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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