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Home My WebLink About01-1770TIMOTHY KARL TRAVITZ, Plaintiff ANITA MARIE TRAVITZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. Ol- : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO: Anita Marie Travitz 18 South 2"a Street Wormleysburg, PA 17043 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 ar~y other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the ground for 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, ()ne Courthouse Square, Carlisle, Pennsylvania 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. Document #: 201158.1 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 TIMOTHY KARL TRAVITZ, Plaintiff V. ANITA MARIE TRAVITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Timothy Karl Travitz, an adult individual curremly residing at 3015 North 4th Street, Harrisburg, Dauphin County, Pennsylvania, 17110 since February, 2001. 2. The Defendant is Anita Marie Travitz, an adult individual who currently resides at 18 South 2~ Street, Wormleysburg, Cumberland County, Pennsylvania, 17043 since 1997. 3. The Plaintiff and Defendant have been bona title residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 17, 1987 in Watts, Perry County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment between the parties. Document #: 201158.1 9. 10. Defendam. 7. Plaimiff has been advised that counseling is available and that Plaimiff may have the right to request that the Court require the parties to participate in counseling. No children were born of the marriage. The marriage is irretrievably broken. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and WHEREFORE, Plaintiff request that this court enter a Decree in Divorce, and enter such other orders as are appropriate. Dated: March 2..~, 2001 METZGER, WICKERSttAM, KNAUSS & ERB, P.C. Karl R. Hildabrand, Esquire Attorney I.D. No. 30102 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Timothy Karl Travitz Document #: 201158.1 VERIFICATION I, Timothy Karl Travitz, verify that the statements made in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. 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: T'~Tra~itz~ Document #: 2011.58.1 TIMOTHY KARL TRAVITZ, Plaintiff ANITA MARIE TRAVITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 01-1770 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Karl R. Hildabrand, Esquire, counsel for Plaintiff Timothy Karl Travitz, hereby certify that a true and correct copy of the Complaint in Divorce in the above matter was served upon Defendant Anita Marie Travitz, by certified mail, return receipt requested, on April 3, 2001. Attached hereto, marked as Exhibit "A" and incorporated herein by reference is the signed return receipt card for said service. Date: METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Karl R. Hildabrand, Esquire Attorney I.D. No. 30102 3211 North From Street, P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 202741.1 Anita Marie Travitz ~gent Receipt for Merchancfi$e TIMOTHY KARL TRAVITZ Plaintiff V. ANITA MARIE TRAVITZ, Defendant. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1770 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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 Complaint: A Complaint in Divorce was filed on March 26, 2001, and served on Defendant on April 3, 2001 via certified mail, return receipt requested. Affidavit of Service has been filed. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiff's and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code: Plaintiff- October 17, 2001 Defendant - October 18, 2001 (b)(1) Date of execution of Plaimiff's affidavit required by Section 3301(d) of the Divorce Code: n/a (2) Date of service of the plaintiff's affidavit upon the defendant: n/a Complete the appropriate paragraphs: Document #.. 201161.1 TIMOTHY KARL TRAVITZ, : Plaintiff : : v. : NO. 01-1770 : ANITA MARIE TRAVITZ, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301{e) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I 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. Dated: Anita I~ri~ T~'~ Document #: 217730.1 TIMOTHY KARL TRAVITZ, : Plaintiff : : v. : NO. 01-1770 : ANITA MARIE TRAVITZ, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301(c) of the Divorce Code was filed on March 26, 2001, and served upon Defendant on April 3,2001. An Affidavit of Service was filed on April 12, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 tkis 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: /ff./~_~//// Anita~XTt~rie T~~ Document #.. 217728.1 TIMOTHY KARL TRAVITZ, : Plaintiff : : v. : NO. 01-1770 : ANITA MARIE TRAVITZ, : Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 26, 2001, and served upon Defendant on April 3,2001. An Affidavit of Service was filed on April 12, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety 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 tree 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: Timothy Ka-Yf Travitz - 4~ Document Il.- 217728.1 TIMOTHY KARL TRAVITZ, : Plaintiff : : v. : NO. 01-1770 : ANITA MARIE TRAVITZ, : Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I 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. Dated: ~,~;F3 /'?e Z~/ ~'imothy"~l Travit~ Document ii.. 217730.1 TIMOTHY KARL TRAVITZ VERSUS ANITA MARIE TRAVITZ INTHE COURT OF COMMON PLEAS OFCUMBERL~ND COUNTY STATE OF ~~ PENNA. NO. 01-1770 DECREE IN DIVORCE AND NOW, t~cff'z~:~,.~ ..7 / ¢* DECREED THAT TIMOTHY KARL TRAVITZ AND ANITA MARIE TRAVITZ ARE DIVORCED FROM THE BONDS OF MATRIMONY. __, IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD iN THIS ACTION POR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. The written agreement of the parties dated the 6th day of March, 2001 im in£orpormtmd, hut nnt merged, hmrei~, BY TH.j~-COURT: / PROTHONOTARY