HomeMy WebLinkAbout01-2677Andrew C. Sheely, Esquire
127 S. Market ~tree% ·
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
STEPHEN C. SAUVE,
VS.
HELEN M · SAUV~,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTIOiN - LAW
01 - ciVIL
IN DIVORCE
NOTICE TO DEFEND AND CLAIRE 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 against 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 with 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 at the Cumberland County Courthouse,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY~. DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIWDRCE 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, GiO 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, PENNSYLVANIA 17013
(717) 249-3166
PA. I.D. No. 62469
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
717 697-7050
Attorney for Plaintiff
Andrew C. sheely, Esquire
127 S. Marke% street ·
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
STEPHEN C. SAUVE,
Plaintiff
VS ·
HELEN M. SAUVE,
Defendant
: IN TEE COU~ OF COMMON PLEAS OF
: CUMBEBLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 01 - ~&~ CIVIL TERM
: IN DIVORCE
DIVORCE COMPLAINT
1. Plaintiff is Stephen C. Sauv~, an .adult individual who
currently resides at 6026 William Drive, Mechanicsburg, Cumberland
County, Pennsylvania.
2. Defendant is Helen M. Sauv~, an adult individual who
resides at 6026 William Drive, Mechanicsburg, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant have been bona fida residents of
the Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 4, 1987 in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties.
6. Neither party is a member of the armed forces of the
United States of America.
7. Plaintiff has been advised of the availability of
marriage counseling and understands that he may have the right to
request that the court require the parties hereto to participate
in counseling.
VERIFICATION
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to penalties of 18 Pa.C.S.A. Section. 4904, relating to
unsworn falsification to authorities.
Steph&n C. Sauv~
Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
STEPHEN C. SAUV~,
Plaintiff
VS.
HELEN M · SAUVE,
Defendant
: IN THE COUR~ OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 01 - 2677 CIVIL TERM
:
: IN DIVORCE
ACCEPTANCE OF SERVICE
I, Helen M. Sauv6, Defendant, hereby accept service of the divorce
complaint filed by Stephen C. Sauv6, Plaintiff, and further certify that I am
authorized to do so in accordance with PA. R.C.P ]No. 402 (b).
Helen M. Sauv6
6026 William Drive
Mechanicsburg, PA 17055
Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
STEPHEN C. SAUV~,
Plaintiff
VS.
HELEN M. SAUV~,
Defendant
: IN THE COU~ OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 01 - 2677 CIVIL TERM
:
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on May 3, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed frc~ the date of filing
and service 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.A. Section 4904 relating to
unsworn falsification to the authorities.
STEPH~N C. SAUV-~
Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Meehanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
STEPHEN C. SAUV~,
Plaintiff
vS.
HELEN M. SAUV~,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 01 - 2677 CIVIL TERM
Defendant :
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301 (C~ OF THE DIVORCE COD~
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 decree 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.A. Section 4904
relating to unsworn falsification to the authorities.
~sTEP~EN .2. ~AUVE
Andrew C. sheel~, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
STEPHEN C. SAUVE,
Plaintiff
vs.
HELEN M. SAUV~,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 01 - 2677 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on May 3, 2001. I acknowledge that I
received a copy of the divorce complaint on May 7, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed frem 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.
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.A. Section 4904 relating to
unsworn falsification to the authorities.
HELEN M. SAUV~
Andrew C. Sheely, Esquire
127 S. Market S~reet ~
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-597-7065 (Fax)
STEPHEN C. SAUV~,
Plaintiff
VS.
HELEN M. SAUVI~,
Defendant
: IN THE COU~ OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 01 - 2677 CIVIL TERM
:
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE: UNDER
~3301 (C) OF THE DIVORCE COD~
1. I
without notice.
2.
consent to the entry of a
final decree of divorce
alimony, division of property, lawyer's fees or expenses
not claim them before a divorce decree is granted.
I understand that I may ]Lose rights concerning
if I do
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.A. Section 4904
relating to unsworn falsification to the autlhorities.
DATE:
HELEN M. SAUV~
STEPHEN C. SAUV~,
Plaintiff
vs.
HELEN M. SAUV~,
Defendant
: IN TEE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:
: 01 - 2677 CIVIL TERM
:
: IN DIVORCE
PI~AECIPE TO TRANSMIT RECO~n
TO TEE PROTHONOTARY:
Kindly transmit the record, together with the following
information to the Court for entry of a Divorce Decree:
1. Grounds for Divorce: Irretrievable breakdown under
Section 3301 (C) of the Pennsylvania Divorce Code.
2. Date and Manner of service of the complaint:
Personal Service, on May 7, 2001.
3. Complete either paragraph (a) or (b).
(a) Date of execution of affidavit of consent required by
Section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on
August 7, 2001 and by Defendant on August 7, 2001.
(b) (1) Date of execution of the affidavit required by
Section 3301 (d) of the Divorce Code: Not_~~ (2) Date of
filing and service of the plaintiff's affidavit upon the
respondent: Not a~cable.
4. Related claims pending: None. All resolved by Post
Nuptial Settlement Agreement dated May 25, 2001.
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention
to file praecipe to transmit record, a copy .of which is attached:
Not applicable
(b) Date Plaintiff's Waiver of Notice in Section 3301 (C)
was filed with the Prothonotary. August , 2001
Date Defendant's Waiver of Notice in Section 3301 (C)
Divorce was filed with the Prothonotary. August , 200]
~ A]~ 0e~e
a~d~e~w' C .. She
Attorney for Plaintiff
1N THE COURT Of COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~
Ste~h~n O.
Plaintiff
VERSUS
Helen M. Sauv~,
D~f~ndan~
NO.
PENNA.
01
2677
DECREE lin
DIVORCE
AND NOW, ~.~ /~
DECREED that Stephen C. Sauv6
AND Helen M. Sauv~
, IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOiIOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION For WHICH A FINAl ORDER HAS NOT
Yet BEEN ENtered; None. All resolved pursuant to the
Post-Nuptial Settlement Agreement dated May 25, 2001.
By Th~COUrt: /
PROTHONOTARY