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Home My WebLink About02-0254IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Wayne Lelie Pier (aka Wayne Leslie Pier) 102 West Locust Street Mechani~burg, PA, 17055 SS~136-44-7216 Plaintiff VS. No. O'~-55-¥ ¢',,.,'1 Diane Ellen Pier (nee Johnson) 929 Eppley Road Mechanicsburg, PA, 17055 SS~148-42-3703 Defendant NOTICE TO DEFEND AND CLAIM 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 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 any other claim or relief requested in these papers by Plaintiff. You may lose money, property or other rights important to you, including the right to demand marriage counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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: Cumberland County Bar Association Lawyer Referral Service address and phone number of the Bar Association 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 COUNSELING NOTICE UNDER Pa.R.C.P. RULE 1920.45('a)*('1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301 (a)(6) Indignities Section 3301 (c) Irretrievable Breakdown Mutual Consent Section 3301(d) Irretrievable Breakdown Two-Year Separation where the court determines that there is a reasonable prospect of reconciliation. A list of qualified professionals is available for inspection in the: FAMILY DIVISION Administrative Court Cumberland County Courthouse S. Hanover Street Carlisle, Pennsylvania 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Wayne Lelie Pier (aka Wayne Leslie Pier) SS#136-44-7216 Plaintiff VS. PENNSYLVANIA FAMILY DIVISION Diane Ellen Pier (nee Johnson) SS~148-42-3703 DIVORCE Defendant COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Wayne Leslie Pier, who currently resides at 102 West Locust Street, Mechanicsburg, Pennsylvania 17055, at least since October 20, 2000. 2. Defendant is Diane Ellen Pier (nee Johnson), who currently resides at 929 Eppley Road, Mechanicsburg, Pennsylvania 17055, at least since Septem- ber 12, 1988. 3. Wayne Leslie Pier 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 marded on May 30, 1970, at Toms River, New Jersey, County of Ocean. 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 the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An odginal copy of the marriage certificate is attached. 10. After ninety (90) days have elapsed from the date of filing of this Com- plaint, plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, plain- tiff respectfully requests the Court to enter a decree of divorce pursuant to §3301 (c) of the Divorce Code. 151aintiff/'(Pr-o Se~/ Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Wayne Lelie Pier (aka Wayne Leslie Pier) SS#136-44-7216 Plaintiff vs. No. .;.:~ Diane Ellen Pier (nee Johnson) SS~148-42-3703 Defendant VERIFICATION I verify that the statements made in this complaint are true and correct to the best of my knowledge, information and belief. I understand that false state- ments made herein are subject to the penalties of 18 PA. C.S., Subsection 4094, relating to unsworn falsification to authorities. ~ Plaintiff ~/ - DATE: TOWNSHIP OF DOVER DEPARTMENT OF HEALTH ToMS RIVER, N.J. 067iS3 DEC 0 7 ZOO1 DATE: Tius Is to certi that the following is a true co--record file~in this dqpartmenL ' ccEPT THIS CO~PY UNL~ESS THE RAISED SEAL WARNING! DO NOT A OF THE DEPARTMENT OF HEALTH iS AFFIXED HEREON, RECORD OF MARRIAGE place of Marrm~ ~ (City borough, or tow~/iP a ~ ~ 15. Residence 5. Residence )ate of Birth 7. Age (At time of Color 10'or Race 11, Occupation 12, Birthplace !.3. Father's Name 14. Mother's 25a. 26a. Signature Witness Signature of .person ,ate of Birth 17. Age Wld. Wid, rq (At tim~ of Div, oiv. ~ Ma,,ied co,o, ~^' 'i?U this ~At time of 20. or Race is matriagel i~ Former Hud- -- - officer of s( 22. Birthplace 23, Father's Name 24. Mother's maid. name b. Residence b. Residence :fating, title and addres Date 26. b ,Local Reg. 0 29. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Wayne Lelie Pier (aka Wayne Leslie Pier) SS~136-44-7216 Plaintiff VS. No. 02- ~-? Diane Ellen Pier (nee Johnson) SS#148-42-3703 DIVORCE Defendant AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a Notary Public in and for said County and State, Wayne Leslie Pier, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of his own knowledge that the Defendant Diane Ellen Pier (nee Johnson) herein is not in the military service as defined in the Solders' and Sailors' Relief Act of 1940 and its Amend- ments thereto, for the following reasons: Diane Ellen Pier resides in Mechanicsburg, Pennsylvania and works full time as a Supervisory Contracts SpecialiSt for the Department of Defense, Navy, Naval Sea Logistics Center. