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Home My WebLink About04-4476 LONNIE A FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff CIVIL ACTION - LAW NO. 64 - 41.rl!p C1c.;ll/82-.WJ vs. ANNE FRIEDMAN, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claim 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 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the office of the Prothonotary at the Cumberland County Courthouse. 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 Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LONNIE A. FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff CIVIL ACTION - LAW vs. NO. ANNE FRIEDMAN, IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff Lonnie A. Friedman is an adult individual who currently resides at 1916 Monterey Drive, Mechanicsburg, Cumberland County, Pennsylvania. His date of birth is May 5, 1972. 2. Defendant Anne Friedman is an adult individual who currently resides at 19 I 6 Monterey Drive, Mechanicsburg, Cumberland County, Pennsylvania. Her date of birth is December 30, 1974. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 31, 2001 in York, York County, Pennsylvania. 5. There have been no prior actions of divorce or annulment instituted by either of the parties in this or any other jurisdiction. 6. There were no children born of this marriage. 7. The marriage of the parties is irretrievably broken. 8. 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' Relief Act of the Congress of 1940 and its amendments. 9. 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. WHEREFORE, Plaintiff Lonnie A. Friedman prays that this Honorable Court enter a Decree dissolving the marriage between the Plaintiff and Defendant pursuant to 11 3301 of the Divorce Code. Respectfully submitted, Date: September L, 2004 KELLY, HOFFMAN & GODUTO LLP By: ~A:'\ / U ~ Rob~/;::~ Attorney LD. No. 55769 Begene A. Bahl, Esquire Attorney LD. No. 87803 Attorney for Plaintiff Commerce Towers - 10th Floor 300 North Second Street Post Office Box 62003 Harrisburg, P A 17106-2003 (717) 920-8100 VERIFICATION I, Lonnie A. Friedman, verify that the statements made in this COMPLAINT 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 authorities. ~\.\D~ ~ t\ ~ · Date Lonnie A. Friedman ~ iq. ...... ~ ti .c 0 - 111 ...... C> "" .-.) II) D ,"] ,'--."J ~ ,-...:: -1'1 Ct) o. .-. 0- ~ ~ '. . CJ..I . lI) I -...0 c':;, 1? 0 - -+--- i:';;' ~ ;' ._~) " LONNIE A FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION - LAW vs. NO. 04-4476 ANNE FRIEDMAN, IN DIVORCE Defendant PROOF OF SERVICE On this 13th day of September, 2004, I, Begene A. Bahl, Esquire, of the law firm of Kelly, Hoffman & Goduto LLP, hereby certify that on the 11th day of September, 2004, I served a true and correct copy of the Complaint in Divorce in the above referenced matter, as evidenced by the attached return receipt, by Certified Mail, Return Receipt Requested, and also by depositing the same in the United States First Class Mail, postage prepaid, in Harrisburg, Pennsylvania, to the person and address indicated below: Anne Friedman 1916 Monterey Drive Mechanicsburg, P A 17055 ~::nqA~ Complete items 1 , 2. and 3. Also complete item 4 if Restricted Delivety 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: ~rllll4... FI':ctc:l.jY)Q nl I Gj I ~ rn O,.v(e......QY yr, (f) e..cJ-.0\ '\J ''CO b> ld'q I f A J 177J~5 o Agent o Addressee C. Date of Delivery o Yas f 2. Article Number (Transfer from service label) PS Form 3811 , February 2004 7003 1680 0007 0831 2378 102595-02-M.1540 i Domestic Return Receipt C) ~~ c ~~l -< '" c, ('"=,~ .r- C/) jTj ~\) o -n -l :T::'T; ~@J ~3 ~~~ ,.,-c5 e;~~~ ..