HomeMy WebLinkAbout10-1142Wayne M. Pecht, Esquire
PA ID No.: 38904
Herbert P. Henderson, II, Esquire
PA ID No.: 56304
Pecht & Associates, PC
1205 Manor Drive
Suite 200
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2010 FED 17 P NJ 1: 2 7
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Mechanicsburg, PA 17055
(717) 691-9808
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
ERIC R. PETERS,
Plaintiff,
V. No. (2 u*,L
MARLA F. PETERS, DIVORCE
Defendant
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 or 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 the Cumberland County Courthouse, 32 South Bedford Street, 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
3S'?2 .oa - LL. P
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Lawyer Referral Service
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
PECHT & ASSOCIATES, PC
Z IcA
Wayne M "Pecht, Esquire
PA ID No.:38904
Herbert P. Henderson, II, Esquire.
PA ID No.: 56304
Pecht & Associates, PC
1205 Manor Drive
Suite 200
Mechanicsburg, PA 17055
(717) 691-9808
Wayne M. Pecht, II, Esquire
PAID No.: 38904
Herbert P. Henderson, II
PA ID no.: 56304
Pecht & Associates, PC
1205 Manor Drive
Suite 200
Mechanicsburg, PA 17055
(717) 691-9808
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION - LAW
ERIC R. PETERS,
Plaintiff,
V.
MARLA F. PETERS,
Defendant
No. l Q l l y ?- c t! `f? ??
DIVORCE
DIVORCE COMPLAINT
UNDER SECTION 3301(c) of the DIVORCE CODE
AND NOW, comes the Plaintiff, ERIC R. PETERS, by and through his attorneys,
Pecht & Associates, PC, and makes the following Complaint in Divorce respectfully
representing as follows:
1. Plaintiff is Eric R. Peters, an adult individual, who currently resides at
6009 Sommerton Drive, Mechanicsburg, Pennsylvania 17050
2. Defendant is Marla F. Peters, an adult individual, who currently resides at
5609 Moreland Court, Mechanicsburg, Pennsylvania 17055.
3. Plaintiff has been a bona fide resident of the Commonwealth of
Pennsylvania for at least six (6) months previous to the filing of this
Complaint.
r
4. The Plaintiff and Defendant were married on July 17, 2004 in Camp Hill,
Pennsylvania.
5. There have been no prior or pending actions of divorce or for annulment
between the parties.
6. The marriage is irretrievably broken; the parties separated July 20, 2009.
7. Plaintiff has been advised of the availability of counseling and the right to
request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a decree
of divorce from the bonds of matrimony existing between Plaintiff and Defendant.
Respectfully submitted,
February , 2010
PE T S O AT , PC
Wayne A. Pecht, Esquire
PA ID No.: 38904
Herbert P. Henderson, II
PAID No. 56304
1205 Manor Drive, Suite 200
Mechanicsburg, PA 17055
(717) 691-9808
2
VERIFICATION
I, Eric R. Peters, the Plaintiff herein, state that the averments
contained in the foregoing pleading are true to the best of my knowledge,
information, and belief. Further, I am aware that any false statements made
herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating
to unsworn falsification to authorities.
February 3 2010
3
Wayne M. Pecht, II, Esquire '~~ ~~ P~~?~~~OTi~Y
PA ID No.: 38904 ZQ~Q MAR -3 PM 2~ S8
Herbert P. Henderson, II
PA ID No.: 56304 CUM~~~+~''~-~ -'-l~~
Pecht & Associates, PC ~E_NNS~~',~ i°.,;~~~~,.
1205 Manor Drive
Suite 200
Mechanicsburg, PA 17055
(717) 691 9808
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION -LAW
ERIC R. PETERS,
Plaintiff,
v No. 10-1142 -Civil Term
MARLA F. PETERS, DIVORCE
Defendant
PROOF OF SERVICE
I hereby swear and affirm that I served a copy of the divorce complaint on Defendant,
Marla F. Peters by US First Class Mail, Certified, Return Receipt Requested (sender's
receipt For 3800 and Return Receipt PS Form 3811) sender's receipts attached hereto on
the 26th day of February 2010.
March 2, 2010
//~~'
Wayn~Vl. Pecht, Esquire
PA ID No.: 38904
PECHT & ASSOCIATES, PC
1205 Manor Drive, Suite 200
Mechanicsburg, PA 17055
(717) 691-9808
Attorney for Plaintiff
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~ Retum Receipt Fee
0 (Endorsement Required)
~ Restricted Delivery Fee
(Endorsement Required)
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~ Total ~
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^ Complete Items, l . 2, and 3. Ado cbmpleRe
item 4 H Restricted Delivery is desired.
^ Print your name and addrt3ss on the reverse
so that we can return the card to you.
^ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
^ Agent
!Verne) ~ C. Date of Delivery
Is delivery address diiferertt frtxn item 1? ^ Yes
If YES, enter delivery address below: ^ No
Ms. Marla F. Peters I
5609 Moreland court
Mechanicsburg, PA 17055 ~cerype
cernned Mail ^ E~rees Mau
O, egistered l7 Rettim Receipt for Merchandise
^ Insured Mail ^ C.O.D.
4. Restricted Delivery? (Extra Fee) ^ Yes
2. Amide Number 7 0 0 8 2 810 0 0 0 2 4 4 7 2 3 516
(iFa-r~-fiom+rMoe yba0 -
P3 Formm 3811, Febnrry 2004 Dotn..nc Rsttm Realpt ,r.M.,sw
_-
CERTIFICATE OF SERVICE
I, Wayne M. Pecht, Esquire, do hereby certify that on this the 2nd day of March
2010, I served a true and correct copy of the foregoing Proof of Service by US First Class
Mail as follows:
Ms. Marla F. Peters
5609 Moreland Court
Mechanicsburg, PA 17055
March 2, 2010
V~/ayne M. Pecht, Esquire
PA ID No.: 38904
Pecht & Associates, PC
1205 Manor Drive
Suite 200
Mechanicsburg, PA 17055
(717) 691-9808
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Eric R. Peters
V.
Marla F. Peters
NO.
10-1142 -Civil Term
DIVORCE DECREE
AND NOW, a ~ w P ~~ ~~~~ , it is ordered and decreed that
Eric R. Peters plaintiff, and
Marla F. Peters ,defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente Cite if any economic claims remain pending. NONE.
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 the Court,
Attest• ~
othonotary
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k~ndLu-son .