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Home My WebLink About04-3750 ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE Defendant NO. 04 - 21SD CJC)Ll'--r~ NOTICE TED W. STRAUCH 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 in 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 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 Dauphin County, Front and Market Streets, Harrisburg, 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 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 (717)249-3166 ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE Defendant NO. 04- :31So CiULL '7-~ TED W. STRAUCH COMPLAINT IN DIVORCE 1. Plaintiff Angela M. Strauch who currently resides at 118 Nagle Street, Harrisburg, Dauphin County, Pennsylvania 17104. 2. Defendant is Ted W. Strauch who currently resides at 2903 Society Hill Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 30, 1998, in Harrisburg, Dauphin County, Pennsylvania. 5. No children were born ofthis marriage. 6. Neither Plaintiff nor Defendant are 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 it amendments. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. The parties have been living separate and apart since July 12, 2004. 10. 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. COUNT II - SECTION 3301 (a) (6) 11. The averments of paragraphs 1-10 are incorporated herein by reference. 12. The Plaintiff avers that the Defendant, in violation of his marriage vows under the laws of the Commonwealth of Pennsylvania, specifically Section 3301(a)(6) of the Pennsylvania Divorce Code, Act 26 of 1980, as amended, has offered such indignities to the person of the Plaintiff as to render her condition intolerable and her life burdensome. 12. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce divorcing Plaintiff and Defendant and such other Orders as are just and appropriate. COUNT III - EOUIT ABLE DISTRIBUTION 13. The averments of paragraphs 1-12 are incorporated herein by reference. 14, During the marriage the parties acquired marital property, assets and debts which Plaintiff requests the Court equitably distribute and assign. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant, enter an Order equitably distributing marital property and such other orders as may be just and appropriate. Respectfully submitted, Date: 0-4 9(Plu)D~ If''kdlHn Of lku..lb Jr Melissa 1. Van Eck, Esquire Attorney ID No. 85869 7800 A Allentown Blvd. Suite B P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 Attorney for Plaintiff VERIFICATION I, Angela M. Strauch, 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: 9v4 ;P, ')O()I.--{ ~) / ~ ~ ;;!c--:~ / JAi-~ //51 M, Strauch o ~1- - ~ ~ ~ -.....c:. ~-,~; :-~ -n rnt:~ r,) :n ~~-j C_) () ~r~ c') r'n r ..f9. ~lU::O o () D 111 0 V) ~ q D TJ- F'b :D~ f-r- - ~ r---::t '-.i c~~ ::i:: ~ --'-, (-:':) o ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -. LAW DIVORCE TED W. STRAUCH Defendant NO. 04-3750 Civil Term AFFIDAVIT OF CONSEN1: 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 30, 2004. 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 unsworn falsification to authorities. ~ ~ /Z .' . '%1~' . ~/C;t' ANGEL M. STRAUCH Plaintiff Date: Jk~l I 7, ;):00'1 r--.) 0 0 = = 1\ ~.; <:J'1 :r C- :;:::.- m::rJ 'r- Z --om I ::J9 0\ 00 r::c: :::1 -r I -0 ..-1--n <- ~> ('5 ~-~ --- r::;rn '=-, r:-:> ~~::1 1,,-_- ~ ~/~ ::::1 c.....) J~ =< -<:: N ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE TED W. STRAUCH Defendant NO. 04-3750 Civil Term 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 of a fina~ 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: tfl~ /7/JoO[,( ~.~dL-4~ ANGELA M. STRAUCH Plaintiff -- :("'~ L1'..... > ?~'C' Ci] _-- o c '- ~::~~ _.' " ~ = = CJ'1 '- > ;;Z I CI') o '1 ~ :C'T1 m- f-' -.,-,t-, ;.,jc:J 01 "'i(J ;~~ :_5rn ..~ '!{-..::.. :<' -0 ~: N .. C,) i'.:;. ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE TED W. STRAUCH Defendant NO. 04-3750 Civil Term AFFIDAVIT OF CONSEN1: I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 30, 2004. 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 Cornplaint. 3. I consent to the entry of a final Decree of Divon:e after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affldavit are !true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.s.g 4904 relating to unsworn falsification to authorities. Date: 0/Jp6 ~~ TED W. STRAUCH Defendant t-::> ') C-.