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Home My WebLink About10-0718 f l?'•I? ? r ?C )[. ?r 2 13 JAH 19 Fk t ic..3a V ?i1?Y s 7•? 74, CV x,ji-. HARRY L. COLESTOCK, IN THE COURT of COMMON PLEAS Plaintiff of CUMBERLAND COUNTY, PENNSYLVANIA VS. No. _ 71g:? KAREN M. FRITZ, CIVIL ACTION - DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend yourself 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 in divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including visitation of your children. When the grounds for divorce are indignities or irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the office of the Court Administrator, Fourth Floor, Cumberland County Courthouse, Carlisle, PA. 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 A 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 COURT ADMINISTRATOR'S OFFICE Fourth Floor, Cumberland County Courthouse One Courthouse Square Carlisle, PA. 17013 (717) 240-6200 .352 • ? P°? "'"'? -7q,od 3e' 9?-? f ..rt HARRY L. COLESTOCK, IN THE COURT of COMMON PLEAS Plaintiff of CUMBERLAND COUNTY, PENNSYLVANIA V. No. j ? q L U? KAREN M. FRITZ. Defendant CIVIL ACTION at LAW IN DIVORCE Complaint in Divorce k AND NOW thi2 -day of January, 2010 comes Harry L. Colestock, Plaintiff above-named, by and through his attorney, John M. Glace, Esquire, and respectfully presents this Complaint in Divorce, as follows: 1. Plaintiff HARRY L. COLESTOCK is an adult individual who currently resides at 142 Fifteenth Street, Unit K, New Cumberland, Cumberland, Pennsylvania 2. Defendant KAREN M. FRITZ is an adult individual who presently resides at 664 Elliot Road, Lewisberry, York County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months preceding the filing of this Amended Complaint. 4. The parties were married on June 18, 1999 in Hershey. Dauphin County, Pennsylvania. 5. There has been no prior action for Divorce or Annulment instituted by either party in this or any other jurisdiction.. 6. No children were born during this marriage nor to the parties as biological parents prior to their above described marriage. a -d 7. Neither party is a member of the armed services of the United States. 8. The parties have been advised of the availability of counseling and the right to request the Court to require the parties to participate in counseling. COUNT ONE Divorce Pursuant to Section 3301(c) of the Divorce Code 9. Paragraphs one (1) through eight (8) are incorporated herein and made part hereof as if set forth in full. 10. The marriage is irretrievably broken. WHEREFORE Plaintiff LEVI J. BAUMGARDNER respectfully prays this Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT TWO Equitable Distribution 11. Paragraphs one (1) through Ten (10) are incorporated herein and made part hereof as if set forth in full. 12. Plaintiff and Defendant, during the course of their marriage, have acquired various items of marital property, both real and personal, which are subject to equitable distribution pursuant to the Divorce Code. 13. Plaintiff and Defendant, during the course of their marriage, have purchased and/or acquired, by credit various items of marital property and/or become indebted as joint parties collateralized by marital assets and these debts are not yet paid in full or satisfied and are subject to equitable distribution pursuant to the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property and debt as of the date of the filing of this Divorce Complaint. i •r' l WHEREFORE Plaintiff HARRY L. COLESTOCK respectfully requests this Honorable Court to divide equitably all marital property and debt. Respectfully submitted: The Law Offices of John M. Glace John M. fFace, Esquire 132- 1144 Walnut Street H . urg, PA 17101-1612 (717)238- 5 51 Telefax (717)238-6929 S me CT ID: 23933 Counsel for Plaintiff VERIFICATION I verify that the statements made m the foregoing Complaint for Divorce are true and correct to the best of my understanding and belief. I understand that false statements herein are made subject to the penalties provided by 18 Pa. CSA, Section 4904, relating to unworn falsification to authorities. Date: UT 0 Harry L. olestock SHERIFF'S OFFICE OF CUMBERLAND CONIINXE ()F THE PROTH MICTARY Ronny R Anderson Sheriff 4u?IV of u?p6rrfrry? 1010 MAR -4 PM 1: 36 Jody S Smith, Chief Deputy ,pry, Edward L Schorpp PENNSYLVA."1111A Solicitor OMCE OF THE S"ER1FF Harry L Colestock vs. Karen M. Fritz Case Number 2010-718 SHERIFF'S RETURN OF SERVICE 02/01/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Karen M. Fritz, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint and Notice according to law. 02/17/2010 York County Return: And now February 17, 2010 at 1709 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Karen M. Fritz by making known unto herself personally, at 664 Elliot Road, Lewisberry, PA 17339 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.44 March 03, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ;c) Goun':ySulte Shenff, 'ieleosoft. InC. ,,r TF.,,- ~ °..r ~r~Y _. ,~ , 2DIQ J~'! 2~ r1 i~~ 55 r'~' ; ~:,,',jf IN THE COURT of COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA HARRY L. COLESTOCK, Plaintiff No. 2010 - 718 CNII, v. KAREN M. FRITZ, Defendant CIVIL ACTION -DIVORCE Order AND NOW this l ~ day o , 2010 ,after due consideration of the attached Motion to Compel, a judicial confe nce is hereby scheduled at .!