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HomeMy WebLinkAbout10-1199 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY..) G PENNSYLVANIA CIVIL ACTION-LAW Chandra Justine Eisenhuth rv M, ?' Plaintiff Pro Se, vs NO ?k ,Q f i . . 0 Samuel Robert Eisenhuth Defendant Pro Se. 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 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 Cumberland County Courthouse, S. Hanover St., Carlisle, PA 17013. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYERS REFERRAL SERVICE Telephone: The Court of 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 jr 55d. 00? Pl?? Cwsh Notice to Defend and Claim Rights Pagel of 2 AO- oL 3,7 84 0 disabled individuals having business before the Court, please contact the Court Administrator at (717) 240-6195. All arrangements must bemade at least 72 hours prior to any hearing or business before the Court. Notice to Defend and Claim Rights Page 2 of 2 f 1 +? • D n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Chandra Justine Eisenhuth 304 April Drive Camp Hill, PA 17011 : Plaintiff Pro Se, vs. NO. Samuel Robert Eisenhuth 304 April Drive Camp Hill, PA 17011 Defendant Pro Se. : COMPLAINT IN DIVORCE UNDER §3301(c) OF THE DOMESTIC RELATIONS CODE Count I-Divorce Plaintiff, Chandra Justine Eisenhuth, pro se, respectfully represents: 1. Plaintiff, Chandra Justine Eisenhuth, currently resides at 304 April Drive, Camp Hill, PA 17011. 2. Defendant, Samuel Robert Eisenhuth, currently resides at 304 April Drive, Camp Hill, PA 17011. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have hasihave been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on 04/06/2002, in Boiling Springs, PA. 5. The parties were separated on 12/18/2009. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 7. The following children were born to the parties: Name Age Sex Date of Birth Residence Alexander Thomas Eisenhuth 5 male 10/25/2004 Mother Complaint in Divorce Page 1 of 2 4 8. There have been no prior actions of divorce or for annulment between the parties. 9. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, spousal support, child support, custody, visitation, fees and costs. 10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 11. Plaintiff waives the right to request that the court require the parties to participate in counseling. 12. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. If a divorce based on consent cannot be granted, Plaintiff further alleges in the alternative that the marriage is irretrievably broken and the parties will have been separated for two years or more at the time of final disposition of this case. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code. Chandra Justine Eisenhuth, Plainti VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn f7andra o authorities ustin e Eisenhuth, Plaintiff Pro Se Date: 2 22 Complaint in Divorce Page 2 of 2 HEREBY CERTIFY THAT ON THE ` 0 F ____JLUl, J / TIYfA TI ?..r .I ?? WERE BY ME t ? Aarriage IN ACCORDANCE WITH LICENSE ISSUED BY MARY C. LEWIS, CLERK OF THE COURT OF COMMON PLEAS, ORPHANS' COURT DIVISION OF CUMBERLAND COUNTY, PENNSYLVANIA. (Original CIlErtifuAte No. VOL. 2002 • RABsi Dis r umai • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION-LAW w ;. (= CS j Chandra Justine Eisenhuth rn ?-- , Plaintiff Pro Se, C n -s -- r vs. NO. c3 :ZF3 Samuel Robert Eisenhuth `•'? Defendant Pro Se. ? AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in ivorce under Section 3301(c) f the ] 'vorce Code was filed on 712 S_/7 C 16 and served on 0 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 the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 P Section 4904 relat?to unsworn falsification to authorities. i Date: ho I C) Samuel Robert Eisenhuth, Defendant Pro Se Defendant's Affidavit of Consent Page 1 of 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , CIVIL ACTION-LAW Chandra Justine Eisenhuth Plaintiff Pro Se, n CC _ c_ --s C ::j r7 1 _U 0 vs. NO. Q .? w - C:p Samuel Robert Eisenhuth ?. Defendant Pro Se. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 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. 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 subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: bo Samuel Robert Eisenhuth, Defendant Defendant's Waiver of Notice of Intention Page I of I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTS PENNSYLVANIA CIVIL ACTION-LAW Chandra Justine Eisenhuth -?? Plaintiff Pro Se, vs. NO. D 41- z " o Samuel Robert Eisenhuth Defendant Pro Se. AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in ivorce under Section 3301(c of the ivorce Code was filed on Q and served on r 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 the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: alt? 3 J o Chandra Justine Eisenhuth, Plaintiff Pro S Plaintiff's Affidavit of Consent Page I of I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Chandra Justine Eisenhuth Plaintiff Pro Se, ? ? 3 .- T vs. NO. w ?r m ?..? - Samuel Robert Eisenhuth C Defendant Pro Se. %.0 r WAIVER OF NOTICE OF INTENTION TO REQUEST C3 ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I . 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. 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 subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ?-- ?, Date: AC ,-'3 0 Chandra Justine Eisenhuth, Plaintiff Plaintiff s Waiver of Notice of Intention Page I of 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Chandra Justine Eisenhuth Plaintiff Pro Se, vs. G C NO. c -? Samuel Robert Eisenhuth rc?u _ Defendant Pro Se. .;: w -moo P '- t- , :Zia -n c PRAECIPE TO TRANSMIT RECORD 2„1 C) . c? 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: on or about O Z //d via Certified Mail. 3. Date of execution of the Affidavit of Consent: by Plaintiff (_// by Defendant 3 // 4. Related claims pending: None. 5. Date of filing of Waiver of Notice of Intention to Request Entry of Divorce Decree Under Section 3301(c) of the Divorce Code: by Plaintiff (--/_/_,5 L/ I / ); by Defendant andra Justine Eise uth, Plaintif ro 304 April Drive Camp Hill, PA 17011 717-418-0309 Praecipe to Transmit Record Page 1 of 1 Uo-^ Ara. J,s+ 1'( F iseAhA . V. IN THE COURT OF COMMON PLEAS ®= CUMBERLAND COUNTY. PENNSYLVANIA ?oft ueq ?66e,-4 ?Se4k d ?• NO. ?Gti' t' r' ?q DIVORCE DECREE AND NOW, j J, Of/ , it is ordered and decreed that J ws+:-L ! sell h v A plaintiffs. arr 'SCI-1k it f 1 kkel rq ' sc h ?a , 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.") ,AhAlf, By the Court. ?4 //01 4 J. C Prothonotary , 14Y 1 l?krhe? IF t7zU/el -Fo Def