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HomeMy WebLinkAbout10-3827 ~fL~~ ~"~ <~`~' Jeannie Siegfried,- `- ;~ ~ ~ ;`"~ ''r^,~':Y P1ain~~0 Jii;'f - 9 °t~ Z: ~ ~ v. GU~~?~ _:~ . °a;~'tCi y, ri ~~p~ a ~ (`~ ^ ~ yf~, Eugene Siegfried, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE NO. 10- 3 ,~ ~.7 CIVIL TERM 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, Cumberland County Courthouse, 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, 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 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 must attend the scheduled conference or hearing. J L. r'F T~'c F '1 ~ `d'?"ARY ZOffl JUr~ -9 ~~ 2: 3~ Jeannie Siegfried, . IN THE COURT OF COMMON PLEAS OF Plaintiff Ct31Jr~~.-~.~, ;~ ~; t ~ UMBERLAND COUNTY, PENNSYLVANIA ~~u~~ r tr~~fJSvl.~r~~FJlq v. :CIVIL ACTION -LAW IN DIVORCE Eugene Siegfried, Defendant : NO. 10- CIVIL TERM DIVORCE COMPLAINT The plaintiff, Jeannie Siegfried, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. §~i3301(c) AND 3301(d~OF THE DIVORCE CODE Plaintiff is Jeannie Siegfried, who currently resides 206 South Queen Street Shippensburg, Cumberland County, PA 17257, since on or about September 10, 2009. 2. Defendant is Eugene Siegfried, who currently resides at 74 Cortland Circle, Shippensburg, Franklin County, PA 17257, since on or about August 1, 1996. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 7, 1988 in Mechanicsburg, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since approximately September 10, 2009. 6. There has been one prior petition for divorce between the parties which was withdrawn on September 3, 2008. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. ~o~vj~' Patrick So aeffer Certified Legal Intern ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. p Date ~- ~1' o~~ IZ~ Plaintiff Jeannie Siegfrie Jeannie Siegfried, Plaintiff v. Eugene Siegfried, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE NO. 10- ~~~CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Jeannie Siegfried, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date: June 9, 2010 :'°" ~ Patrick Schaef er Certified Legal Intern ROB T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 ~ ~ _ rl'1r;° C ~~ -s "' t ~ i"7`S C_., - I ~ {~_~~~ ~~+ -- ~ _ . ?'' ~ `~ cf C N ~ -G W W ~ Jeannie Siegfried, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION-LAW IN DIVORCE Eugene Siegfried, : Defendant NO. 10 - 3827 CIVIL TERM "~: _« r ~,' CERTIFICATE OF SERVICE ~ f ~ v, __ I, Patrick Schaeffer, Certified Legal Intern, Family Law Clinic, hereby certify=that I L~ ` N served a true and correct copy of the Divorce Complaint on Eugene Siegfried, residing 74 ~, Cortland Circle, Shippensburg, PA 17527, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Eugene Siegfried, on the 12~' day of June 2010 as evidenced by the attached green card. ~ Patrick Schae fer ~ N O Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 a .m ~' ~ E ~ m Q U ~ p Q 1"1 ...~ LJ 0 o 0 0 N ~"~ r~ ld ~ ~ m ~ Q ~` T M O a d ~; -T1 r'a C-' ~:,=-; :r_•; ,.'.T 4 it w, :~ Jeannie Siegfried, Plaintiff V. Eugene Siegfried, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 10-3827 CIVIL TERM CERTIFICATE OF SERVICE I, Patrick Schaeffer, Certified Legal Intern, Family Law Clinic, hereby certify that I served a copy of the Plaintiff's Affidavit of Consent and Waiver of Notice, Defendant's Affidavit of Consent and Waiver of Notice, Praecipe to Transmit Record, and Divorce Information Sheet on the following person by first class U.S. Mail, postage prepaid, this 1st day of October, 2010: Eugene Siegfried 74 Cortland Circle Shippensburg, PA 17527 WE= - Patrick Schaeffer' Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 2 C.- r-a -r? C27 CJ -11 F= -<> 1w7? !`- ;z7- -Tj V j J Jeannie Siegfried, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Eugene Siegfried, : Defendant : NO. 10-3827 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on June 9, 2010. 2. The 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 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 herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date C-) -n c , C :)-n Jeannie Siegfried, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Eugene Siegfried, Defendant : NO. 10-3827 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on June 9, 2010. 2. The 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 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 herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date 2-'?0 _ /U Eug a Siegfried, De ant cc o C) --s T"T 11 -om r + C3 F?F Jeannie Siegfried, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Eugene Siegfried, Defendant : NO. 10-3827 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date 9'Z0 /0 Eug a Siegfried, D dart w7 Cz) o.? e? Fri ? r7i r- CJ- '_ a cn 2, CD ' -'. - n ;cam . s Jeannie Siegfried, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Eugene Siegfried, : Defendant : NO. 10-3827 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. 1 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 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 g -19 - a0 (C' C-T1Q C) =-T,, =r CD 7 5- , {iT1 ? ° i r-n 0 Jeannie Siegfried, Plaintiff V. Eugene Siegfried, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 10-3827 CIVIL TERM PRAECIPE TO TRANSMIT RECORD r v _- ? r ? o ` y ppl? t ` ?n Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: United States mail, certified, restricted delivery, return receipt requested, postage prepaid on the 12'' day of June 2010 to Eugene Siegfried, residing at 74 Cortland Circle, Shippensburg, Franklin County, PA 17527. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by Plaintiff: September 19, 2010; by Defendant: September 20, 2010. 4. Related claims pending: none 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: October 1, 2010. Date Defendant's Waiver of Notice was filed with the Prothonotary: October 1, 2010. /D///zalo Date 7**0z="- Patrick Schaeffer Certified egalInt r AWNA4CP0NALD-FOX/- THOMAS'A PLACE ROBERT E. RAINS MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff Jeannie Siegfried IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. Eugene Siegfried NO. 10-3827 DIVORCE DECREE AND NOW, 4~a~.- S' Ze ~ o , it is ordered and decreed that By the Court, Jeannie Siegfried plaintiff, and Eugene Siegfried ,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.") None. Atte J. r v,~! b. ~u,eh• Proth notary ~~~ ~=L- Jp •~.. JD `71~~