~ : ~M on 2010 at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania and all parties are hereby dire d. ~. ~J Distribution ~hn M. Glace, Esquire 132-134 Walnut Street, Harrisburg, PA 17101 men Fritz, 664 Elliot Road, Lewisberry, PA 7339 Court Administrator ., aL~cs~cL. r ~J ~ ~~_ •~ ~ e. s rn.~ ~ ~, ~~~v f LC7 FlL?4D-??'w -rr1gY HARRY L. COLESTOCK, Plaintiff V. KAREN M. FRITZ, Defendant M&? CSYLVANIA IN THE COURT of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 2010-718 CIVIL ACTION - DIVORCE Praecipe of Withdrawal of Motion to Compel To: Prothonotary of Said Court: Please withdraw Plaintiffs Motion to Compel and cancel the Hearing relative that Motion presently scheduled for August 31, 2010 at 4:00 PM before the Honorable, Edward Guido of this Honorable Court. Dated: P Respectfully submitted. The Law Office of John M. Glace Joh# . Glace, Esquire 13 - Walnut Street H urg, PA 17101-1612 ( ) 238-5515 Supreme Ct. ID: 23933 Attorney for Plaintiff/Petitioner FILED-OFFICE G' 1,'. it l IF H 040 i A % ?010 SEP 29 P11 2.2 0 HARRY L. COLESTOCK, IN the COUI 0M(RtAMX WN of Plaintiff CUMBERLANDFtOM#;' PENNSYLVANIA V. No. 2010 - 718 CIVIL TERM KAREN M. FRITZ, Defendant CIVIL ACTION - DIVORCE Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301 (c) of the Divorce Code 1. I consent to the entry of a final Decree in 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 that Decree is filed with the Prothonotary. I verify that the statements herein are made 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 unworn falsification to authorities. Z?- /p Date larry L. olestock HARRY L. COLESTOCK Plaintiff V. KAREN M. FRITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-718 CIVIL TERM CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT C/7 i ` nJ :;:t om 1. A Complaint in Divorce under Section 3301(c) on January 29, 2010, erved o C February 17, 2010, by Sheriff's service. :~'=?;?, -?•-' ?,,.,? 2. The marriage of the Plaintiff and Defendant is irretrievably broken and *et)?, 90 days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce without notice. 4. I understand that may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. I verify that the statements made herein 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. Dated: ? - Z S - ( I A. zzz A4 KAREN M. FRITZ, Defend t DWLMDOWFritz.Karen. M.Affidavit of Consent.wpd HARRY L. COLESTOCK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-718 CIVIL TERM KAREN M. FRITZ, CIVIL ACTION - DIVORCE `- Defendant WAIVER OF NOTICE OF INTENTION 4 r ?? - TO REQUEST ENTRY OF A DIVORCE DECREE ° rJ `, UNDER § 3301(c) OF THE DIVORCE CODE , v 1. I consent to the entry of a Final Decree in 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 herein are made 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. Dated: ' Z S r0 KAREN M. FRITZ, Defe ant HARRY L. COLESTOCK, IN THE COURT of COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA, V. No. 2010 - 718 KAREN M. FRITZ, CIVIL ACTION - DIVORCE c? Defendant °a rra r" F= PRAECIPE to TRANSMIT RECORD - TO THE PROTHONOTARY: Dt c Kindly transmit the record, together with the following information to thelga t P M for entry of a Divorce Decree: r:1. Ground for Divorce: Irretrievable Breakdown under Section 3301(c) of the Divorce Code 2. Date and Manner of Service of the Complaint: Sheriffs Service on February 17, 2010. 3. Date of Execution of Affidavit of Consent required pursuant to Section 3301(c) of the Divorce Code: a. By Plaintiff: September 25, 2010. b. By Defendant: September 25, 2010. 4. Related Claims Pending: None 5. Date of Plaintiff's Waiver of Notice in Section 3301(c) Divorce filing with Prothonotary: September 25, 2010. 6. Date of Defendant's Waiver of Notice in Section 3301(c) Divorce filing with Prothonotary: September 25, 2010. Respectfully Submitted, THE LAW OFFI of JOHN M. GLACE Glace, Esquire S p e Court I.D. 23933 132-134 W treet, Harrisburg PA 17101-1630 (717) 238-5515 Attorney for Plaintiff I^ ILLD-0F F IC 7010 SinP 29 PEii 2: CLO ,.;. _ i.? .``,BEit..rti??u 1, ? 0U HARRY L. COLESTOCK IN THE COURT of COMMON PLEAS of Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. KAREN M. FRITZ, No. 2010 - 718 CIVIL TERM Defendant CIVIL ACTION - DIVORCE Affidavit of Consent 1. A Complaint in Divorce was filed under Section 3301 (c) on January 29, 2010, and served on February 17, 2010 by Sheriffs Service. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice 4. 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. 5. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. I verify that the statements made herein 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 unworn falsification to authorities. Date arry L olestock Harry L. Colestock V. Karen M. Fritz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010 - 718 DIVORCE DECREE ~~~~ ~- 1: SSs~.,vt AND NOW, Q~~yltl"'t ~ I'~ , it is ordered and decreed that Harry L. Colestock plaintiff, and Karen M. 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 , Court, ,,, Attest: J. Prot onota ~ ~;d b. t3u.el/ -Y J~ 1 D ~ ~ • I D ~ec~ ~ @o~- n1 a•~ ,~ ~ ~ ~~~~ I D -g• /o