-):n ;::,., T' -'. r;~ cr, IN THE COURT OF COMMON PLEAS OF CUMIIERLAND COUNTY, PENNSYLVANIA LoY\V\ I ~ A - ~f L .eAfVlaV) Plaintiff Vs FileNo. Cy-f - ({ c{ 7 fa IN DIVORCE A (/\,ltl P ~I \-eJ M(tVI Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] ~ prior to the entry of a Final Decree in Divorce, or _ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of -.Jv\ e l VI,+k, written notice avow.. ng his I her intention pursuaMovision Date: 0 Si , and gives this COMMONWF,.j\LTH 9F P~NNSYLV ANIA COUNTYOF~d On the /t/k-aay of 0 c..:Ivb () /' , 2004 before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand herelmto set my hand and official ~S. 'f b. 19nature 0 name emg res ) P1v'\V\e ~e.tV\\./k seal. ~~Q &~,dn{llk/ Prothonotary or Notary Public \' NOTARIAL SEAL CLAUQ!A I.. Bi\EWBiIKER. NOTARY PUBLIC f Carlisle Bore C:umberland County , t_A'~' Commiss!Ori ~:,~,;dS !\pril4, 2005 ~ f ~ '" c.;:) C) C.:l .)"1 ~- = .. r: ~ ~ -; ~\ :-< ~ .r:- ~ 6 t-? \..f) (J'l - LONNIE A. FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION - LAW vs. NO. 04-4476 ANNE FRIEDMAN, IN DIVORCE Defendant AFFIDAVIT OF CONSENT I. A Complaint in Divorce under S 3301(c) ofthe Divorce Code was filed on September 3,2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and 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 subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification of authorities. Date: raj,.3)0 ~ I (1 ~N ~A ;j) n'1reiYJ Anne Friedman (.,r-, LONNIE A. FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION - LAW vs. NO. 04-4476 ANNE FRIEDMAN, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. 1 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! 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. CS. 9 4904 relating to unsworn falsification to authorities. Date: \ \J -) \(}\ ~ Lonnie A. Friedman _.._~ . , LONNJE A FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION - LAW vs. NO. 04-4476 ANNE FRIEDMAN, IN DIVORCE Defendant PROOF OF SERVICE On this 13th day of September, 2004, I, Begene A Bahl, Esquire, of the law firm of Kelly, Hoffman & Goduto LLP, hereby certify that on the 11 th day of September, 2004, I served a true and correct copy of the Complaint in Divorce in the above referenced matter, as evidenced by the attached return receipt, by Certified Mail, Return Receipt Requested, and also by depositing the same in the United States First Class Mail, postage prepaid, in Harrisburg, Pennsylvania, to the person and address indicated below: Anne Friedman 1916 Monterey Drive Mechanicsburg, P A 17055 ~()~ Begene A Bahl .. ~ . Complete items 1, 2. and 3. Also complete . item 4 jf 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 mallpiece, or on the front it space permits. 1. Article Addressed to: -A: rJ !Ii <2- F I' ~ <2.<lfYl Q nI Iql~ f'hOr/(<?"'f('QyPr. If) e.~C\ '\J I c:,s b> (,\l'"CX" f A J I 7vC;5 2. Article Number (Transfer from service label) PS Form 3811, February 2004 o Agent o Addressee C. Date of Delivery --- ~ertified Mail egrstered o Insured Mail 4. Restricted OelivelJl? (Extra Fee) DYes i 7003 1680 0007 0831 2378 102595-02-M-154Q: Domestic Return Receipt ::-" ~/) I"~; \ VN '..)