HomeMy WebLinkAbout10-3827
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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.
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Jeannie Siegfried, . IN THE COURT OF COMMON PLEAS OF
Plaintiff Ct31Jr~~.-~.~, ;~ ~; t ~ UMBERLAND COUNTY, PENNSYLVANIA
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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.
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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.
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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
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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 ~
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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
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CERTIFICATE OF SERVICE ~ f ~ v,
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I, Patrick Schaeffer, Certified Legal Intern, Family Law Clinic, hereby certify=that I
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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
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O Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
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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
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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
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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
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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
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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.
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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
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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.
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Patrick Schaeffer
Certified egalInt
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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.
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