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondari~/~f, ora party in the military service. SignatuFe of Plaintiff IN WITNESS THEREOF, I have hereunto set my hand and seal. Dated: /~/2~- ~ /~_~ ~--~"~~~;~'~'.~ "1 ~TARIAL S~L ~ ~y ~ ~K, ~ P~i~ J ~ ~., C~ uo. I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Wayne Lelie Pier (aka Wayne Leslie Pier) SS~136-44-7216 Plaintiff vs. No. 02-254 Diane Ellen Pier (nee Johnson) SS~i48-42-3703 Defendant AFFIDAVIT OF NOTICE Wayne Leslie Pier, Plaintiff, being duly sworn according to law, deposes and says that Wayne Leslie Pier is the Plaintiff in the above captioned matter, that the Plaintiff has sent copies of the Complaint, properly endorsed, in Divorce to Diane Ellen Pier (nee Johnson) of 929 Eppley Ddve, Mechanicsburg, Pennsyl- vania 17055, the Defendant's last known address (by registered mail, postage prepaid, return receipt requested to 102 West Locust Street, Mechanicsburg, Pennsylvania 17055). - - ~ne Le~slie ~ier-- Plaintiff Notarial Seal IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Wayne Lelie Pier (aka Wayne Leslie Pier) SS~136-44-7216 Plaintiff VS. No. 02-254 Diane Ellen Pier (nee Johnson) SS~148-42-3703 :DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 18, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of 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 prop- erty, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA C.S. Sec 4904 relating to unswom falsification to authorities. ~ VPiaint~f,- ' v Dated: RIBED No~a Sea SWORN TO AND SUBSC ~ I Vilginia K. Brenneman, Notaly Pubil¢ I ..~ // I Uecma~u~g~m, Cun~edandC_,a~y I ............. "~'~ DAY //'~"{"~/ I My C°mml~l~J~n Explres Mar' 28' 20041 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Wayne Lelie Pier (aka Wayne Leslie Pier) SS#136-44-7216 Plaintiff VS. No. 02-254 Diane Ellen Pier (nee Johnson) SS#148-42-3703 DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 18, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose dghts concerning alimony, division of prop- erty, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I / - understand that false statements herein made are subject to the penalties of 18/~ / PA C.S. Sec 4904 relating to unsworn falsification to authoriti~. /~ y/// I~r~'e~d ~'n~ ' ~ .... Dated: SWORN TO AND SUBSCRIBED BEFORE ME THIS~,.~ DAY Notarial Seal I Virginia K. Brenneman, Notmy Pu~ ~ Mechanlcsburg Bom. Cumbedand.?u~b'~., ~ My Commission Expires Mar. 28, ~ I Member, pen~sytvanla Association of ~'~ Wayne Lelie Pier IN THE COURT OF COMMON PLEAS OF (aka Wayne Leslie Pier) CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS Diane Ellen Pier (nee Johnson) Defendant NO: 02-254 CIVIL ACTION - LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S.3301~c~ OF THE DIVORCE CODF 1. I consent to the entry of a final Decree in Divorce without notice. 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. 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 tot he penalties of 18 Pa. C.S.S.4904 relating to unsworn falsification to authorities, Notarial Seal '~ Virginia K. Brenneman, Notary Public I Me~rg Bom, Cumberland ,~Cou..n~^, / My Commission Expires Mar. 28, ~ut~I ~ber, Pefll~3/~vanlaA-~'s°c~n °f N°taries Wayne Lelie Pier (aka Wayne Leslie Pier) Plaintiff vs Diane Ellen Pier (nee Johnson) Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 02-254 CIVIL ACTION - LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S.3301(c/OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. I understand that I may lose dghts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 tot he penalties of 18 Pa.C.S.S.4904 relating to unsworn falsification to authorities. Wayne Lelie Pier (aka Wayne Leslie Pier) SS# 136-44-7216 VS. Diane Ellen Pier (nee Johnson) SS# 148-42-3703 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 02-254 CIVILTERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under §3301(c) -3,30-1.(d~..) .~f -t h e -D i.~er~e ~ (Strike out inapplicable section). Date and manner of service of the complaint: January 18, 2002 Served by Certified Service on January 25, 2002 Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff Apr1! 23, 2002 ; by defendant Apr1! 23, 2002 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 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: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divome was filed with the Prothonotary: Apr11 ~,~, , 2002 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: April ,~¢~ ,2002 ,~,',',c~,,c,,, ,~.,' Pla~tiff/~,fefR~mt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of Wayne Lelie Pier (aka Wayne Leslie Pier) SS# 136-44-7216 VERSUS Diane Ellen Pier (nee Johnson) SS# 148-42-3703 PENNA. NO. 02-254 DECREE IN DIVORCE AND NOW, ~ ~ DECREED THAT Wayne Leslie Pier AND Diane Ellen Pier , 2~O2, IT IS ORDERED AND , PLAINTIFF, , 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; BY THE COURT: r ~ ~ROTHONOTARY