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HomeMy WebLinkAbout10-2412F:\DCCS\FL\DIV\Eisenhower..Valerie - 3301(c) complaint & verification.wpd ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF VALERIE ANNE (SHEAFFER) EISENHOWER, Plaintiff V. JOSEPH BENJAMIN EISENHOWER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. IO -? yl ?, ?; l ??M CIVIL ACTION - LAW 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 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 the Cumberland County Courthouse, 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. f 3s1 00/0 u'r c?c? 9at lQ'??-l/0 .?3 S Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF VALERIE ANNE (SHEAFFER) EISENHOWER, Plaintiff V. JOSEPH BENJAMIN EISENHOWER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 16 y1? c??l CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is VALERIE ANNE (SHEAFFER) EISENHOWER, an adult individual, who currently resides at 427 Hillside Road, New Cumberland, Pennsylvania 17070. 2. The Defendant in this action is JOSEPH BENJAMIN EISENHOWER, an adult individual, who currently resides at 702B North Front Street, Wormleysburg, Pennsylvania 17043. 3. Both the Plaintiff and the Defendant have been bona fide ;residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in ,marriage on April 7, 2006, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that no children have been born of this marriage. 8. The 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. 9. The Plaintiff requests the court to enter a decree of divorce. STONE LaFAVER & SHEKLETSKI "Oo Date: W1110 Eliz h B. to e, Esquire Sup e Cou t # 60251 4 Bridg S eet, P.O. Box E N w Cum r nd, PA 17070 Telep e 17-774-7435 Attorne,Ws for Plaintiff V E R I F I C A T I O N VALERIE ANNE EISENHOWER states that she is the Plaintiff named in the foregoing instrument and that she is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of her knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. JU -,AJ?F"L4-? - VALERIE ANNE EISENHOWER Date 10 ELIZABETH B. ATTORNEY ID 414 BRIDGE ST: NEW CUMBER] (717) 774-7435 ATTORNEY FO VALERIE ANNI EISENHOWER, v. JOSEPH BENJ BONE, ESQ ~. 60251 ?ET AND PA 17070 PLAINTIFF (SHEAFFER) Plaintiff vIIN EISENHOWER, Defendant 1~'-~ ~ ~ ~ ~~~' ~~~a .~~~ i ~ ~-~ ~ ~ ~`~ VLii~t ~ ~ J'y ,, ~ "a ` '''~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-2412 : CIVIL ACTION -LAW . IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonot Transmit the reco d, together with the following information, to the Court for entry of a divorce decree: 1. Gr and for divorce: irretrievable breakdown under Section ®3301C ^ 3301D of he Divorce Code. (Check applicable code) 2. Da e and manner of service of the complaint April 14, 201 D, via service upon De endant, Joseph Benjamin Eisenhower, by United States Certified Mail, postage pr aid, restricted delivery. 3. (C mplete either paragraph (A) or (B).} (A Date of execution of the affidavit of consent required by Section 3301(c) of the divorce code: By plaintiff 7 / 15 /10 by defendant 7 / ~j /10 (B (1) Date of execution of the affidavit of consent required by section 3301(c) of the divorce code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent 4. Re~ated claims pending: No claims raised 5. (A fete either (A) or (B).) Date and manner of service of the notice of i ntion to file praecipe to transmit record, a copy of which is attached: Date plaintiff's Waiver of Notice in § 330 c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in c) Divorce was filed with the Prothonotary: By: STONE, ESQUIRE ®Plaintiff ^ Defendant ELIZABETH B. STONE, ESQ ±~.F ~~ ~- ~~'~ `~~'~ ATTORNEY ID O. 60251 414 BRIDGE ST ET 20 (0 ,(~ ~ (~ ~!''i (' `~ %+ NEW CUMBERL ND PA 17070 (717) 774-7435 CU~w'`~~_. ._ ~.. ~.~~+ ?~~+.T`f' ATTORNEY FO PLAINTIFF r;:''~~`~`"~~~°'''~~!" VALERIE ANN (SHEAFFER) : IN THE COURT OF COMMON PLEAS OF EISENHOWER, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 10-2412 JOSEPH BENJ MIN EISENHOWER, :CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A ~omplaint in Divorce under § 3301 (c) of the Divorce Code was filed on April 12, 2010. 