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Home My WebLink About04-4763JENNIFER L. YOHN, TODD M. YOHN, Plaintiff V. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.6y-47W CIVIL TERM IN DIVORCE 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 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 in the Office of the Prothonotary at: Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. 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. The Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle/ancf?ra 1'70013 L. Meilton ?? Attorney for Plaintiff TUCKER ARENSBERG, P.C. P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 JENNIFER L. YOHN, Plaintiff V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.OH- CIVIL TERM TODD M. YOHN, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Jennifer L. Yohn, an adult individual who is sui juris and resides at 405 Greenspring Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Todd M. Yohn, an adult individual who is sui juris and resides at 41 Wooded Run Drive, Dillsburg, Cumberland County, Pennsylvania. The present whereabouts of the Defendant, Todd M. Yohn, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 28, 2002, in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. TUCKER ARENSBERG, P.C. Sandr? i ton By:----IJ P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorney for Plaintiff 69982.1 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. ao ay ,?? / n ifer L. Yohn, ainti o w FL COMMONWEALTH OF PENNSYLVANIA COUNTY OF: DAUPHIN Commonwealth of Pennsylvania Pennsylvania State Constable Michael R Maugans (717) 5454448 SERVICE OF PROCESS Jennifer L. Yohn vs. DEFENDANT: NAMEaM ADDRESS r Todd M. Yohn 41 Wooded Run Dr L Dillsburg PA J Docket No.: 04-4763-Civil Date Filed: Ala Served upon Todd M. Yohn by handing a copy of Describe Document(s): (Person to be Served) Notice To Defend And Claim Rights -- Divorce tox ? I, 2eS?lff / (Person Actually Served) (Relationship) on / ?I?vLe ?/ , at /e' -F-r? .M., at Date) (Time) OU/ /,Yr er For Landlord/Tenant complaints: (Location) none of the above found, served by posting a copy of the complaint conspicuously on the premises on at , at M., (Location) Miles Traveled: /J7 10' (Signature) Michael P. Maugans- Constable AOPC 624-95 (Print Name and Title) C. N 5? Ti "IJ r i N ?rn r JENNIFER L. YOHN, Plaintiff V. TODD M. YOHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-4763 CIVIL TERM : IN DIVORCE PETITION TO WITHDRAW AS COUNSEL AND NOW comes James G. Morgan, Jr., Esquire, for the law firm of Tucker Arensberg, P.C. and hereby avers the following: 1. In or about May, 2004, Petitioner (through Sandra L. Meilton, Esquire) began performing legal services on behalf of Plaintiff. 2. Representation included the commencement of the within divorce action as well as representation of Plaintiff related to support and custody actions. 3. Recently, correspondence was forwarded to Plaintiff from Petitioner's office concerning Sandra Meilton's departure from Tucker Arensberg, P.C. effective November 6, 2006. No written response has been received from Plaintiff. 4. The last email communication from Plaintiff to Petitioner was in July, 2005. 5. Plaintiff is indebted financially to Petitioner's law firm for legal services performed on her behalf. 6. For the reasons set forth herein, Petitioner desires to sever the representation relationship with Plaintiff. Y1 R WHEREFORE, Petitioner respectfully requests that this Honorable Court grant permission to Sandra L. Meilton, Esquire, and the law firm of Tucker Arensberg, P.C. permission to withdraw as counsel for Plaintiff, Jennifer L. Yohn. Respectfully submitted, TUCKER ARENSBERG, P.C. 111 North Fr6Rt St et, P.O. Box 889 Harrisburg, PA f7fO8 PETITIONER CERTIFICATE OF SERVICE # J?'M AND NOW, this .,?247- day of , 2006, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, formerly of the law firm of Tucker Arensberg, P.C, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Mrs. Jennifer L. Yohn 405 Greenspring Road Newville, PA 17247 Penny V. Ayers, Esquire 17 E. Market Street York, PA 17401 r Gloria M. Rine c o o ?' : rn c co c7A DO IDEC 0 5 2006 P, i JENNIFER L. YOHN, Plaintiff V. TODD M. YOHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-4763 CIVIL TERM : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this Y" day of , 2006, upon consideration of the Petition to Withdraw as Counsel, a Rule is issued upon Plaintiff, Jennifer L. Yohn and Penny V. Ayers, Esquire, counsel for Defendant, to show cause why Sandra L. Meilton and TUCKER ARENSBERG, P.C., should not be granted leave to withdraw as counsel for Plaintiff in this case. RULE RETURNABLE Zo DAYS FROM THE DATE OF SERVICE. Service shall be accomplished by first class mail to Plaintiff and Defendant's counsel. BY THE COURT: 90 ,4 W'd 8- 310 90OZ AdViOiZ- 1-%lo'd -:l.Hl JO JENNIFER L. YOHN, Plaintiff TODD M. YOHN, V. