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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 F1 T""C ??Tl 1 1 2010 FED 17 P NJ 1: 2 7 ?vI J; _ 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 m ti N ti ~ Retum Receipt Fee 0 (Endorsement Required) ~ Restricted Delivery Fee (Endorsement Required) O ~ Total ~ e~ IU O O r~ ^ 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 (~ •~~ • l o IUo•~; c.~. mom lec~ -~o `~~. k~ndLu-son .