2. Th~ marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed frorr~ 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 o~ 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: ~..._..~ _„r._-. - ..--- By: ~~ -0 _ -~.._ /J PH B MIN EISENHOWER, Defendant G ELIZABETH B. TONE, ESQ ATTORNEY ID O. 60251 414 BRIDGE ST ET NEW CUMBE AND PA 17070 (717) 774-7435 ATTORNEY FO PLAINTIFF t,tJl,ls_ u!\~~~ f 'f ~ r,.. ~ ~ ?. r~° VALERIE ANN (SHEAFFER) : IN THE COURT OF COMMON PLEAS OF EISENHOWER :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . v. : NO. 10-2412 JOSEPH BENJ MIN EISENHOWER, :CIVIL ACTION -LAW Defendant IN DIVORCE WAVER OF NOTICE OF INTENTION TO REQUEST ENTRY 1. I consent to the entry of a final decree of divorce without notice. 2. I u derstand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses i I do not claim them before a divorce is granted. 3. I derstand that I will not be divorced until a divorce decree is entered by the Court and that a copy of he decree will be sent to me immediately after it is filed with the Prothonotary. I verify tha 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 aut orities. /~ ~--~ Date: ~/l5° By: `'~j"' ~-/ ~-~ _/ JJ SEPH BENJ IN„EfSENHOWER, ELIZABETH B. TONE, ESQ ATTORNEY ID O. 60251 414 BRIDGE ST ET NEW CUMBE AND PA 17070 (717)774-7435 ATTORNEY FO PLAINTIFF IV v: ~~~ , :r 2~iQ J!'~ 1 ~ ~'a`~ l ~ ~-~ (SHEAFFER) : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . NO. 10-2412 RIN EISENHOWER, :CIVIL ACTION -LAW Defendant IN DIVORCE JOSEPH BEN 2010. AFFIDAVIT OF CONSENT 1. A omplaint in Divorce under § 3301 (c) of the Divorce Code was filed on Apri112, 2. Th~ marriage of 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 tha 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 aut orities. Date: 1 ~ .D) By: ~ ~ L~~~~~ VALERIE ANNE (SHE FFER) EISENHOWER, Plaintiff ELIZABETH B. TONE, ESQ ATTORNEY ID O. 60251 414 BRIDGE ST ET NEW CUMBE AND PA 17070 (717) 774-7435 ATTORNEY FO PLAINTIFF II EISENH t 1.J j ~Iw.r` ` 2~ i 0 't~! 1 ~ ~~i 1 ~ ~ `.~ CVt:~;l~ _11~J«, E ~'~,,, r~. ti~Ar~r~~:x~ : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-2412 v EISENHOWER, :CIVIL ACTION -LAW Defendant IN DIVORCE v. IJOSEPH BEN WAVER OF NOTICE OF INTENTION TO REQUEST ENTRY 1. I c~nsent 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 i~' I do not claim them before a divorce is granted. 3. I and that a copy of I verify statements herein that I will not be divorced until a divorce decree is entered by the Court decree will be sent to me immediately after it is filed with the Prothonotary. the statements made in this Affidavit are true and correct. I understand that false made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to Date: ~~IS ~C~ By; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Valerie Anne (Sheafl Joseph Benjamin Ei; AND NOW, Eisenhower hoover NO 10-241.2 DIVORCE DECREE o"~ ~ , it is ordered and decreed that Valerie Anne (Shea er) Eisenhower plaintiff, and Joseph Benjamin Ei enhower ,defendant, are divorced from the bonds of matrimo Any existin spousal support order shall hereafter be deemed an order for alimony pendente ite if any economic claims remain pending. The court r tains jurisdiction of any claims raised by the parties to this action for which a final or er has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") e Court, ~'' Attest: J Prothonotary 7,a~- IZ7 c~-~-. c.o~~ m~,; te~S -1-o A~++.~ fie, U ~~^~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA ~-, -~.~ c_- ;:~, __.. ~, VALERIE ANNE (SHEAFFER) EISENHOWER, ~' ~~ ~ Tm Plaintiff - ' - Q ~.~~ a -~ ;-- r File No. 10-2412 ;_ W r..,.:; . IN DIVORCE ~~ 9" ~;,' JOSEPH BENJAMIN EISENHOWER, . Defendant ~ ~ '' NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, [select one by marking ":-"] prior to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of VALERIE ANNE SHEAFFER, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: ~v- ~ ~i 1~ ~n ~C ,t 'ill - Signature, VALERIE ANNE EISENHOWER Signature of name being resumed, VALERIE ANNE SHEAFFER COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLANB . On the ~~ day of I~~r~_, 2010, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. $ I I.00 PO PUFF ? ~~i+oh0~ w~~t~irM ~ h~ ~` Notary Pu he M~r11.