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HomeMy WebLinkAbout01-1398STEPHEN L. DARHOWER TAMMY J. DARHOWER Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION o LAW :NO. CIVIL TERM : 1N DIVORCE NOTICE 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 cottrt. 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 nmrriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 STEPHEN L. DARHOWER, Plaintiff TAMMY J. DARHOWER Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.0/ -/'~C~IVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Stephen L. Darhower, who currently resides at 4201 Carlisle Road, Gardners, Cumberland County, Pennsylvania, since February, 1986. 2. Defendant is Tammy J. Darhower, who currently resides at Mt. Holly Springs, Cumberland County, Pennsylvania, since June, 2000. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 15, 1986, in, Huntsdale, 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 marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. 155 South Hanover Street Carlisle, Pennsylvania 17013 1 North Main Stre~ Chambersburg, Pennsylvania ] 720 I verify that the statements made in this Complaint 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: Darhower, Plaintiff Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 STEPHEN L. DARHOWER, TAMMY J. DARHOWER., Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01 - 1398 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT l, A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 12, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 1 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. Stephen L Darhower, Plaintiff STEPHEN L. DARHOWER, Plaintiff TAMMY J. DARHOWER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 - 1398 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT AND ACKNOWLEDGEMENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 12, 2001, and I acknowledge receipt ora copy of the same, which was served on me on March 16, 2001, by HAND DELIVERY. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divome is granted. 5. I have been advised of the availability of marriage counseling, and do not request that the Court require that my spouse and I paW]cipate in said counseling. 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: q l g l o t Tam0ly/3. Darhower, Defendant  ~d s~sc~ri,,bsd to before me this Notary Public NOTARIAL SEAL DAWN M, SHUGHART, Notaw Carlisle, Cumberland CoiJ~lt¥ My Commission ExpkN N~/, STEPHEN L. DARHOWER, Plaintiff TAMMY J. DARHOWER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 ~ 1398 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF TItE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 unswom falsification to authorities. Date: ~:~'~' v~t~phen L. Darhower, PlaintilI STEPHEN L..DARHOWER, Plaintiff TAMMY J. DARHOWER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 - 1398 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl 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 aPter 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. ammy J. Darhower, Plaintiff STEPHEN L. DARHOWER TAMMY J. DARHOWER Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : .'NO. 01 - 1398 CIVIL TERM : 1N DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 16th day of March, 2001, I, Karl E. Rominger, Esquire, attorney for Stephen L. Darhower, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant, Tammy Darhower, by hand delivery at the Hamilton Restaurant in Carlisle, Pennsylvania. Dated: March 16, 2001 Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 I.D. # 81924 STEPHEN L. DARHOWER TAMMY J. DARHOWER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 - 1398 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry ora divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Affidavit of Service by hand delivery on March 16, 2001. 3. Date of execution of the affidavit of consent required by § 3301 (c) or The Divome Code: by the Plaintiff.' September 25, 2001; by the Defendant: October 23, 2001. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 23,2001. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 23, 2001. Date: October 23, 2001 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241 ~6070 Supreme Court ID No. 81924 IN THE COURT OF COMMON PLEAS Stephen Darhower OF CUMBERLAND COUNTY STATE OF ~,~- ~ PENNA. Tammy Plaintiff VERSUS Darhower Defendant NO. 01-1398 CIVIL TERM AND NOW, DECREED THAT DECREE IN DIVORCE 3t Stephen Darhower , ~/ , IT IS ORDERED AND , PLAINTIFF, AND Tammy Darhower , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; none BY TH~ ATTEST: PROTHONOTARY