ~ Date: '*- ~'~ ~ ` nifer L. Myers, Plaintiff Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 ttanner@tanner-law. com Flier - , , 7~~'_ ' " ~ ~ °' ~_~'~"~RY ZQPQ JAIL - I Pr~i f2: u2 JENNIFER L. MYERS, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA ~, § NO. 09-8005 CIVIL TERM DANIEL G. CHARNEY, § CIVIL ACTION - IN DIVORCE Defendant § WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (~ 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 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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: (1~ ~ Jenni r L. Myers, Plain i f JENNIFER L. MYERS V S. DANIEL G. CHARNEY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 09'8005 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: C`~ z. ~ ,°i Transmit the record, together with the following information to the court for entry of ~ ~tivorc~ C ~,~~ -~, decree: -~= ~ c ~~ _,., ~ --, ~._. ._--~ , 1. Ground for divorce: ,_. ~a Irretrievable breakdown under 3301 (c) ' T. ~3(~-f~~-Bi~v~sa~- (Strike out inapplicable section) C; ~, ~ . 2. Date and manner of service of the complaint: ~_ ~e ~o, zoo. ~ ~.s. ~~ ~.~~. rc ~~~~, ~ ~~~ ~~ 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: by plaintiffJUrie 15, 2010 ; by defendant July 19, 2010 b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs 3301 (d) affidavit upon the respondent opposing party: 4. Related claims pending: ~. 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: b. Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: July 1, 2010 Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: filed contemporaneously with this Praecipe to Transmit Record Attorney for Plaintiff, . ~ TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 -~: r~~t . ~:: , . . G /~~Sv .. y 2~i0 ~E `i~i~ .. _ ~ .. ;r, rr.~. JENNIFER L. MYERS, § Plaintiff § v. § DANIEL G. CHARNEY, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8005 CIVIL TERM CIVIL ACTION - IN DIVORCE CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a copy of the reinstated Complaint in Divorce filed in the above-captioned matter upon the Defendant, Daniel G. Charney, by U.S. first class and certified mail, restricted delivery, return receipt requested, addressed as follows: Mr. Daniel Charney 121 Fairview Drive Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office receipt card dated March 10, 2010. Respectfully submitted, Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 . t ~ ~RestrlCbd2DrNvery b deahsd. ^ Prlnt your rams and address on the r~sverse so tyre cm~ ratan the card to you. ^ This card to the bads of the magpieoe, or on _ rror-c N apace permks. 1. Ardcis ~ to: ~~ !Xall ~ ~~ Uittr l~ ~ Fu<<vTec,~ ~'. Cdr ~; 5~' PA ~~a~3 A. 81pn ~i X ~ ~ addr. B, by (PAnlsd IVrns) of Da4 D. Is dsMrery eddiaae dflb~erR f1art1 K![n 1T ^ Vbb K YE3, aiKer cleMrorY addnDSS bebw: D No ~. or~- o o~~ a. a~nde~,n+asr 7DD9 ODBD ODD1 17DD 7844 prarare-' liars, servks i+3 lam 311, Fr~rrwy ~OOf DaM~lo AArn 1MoMt+t aaoesaE~raa Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (~ 17) 731-8114 ttanner~a tanner-law.com ~ •i ~..r r :, ~:rt..i 2010 6~E.JJ ~~=t r,i i t~, ~rJ ~{ IF.r'.. - ., t'i`ff JENNIFER L. MYERS, § Plaintiff § v. § DANIEL G. CHARNEY, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8005 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on November 18, 2009 and reinstated on March 9, 2010. 2. The marriage of the 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 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. Section 4904 relating to unsworn falsification to authorities. ~ ~b r~ . r~_. ~ l ~ ._ -- - Daniel G. Charney, Defendant Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717)731-8114 ttanner@tanner-law. com T f ~i. a r ! .._ t r~ ~ ~SV` ~.. 210 " ~" _~. , A~io:~ GL ~~:~" ~,-„ JL:NNll~'EK L. MYERS, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA ~• § NO. 09-8005 CIVIL TERM DANIEL G. CHARNEY, § CIVIL ACTION - IN DIVORCE Defendant § 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 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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. _. Date:... ._ ~ ~~ . , ct~ IN THE COURT OF COMMON PLEAS OF JENNIFER L. MYERS :CUMBERLAND COUNTY, PENNSYLVANIA V. :. _ ~ , DANIEL G, CHARN~Y ~ 09-8005 CIVIL TERM NO. DIVORCE DECREE AND NOW, ~~ , it is ordered and decreed that JENNIFER L. MYERS ,plaintiff, and DANIEL G. !/HARNEY ,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 t u , '/~ Attest: J. ~~ D. 8us1.t.~ Proth otary '0 ,,~ ~ -}.o Tanrv.~- t..rh,~