-:> ::::il ~::::.:::> <p c- .,..:.. c..,':;: ~:-:I VJ ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE TED W. STRAUCH Defendant NO. 04-3750 Civil Term WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lUNDER ~3301 (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 tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.g 4904 relating to unsworn falsification to authorities. Date: f/~QS ~~;z;:. TED W. STRAUCH Defendant .-r-~ ,. "-, ,. -~:-) ,,-:::J <,n <- 77-' ""r (.... ~/l ~ u -0 w ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE TED W. STRAUCH Defendant NO. 04-3750 Civil Term AFFIDAVIT OF SERVICE I do hereby state that I served a true and correct copy of the Complaint in Divorce, in the above captioned matter, by placing the same in the United States mail, first-class, postage prepaid, certified mail, return receipt requested, in Harrisburg, Pennsylvania, and delivered on August 25, 2004, as per the attached return receipt card, addressed to: Ted Strauch 2903 Society Hill Drive Camp Hill, P A 17011 Respectfully submitted, ~~/JdU&i Melissa 1. Van Eck, Esquire Attorney ID No. 85869 7800 A Allentown Blvd. Suite B Harrisburg,PA 17112 (717)540-5406 Attorney for Plaintiff Date: /-7-05 SENDER: COMPLETE THIS SECTION . Complete items 1,2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: COMPLETE THIS SECTION ON DELIVERY B. ~r:;:(7f '\ td S-\-v ctLLC.h ,:9[103 Sac! ekt t+t llDr Q~rR..p HLQj) I 9 A 1701/ D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No ~PT 302- 3. Service Type l&Certified Mail D - Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (fransfer from service label) 7002 3150 0001 4960 5212 PS Form 3811. August 2001 Domestic Return Receipt 102595-02-M-1035 1"',) ,...., .:,...::. ~., L.. ,-) -n .-1 ':r: i .~ '1 (.0:;' -~'l w ...... .....:.:.. ANGELA M. STRAUCH Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE TED W. STRAUCH Defendant NO. 04-3750 Civil Term PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: I. Ground for divorce: irretrievable breakdown under Se'~tion 330 I (c) of the Divorce Code. 2. Date and manner of service of the complaint: Served via certified mail on August 25, 2004. Affidavit of Service filed simultaneously with this Praecipe. 3. Complete 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 on December 17, 2004; by defendant January 1,2005. (b)(l) Date of execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: N/A; (2) Date of service of the plaintiff's affldavit upon the defimdant: N/ A. 4. Related claims pending: None. 5. Complete either (a) or (b). a. Date and manner of service of the notice of inhmtion to file praecipe a copy of which is attached: b. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: Executed on December 17, 2004; filed January 6, 2005. Date Defendant's Waiver of Notice was filed with the Prothonotary: Executed on January 1,2005; filed simultaneously with this Praecipe. Respl~ctfully submitted, ;jj;h1M~Uuff~ Melissa 1. Van Ec, squire Attorney ID No.: 85869 7800 A Allentown Blvd, Suite B Harrisburg, PA 17112 (717) 540-5406 Date: I-/(} ~125 CERTIFICATE OF SERVICE I, Melissa 1. Van Eck, Esquire, counsel for Angela M. Strauch, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Praecipe to Transmit was served upon Ted W. Strauch, by depositing same in the United States mail, first class, on January 10, 2005 addressed as follows: Ted W. Strauch 6150 Springford Drive Apt.P7 Harrisburg, PA 1711 1 Date: 1- / () .- ()..5 ~z(;j(j(~ 1fx Melissa 1. Van ck, Esquire 7800 A Allentown Blvd, Suite B Harrisburg, PA 17112 Telephone: 717-540-5406 Attorney for Plaintiff .':2 cC> "" "-l C...::) I;Jl o -II '-1 ~r ili::r: )'-' -,;~:q c_ ;.,." G.,:. "1 e) ~~~~~~~~~~~~~+~++~~~~+++~~+~++++++~++++++++++++++++++++++++++++++~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + +++++++~++++++++~++++++++++++~++++++++~++++++? ~+ ~ + + + + ++~++~+ IN THE COURT OF COMMON PLEAS + + + + + + + + + + OF CUMBERLAND COUNTY PENNA. STATE OF + + + + IlNGELA M. S'I'RATJC'H NO'04_i7'in + + . + + + + + + + + PLAINTIFF VERSUS 'I'I<'D W STRATl('j,! + + + + + + + + + + + + DECREE IN DIVORCE + + + + + + + + + + + + + + + l'?-IllII'~f'~1 AND NOW, _ , ::>nn'i , IT IS ORDERED AND ANGELA M. STRAUCH , PLAINTIFF, DECREED THAT 'FED W. D'FRAUCII , DEFENDANT, AND + + ARE DIVORCED FROM THE BONDS OF MATRlMONY. + + + + + + + + + + + + + + + + + + + + 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 ATTE BY THE COURT: + + + + + + + + + + + + + + + + + :++~+:+++:.:+ :':+'f.+ + :I':+:+:f:+:+ :+ ++ J. . ;;4;;1- ~." '7'~ t!fi' ___"'" &v? ;>'l r;} >np 7-1" '1- r V .' ". . ---- SO rei fl.! .It' >j -