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Home My WebLink About01-6999H. GLENN STEAGER, Plaintiff VS. MYRNA MOOD STEAGER, Defendant )IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA ) : .o. q civil ) . ) 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 bc 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, Cumberland County, 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. The Court bf Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. 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, PA 17013 Telephone: (717) 249-3166 H. GLENN STEAGER, Plaintiff VS. MYRNA MOOD STEAGER, Defendant )IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA ) : NO. ~/-~ .~ Civil Term 2001 ) : ) IN DIVORCE COMPLAINT UNDER SECTION 330t(C) OF THE DIVORCE CODE AND NOW, this 14th day of December, 2001, comes the Plaintiff, H. GLENN STEAGER, by and through his attorneys, the Law Offices of BATURIN & BATURIN, and respectfully represents the following: 1. The Plaintiff is H. GLENN STEAGER, an adult individual, sui juris, with a Social Security Number of 204-28-2210, and who currently resides at 625 Mountain Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is MYRNA MOOD STEAGER, an adult individual, sui juris, with a Social Security Number of 212-54-8043, and who currently resides at 6 Deer Trail, Fairfield, Adams County, Pennsylvania 17320. 3. The Plaintiff has been bona fide resident of the Commonwealth of Penn- sylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 7, 2001, in Fairfield, Adams County, Pennsylvania. 5. There has been no pdor action for divorce or annulment of the marriage between the parties hereto in this or any other jurisdiction. 6. Plaintiff avers that there are no children of the parties under eighteen (18) years of age. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member on active duty of the Armed Forces of the United States of America nor any of its allies. 9. The Plaintiff avers that the grounds upon which this action is based is that the marriage is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Plaintiff does not wish to have any counseling. COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 11. All of the averments in Paragraphs 1 through 10 are incorporated herein as though each was set forth under Count II as in Count I. 12. In the alternative, Plaintiff avers that the Defendant hath offered such indignities to the person of the Plaintiff, the innocent and injured spouse, so as to render his condition intolerable and life burdensome. WHEREFORE, Plaintiff, H. GLENN STEAGER, requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant. Respectfully submitted, BATURIN & BATURIN Date: December 14, 2001 By: Harry~ire Attorney I.D. No. 83006 Attorney for the Plaintiff 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Dec~,~ier 1~, 2001 - ~. G~enn Stea~r ~ z~ o H. GLENN STEAGER, Plaintiff vs. MYRNA MOOD STEAGER, Defendant )IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA ) : NO. 01-6999 Civil Term 2001 ) ) IN DIVORCE CERTIFICATE OF SERVICE I, Harry M. Bamrin, Esquire, of the law firm ofBaturin & Baturin, attorney for the Plaintiff in the above captioned matter, do hereby certify that on December 13, 2001, I deposited in the United States Mail, at the United States Post Office, Harrisburg, Pennsylvania, an article of Certified Mail, Return Receipt Requested, marked "Restricted Delivery", a certified copy of the Complaint in Divome and Notice to Defend and Claim Rights attached thereto, beating Article No. 7000 0520 0022 6167 4059, addressed to: Myma Mood Steager, 6 Deer Trail, Fairfield, PA 17320. The said article of Certified Mail, as shown by the Postal Return Receipt Card was received by the Defendant herein on December 20, 2001, and according to same, was signed by her, to wit: Myma Mood, which card is attached hereto and marked as Exhibit "A", along with the deposit slip dated December 13, 2001, for said article of Certified Mail aforementioned. BATLrRIN & BATURIN By: Harry M. Baturin, Esquire Attorney I.D. 83006 717 North Second Street Harrisburg, PA 17102 (717) 234-2427 (Attorney for Plaintiff) Dated: December 28, 2001 3.20 ~/F~i-ld. PA 17320 · Gomplete items 1, 2, and 3. Also complete I~m 4 if Rest~cted Delivery is desired. · I~int your name and address on the reverse ee that we can return the card,o-you. · Attach this card to the back of the mallpiece, ~nt ~f space permits. A. Rece;ved t B. Date of De~,m~ 0 Agent ~airfleld, PA 17320 7000 0520 0022 6167 40.59 [] Exlxe~s ~ [] Return Re~~~ [] Insured Mail [] C.O.D. EXHIBIT "A" H. GLENN STEAGER, Plaintiff VS. MYRNA MOOD STEAGER, Defendant )IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA ) : NO. 01-6999 Civil Term 2001 ) : ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 13, 2001. 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 in 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: April 4, 2002 ,(SEAL) H. GLENN STEAGER, Plaintiff VS. MYRNA MOOD STEAGER, Defendant )IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA ) : NO. 01-6999 Civil Term 2001 ) ) IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lIN-DER SECTION 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 and 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. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE TO THE PENALTIES OF 18 PA. C.S. SECTION 4904 TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: April 4, 2002 H. Gi~nn Steager - ~-- 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW H. GLENN STEAGER, Plaintiff VS. MYRNA MOOD STEAGER, Defendant NO. 01-6999 Action in Divorce DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 13, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of service of the Complaint on Deceml~r 20, 2001 3. I consent to the entry of a final decree of divorce, and have signed a waiver 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 Myr~a~Vlo[d Stea~er, D~fend~'nt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW H. GLENN STEAGER, Plaintiff VS. MYRNA MOOD STEAGER, Defendant NO. 01-6999 Action 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 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 tree 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: Myr/n~ M~od Stea~er, Def'enda~'t H. ~ STEAGER, (SS#204-28-2210) Plaintiff VS. MYRNA MOOD STEAGER,(sB#212_54_8043): Defendant IN THE COURT Of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 01-6999 2001 CIVIL TERM PRAEClPE 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 §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the complaint: ~laint was served on December 20, 2001, by Certified Mail-Return Receipt Requested "Restricted Delivery" Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff Na~ch 27, 2002 ; by defendant April 4, 2002 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: No 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: Date: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Aoril B. 2002 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: BATURIN & BATURIN Harry M. ~or~Dy, f o¢~ j~t'e6~ ~ ~'t/ April 5, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. Plaintiff Versus MYRNA MOOD STEAGER, Defendant No. 01-6999 ~{~/2001 DECREE IN DIVORCE ~..~.~i~.~..%.~ ................ ~1~ .~.0.0.~.., it is ordered and AND NOW decreed that ....~.-..G~ .~...~.?~...~?. .............................. plaintiff, and .....~.~0D. $~-4~-~ ................................... 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: No claims raised By The C,oprt/