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-4763 CIVIL TERM : IN DIVORCE PETITION TO MAKE RULE ABSOLUTE AND NOW, comes the Petitioner, James G. Morgan, Jr., for the firm of Tucker Arensberg, P.C., and petitions this Honorable Court as follows: 1. A certified copy of the Petition to Withdraw as Counsel filed by Petitioner in the above matter, along with a copy of the Rule entered by the Honorable Kevin A. Hess were served on Plaintiff and Defendant's counsel by letter dated December 12, 2006 by Sandra L. Meilton, Esquire, of Daley, Zucker & Gingrich. The certificates of mailing evidencing service are attached hereto. 2. Said Rule gave Plaintiff and Defendant's counsel twenty (20) days to respond after service. 3. More than twenty days has elapsed since service. Neither Plaintiff nor Defendant's counsel have responded to said Petition and Rule. WHEREFORE, Petitioner respectfully requests that this Honorable Court make the Rule absolute and allow Petitioner to withdraw as counsel for Plaintiff the above matter. TUCK!t ? ARENSBERC?j. P.C. By: James G. Mor ' Jr P. Box 889, Harrisburg, 17108 (7 7) 234-4121 P titiciner U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: f G, r 16 t One piece of ordinary mail addressed to: N•? ?? I/?GL? , X14 17(/7 PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER 4- 0 Received From: One piece of ordinary mail addressed to: PS Form 3817, January 2001 o ?m R /s 1 V ??A th :D C= 3M -M?(n MUD ZN -COO M :U J 0 2) m 0 :t z ?dS 9004 zt 036 6101• ? c o m X 00 oI I?1 ZN-CEO CD F) -i X> M m CERTIFICATE OF SERVICE AND NOW, this day of ??J i ,fly L'f 2007, I, Gloria M. Rine, f Paralegal to Sandra L. Meilton, Esquire, formerly of the law firm of Tucker Arensberg, P.C, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Mrs. Jennifer L. Yohn 405 Greenspring Road Newville, PA 17247 Penny V. Ayers, Esquire 17 E. Market Street York, PA 17401 f / Gloria M. Rine C ? '' ?_._ . = , _?, i -? ? .--s ;1- 4 , JAN 12 2001 Y/ 0;z y 1A JENNIFER L. YOHN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. :NO. 04-4763 CIVIL TERM TODD M. YOHN, Defendant : IN DIVORCE ORDER AND NOW, this 16" day of ?, 2007, upon consideration of the Petition to Make Rule Absolute, it is hereby ORDERED AND DECREED THAT Sandra L. Meilton, Esquire, and the law firm of Tucker Arensberg, P.C. shall be withdrawn as counsel for Plaintiff, Jennifer L. Yohn, in the above matter. BY THE COURT: Distribution: James G. Morgan, Jr., Esquire, P.O. Box 889, Harrisburg, PA 17108 Jennifer L. Yohn, 405 Greenspring Road, Newville, PA 17247 Penny V. Ayers, Esquire, 17 E. Market Street, York, PA 17401 ?? ?7-d? ?.. :? - _ ? - - , t. , . ?? t- , , ....,. ?-, - _' ?= ? . ?? _' '_ ? Y P? C (? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. YOHN NO. 04-4763 CMVIL TERM Plaintiff vs. CIVIL ACTION - LAW c ,v ° TODD M. YOHN `2 LT? r 17 4 L i r Defendant DIVORCE ? ?A rn AFFIDAVIT OF CONSENT C -v M z 1 A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 21 200; . , kwo 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the initial 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. 4. 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 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. §4904 relating to unsworn falsification to authorities. Date: 14111)0 1. Todd A. Yohn WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 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 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. Section 4904 relating to unsworn falsification to authorities. Date: 12,11-7101 Todd . Yohn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. YOHN NO. 04-4763 CIVIL TERM Plaintiff v C- y Z vs. CIVIL ACTION - LAW 65 `r. cy, TODD M. YOHN Defendant DIVORCE 5; C AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 21, 2009 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the and service of the initial Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the o a M C"3 ? ?:. r„_ _ )> C decW,e. C3 4. 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 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. §4904 relating to unsworn falsification to authorities. Date: !2-- ('3 Jennif r L. Yohn i WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 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. Date: 1 f - w9 t, , t , ?-? -1 k Jenni r . Yohn JENNIFER L. YOHN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION TODD M. YOHN NO 04-4763 CIVIL TERM ' n rs PRAECIPE TO TRANSMIT RECORD' - ,r c;0 rn t To the Prothonotary:F to Transmit the record, together with the following information to the court for entry of a dice decree: 1. Ground for divorce: C? Irretrievable breakdown under 3301 (c) (Strike out inapplicable section) 2. Date and manner of service of the complaint: Service of process October 20, 2004 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: byplaintiff 12/18/09 by defendant 12/17/09 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 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: b. Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: 1 / 6 / 10 Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: 1/6/10 1 Attpmey for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER L. YOHN V. TODD M. YOHN : NO. 04-4763 CIVIL TERM DIVORCE DECREE AND NOW, 1 ° , it is ordered and decreed that JENNIFER L. YOHN plaintiff, and TODD M. YOHN bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, Attest J Proth notary ? - a -moo ??,? ??u? ?' d? ?? Q?????,