! ,. , - LONNIE A. FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION - LAW vs. NO. 04-4476 ANNE FRIEDMAN, IN DIVORCE Defendant AFFIDAVIT OF CONSENT L A Complaint in Divorce under S 3301(c) ofthe Divorce Code was filed on September 3, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and 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 ofthe decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification of authorities. Date: 1"( - 1. q -0. ~ ~ Lonnie A Friedman c'" (.~ \..., ."" 1"-"") . . --------- -----'- . LONNIE A. FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW vs. NO. 04-4476 ANNE FRIEDMAN, IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for Divorce: Irretrievable breakdown under 9 3301(c) of the Divorce Code. .' 2. Date and Manner of Service of the Complaint: The Complaint was served on Defendant on September 11,2004 via certified mail. 3. Complete either (a) or (b): (a) Date of Execution of the Affidavit of Consent required by 9 330I(c) of the Divorce Code: By Plaintiff: 12/29/04 By Defendant: 12/13/04 (b) Date of Execution of the Affidavit required by g 3301(d) of the Divorce Code: Date of Filing and Service of the Plaintiff's Affidavit upon the Respondent: N/A 4. Related claims pending: NI A . 5. Complete either (a) or (b): Dated: 1/,3/05 / I (a) Date and Manner of Service of the Notice ofIntention to File Praecipe, a copy of which is attached: N/A (b) Date of Plaintiffs Waiver of Notice as filed with the Prothonotary: 12/29/04 Date of Defendant's Waiver of Notice as filed with the Prothonotary: 12/13/04 ~/lU O<:Z:{L(~' Att eys for PlamtJff Kelly, Hoffman, & Goduto, LLP Robert Goduto Attorney LD. No. 55769 Begene Ann Bahl Attorney LD. No. 87803 Commerce Towers - 10th Floor 300 North Second Street Harrisburg, Pennsylvania 17101 717-920-8100 (Fax) 717-920-0691 ------ L. ( t_,; '.;.) ----- ii'f.:t: :+: , , , , , , , , , , . , . . . . . . . . . . . . . . . . . . . . . . . . . , , . , , . + . . . + . , . . , + , , . , . , . . . , . , . . , + . , , , . . . , . , , + , . , , + , . , , , + , , + , , + +"':t: + , , Of. +.+::+: :t: :f.+'+: '+:+'f.+:t:'I':tO:tO +'I':+.:f.:t: +:t::t::+: +::+::+. +", + + + + + + + + . +++:t: ++:1: :+. + +: +:+:+ :+::+: :t: +:+++: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. LONNIE A. FRIEDMAN, Plaintiff NO. 04-4476 VERSUS ANNE FRIEDMAN, Defendant DECREE IN DIVORCE AND NOW, _'\~ IF ---- '?W~ , IT IS ORDERED AND DECREED THAT Lonnie A. Friedman , PLAINTIFF, AND Anne Friedman , 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; ~O~ ./ ? , // / BY TH~ COURT: // / // / \'/I')~ ATTEST~ '~ ( ~~~ ~ I ~ PROTHONOTARY +" :+:'1'+'+''1''++:+::+::+:+'1'+'1;++ +:+:+++'f.:+: '+'++'1' :t:+:+:+ +:t::+:+:+::+:++:+:+:+::+:++:+:++ +++:+: , :+: 'I' '+:+: Of , + . + + , , + + + + . + , , + + . + + + . , , , + , + , + . + + , + + , , + + + . , + , , + + , + , , , + , . , , , , , , + , , + , , , , + , , . , J. , , . , , , , . + , . , , . , :to +: +.+' '" .. _~;? ';z /Pyr~,y,", ,_~~7Z , -?h,o . ;"1,;7':/ ;1/".7 fY",f /1fT''- "r Y . . ..--------- If ' II I - LONNIE A. FRIEDMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff CIVIL ACTION - LAW vs. NO. 04-4476 ANNE FRIEDMAN, IN DIVORCE Defendant AFFIDAVIT OF CONSENT l. A Complaint in Divorce under S 3301(c) of the Divorce Code was tiled on September 3,2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and 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 ofthe decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. CS. S 4904 relating to unsworn falsification of authorities. Date: , ~ J',3)0 cf f Cf It\W t; A ;JJ k1(OlYj Anne Friedman ,---.~~ c_ ~"; c." __J