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HomeMy WebLinkAbout02-04601.22.02. Cindy Straitiff DiVbrce Complaint IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CINDY L. STRAITIFF, Plaintiff ROBERT T. STRAITIFF, Defendant NO. O2-- 450 CIVIL ACTION - I.~.W DIVORCE 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 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GR3kNTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 1.22.02. Cindy Straitiff Divorce Complaint 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 1.22.02. Cindy Straitiff Divorce Complaint IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CINDY L. STP~AITIFF, Plaintiff ROBERT T. STRAITIFF, Defendant : CIVIL ACTION - LAW : DIVORCE Plaintiff, Cindy L. Straitiff, by er attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUlqT I: DIVORCE The Plaintiff is Cindy L. Straitiff, an adult individual residing at 202 Third Street, Apartment 6, New Cumberland, Cumberland County, Pennsylvania. The Defendant is Robert T. Straitiff, an adult individual residing at 1701 Maple Street, New Cumberland, Cumberland County, Pennsylvania. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 1.22.02. Cindy Straitiff Divorce Complaint Plaintiff and Defendant were married on May 31, 2001 at Cumberland County. There have been no prior actions of divorce or annulment between the parties. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. The Defendant is not a member of the Armed Services of the United States or any of its Allies. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b· That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. 1.22.02. Cindy Straitiff Divorce Complaint WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, Supreme Court ID #32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff 1.22.02. Cindy Straitiff · DivOrce Complaint VERIFICATION I 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. Section 4904, relating to unsworn falsification to authorities. CINDY,. -~TP~AITIFF ~ · ..< ~ CINDY L. STRAITIFF, Plaintiff ROBERT T. STRAITIFF, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 02-460 : : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Divorce Complaint has been served upon the Defendant, Robert T. Straitiff, by Certified Mail, Restricted Delivery on the 6th day of February, 2002. The return receipt for said mailing is attached hereto as Exhibit "A" and made a part hereof. Respectfully submitted, ~f~. 'CL~a~, ESQUIR ~~AR~011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff - 1 - $ Certified Fee Return Receipt Fee Postmark (Endorsement Required) Here (E,dorsernent Requ,r6d) 3. 5b Total Postage & Fees .~ SENDER: . . I also wish to receive the · Complete items 1 and/or 2 f4~r additional serwces, following services (for an · Complete items 3, 4a, and b. . · extra fee): i~i~nt your narne and address on the reverse of thru form so that we can return th~s .Attecht~isformtotfleffontofthemallpiece, or on the beck lf space d°es n°t j~ ~'~ _ 2.JJjJ Restn'cted Delivery · 'P~'-'?t;~-o-m Receiot R~uested' on the mailpiece below the article number. _~ _ · The Return Receipt will show to whom the article was delwered a d Consult postmaster for lee. ~eliv,ered. 4a Art c e Number ~,--t~.,~t~cle Addressed to. ~ ~ ! I'1(%1 CY' n ...... ~1",~ J~.\ J~ -- . Addmssee's Address (Only if requested and fee is paid) ~enE)elii~sil~c Return ~ EXHIBIT "A" - 2 - CINDY L. STRAITIFF, Plaintiff v ROBERT T. STRAITIFF, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-460 : : CIVIL ACTION - LAW : IN DIVORCE o WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION ~301(c) OF THE D~VORCE CODE 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 to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ROBERT T. STP~AITIFF ~ CINDY L. STRAITIFF, Plaintiff v ROBERT T. STRAITIFF, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-460 : : CIVIL ACTION - LAW : IN DIVORCE 2 o 3 o WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c~ OF THE DIVORCE CODE 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 to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: CINDY ~ STP~tITIFF ~7 CINDY L. STP~AITIFF, Plaintiff ROBERT T. STRAITIFF, Defendant 3 o : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-460 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSEI~T A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 28, 2002. 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. I consent to the entry of a final Decree in 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. Section 4904 relating to unsworn falsification to authorities. Dated: ROBERT T. STRAITIFF ~ CINDY L. STP~AITIFF, Plaintiff ROBERT T. STP~AITIFF, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-460 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSEI~T A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 28, 2002. 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. I consent to the entry of a final Decree in 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. Section 4904 relating to unsworn falsification to authorities. Dated: CINDY L. STRAITIFF, : Plaintiff : : v : : ROBERT T. STRAITIFF, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-460 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE OF TRANSMIT RECORD To the Prothonotary: Transmit the recdrd, together with the following information, to the court for entry of a divorce decree: 3e Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date of filing and manner of service of the complaint: a. Date of filing of Complaint: January 28, 2002 b. Manner of service of Complaint: Certified Mail Restricted Delivery c. Date of Service of Complaint: February 6, 2002 Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a. Plaintiff: May 6, 2002 b. Defendant: May 7, 2002 Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code and date of service of the Plaintiff's 3301 (d) affidavit upon the Defendant: a. Date of execution: N/A b. Date of filing: N/A c. Date of service: N/A Related claims pending: None Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) (1) (i) of the Divorce Code: a. Date of Service: N/A b. Manner of Service: N/A OR Date Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: a. Plaintiff's Waiver: May 10, 2002 b. Defendant's Waiver: May 10, 2002 ;3 ~L~-~FF, ESQUkR~ ~dle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 IN The COURT OF COMMON PLEAS OFCUMBERL~NDCOUNTY STATE OF CINDY L. STRAITIFF, Plaintiff VERSUS Defendant PENNA. NO. 02-460 CIVIL TERM Decree IN DIVORCE AND n OW, ~~__.L~' DECREED THAT ~, IT IS ORDERED AND , PLAINTIFF, AND ~©RRRT T. ~TRAITIFF , 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; None PROTHONOTARY CINDY L. STRAITIFF, Plaintiff v ROBERT T. STRAITIFF, Defendant : IN THE COURT OF C : CUMBERLAND COUN~ : : NO. 02-460 : : CIVIL ACTION - IJ : IN DIVORCE NOTICE OF ~L~CTION TO RET~ FORMER Notice is hereby given that the Plainti: captioned Divorce Action, hereby elects to retake her previous name of Cindy L. Wickard. This pursuant to the provisions of 54 P.S. §704. Signat~e (ma Signat~e (fo COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss: On the 14th day of June, 2002, before personally appeared Cindy L. Straitiff known to m whose name is subscribed to the within document that she executed the foregoing for the purpose Seal IN WITNESS WHEREOF, I have hereunto set my NO~ ~rO Guml~dand County ~MMON PLEAS OF pENNSYLVANIA if in the above ~nd hereafter use lection is made ried nam~ rmer name) a Notary Public, to be the person and acknowledged ~erein contained. hand and Notarial