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HomeMy WebLinkAbout04-4985 PHILLIP A. ALLEMAN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. NO.(:j-l - i./qPS CIVIL TERM WEN DEE ALLEMAN, Defendant 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 32 South Bedford Street Carlisle, PA ~;;(c::n1~ ~ S~~~L. Meilton ' ~- Attorney for Plaintiff TUCKER ARENSBERG, P.C. P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 .0 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PHILLIP A. ALLEMAN, v. NO. C:J./- 4 c:;.es CIVIL TERM WEN DEE ALLEMAN, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Phillip A. Alleman, an adult individual who is sui juris and resides at 4181 Elk Court, #109, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Wendee Alleman, an adult individual who is sui juris and resides at R.D. 4, Box 4616, Duncannon Perry County, Pennsylvania. The present whereabouts of the Defendant, Wendee Alleman, 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 May 23, 1998 in Newport, 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. By: I 0A(/X~ ~ L. Mei~on P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorney for Plaintiff 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. Dated: ?-J.l-D'1 Phill~~l~Plaintiff 71814.1 ~ ~ -&Q.. ""- (, r-,:j ..c c c:-, c: , C> (~l -'-~ . _.._..1 ~ ~ err ~ i ~ f' 0 , C> ~ ()C ~ -,-;.. r-) " , lI\ ()' "." r--':: .. -F -- COMMONWEALTH OF PENNSYLVANIA COUNTY OF: DAUPHIN Commonwealth of Pennsylvani,! Pennsylvania State Constable SERVICE OF PROCESS If/ / l L /7 /I, /J LL E /VIAll DEFENDANT: r \Ai t ,lJJ G. E VS. NAME and ADDRESS flLL C 1111 AI I Michael P. Maugans (717) 545-4448 L Docket No.: Date Filed: dif-l.f~F~ CIVIL 1f1l..#J ..J aJ&t_ ~ Served upon Describe Document(s): ]J/y"f{CE 7h7E~5 ~ A&llc E -r; fit f~N') tlf NflE ~ II iLf Mil /)( (Person to be Served) , by handing a copy of /J"l}) (L/11 /11 ~I C #/5 lOX ( Al~fL,cfJll/l1 A11a4 ;.~ //11 It 1 (Date) Sc:/fl (Relationship) on I at J:.fS' (Time) ? , .M., at Otic IJ/!~(L(ff J,j I f\ l..P J 51 fL(}/J,(' IIIlKf.ll$t1f(t" c/J;/ hilt L HIlti.~/fZUfi.{1 ?11 (Location) For LandlordlTenant complaints: Since none of the above found, served by posting a copy of the complaint conspicuously on the premises on , at .M., (Date) (Time) at (Location) ~~2~~~ Michael P. Maugans- ~ble (Print Name and Title) Miles Traveled: AOPC 624-95 (';. " , '. "",) 1/. ~\::- r :---1 rC,.1 r ("") i I '\ ,. ; C , ....~~ ) ; i"."'l c: PHILLIP A. ALLEMAN, Plaintiff v. : IN THE COUI~T OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-4985 CIVIL TERM : IN DIVORCE WENDEE ALLEMAN, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c:) of the Divorce Code was filed on October 1, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: S-//-,;?tW5 ~d,~ Phillip A. Alleman, Piaintiff '* .:::;l..." --';\?:. (' ,'(1:---' 1l.<Z '::-:\9, ~..,'-..S;~ ';%..'0" ~ .~ .;z '?-. -7' .....,,:,', ,-\-.., ~ ~ ~ or ~ '" \'-~ --- - \!L -:-"':::;', ,. '";"'1.'-" ~~ --0 -::;;. ...- " ~ v. : IN THE COUI~T OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-4985 CIVIL TERM : IN DIVORCE PHILLIP A. ALLEMAN, Plaintiff WENDEE ALLEMAN, Defendant WAIVER OF NOTICE OF INTENTION T'O REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 CtJnceming 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: g, /1,;).Q05 -dI4./~ Phillip A. Alleman, 'Plaintiff o ~' ....> ~ E: G-:> \1' N .f;" -0 ~" --",.~ o -n s:! rn~ -ots ~o "l (:io :'f_:~{ ;.}C) M~,..rn o "-' ~ C> N PHILLIP A. ALLEMAN, Plaintiff v. : IN THE COUHT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-4985 CIVIL TERM : IN DIVORCE WENDEE ALLEMAN, Defendant AFFIDAVIT OF CONSEN': 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 1, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 4. I understand that I may lose rights concerningl alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: 8/11/05 {~d1l rI afJMltuL Wendee Alleman, Defendant n (;:. ..,.. ..O\-:.~ \-::.':(l -;:':' ~ ~ ~ <.;~) 1') ~ ../; r::-'. \ Q, ie _(1("(' --,\:;1 (~ )/~) -;-':-"::r~ (s~ ;::;:~ s. c~ -0 -~" - o I'" - PHILLIP A. ALLEMAN, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-4985 CIVIL TERM : IN DIVORCE WENDEE ALLEMAN, Defendant WAIVER OF NOTICE OF INTENTION 1"0 REQUEST ENTRY OF A DIVORCE DECREE UNDER lSECTION 3301(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 divomed 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 penaltiell of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 8/11/05 ~Jr/aJiMrM Wendee Alleman, Defendant ~ <'fJ. ~ c:;, u ~ Q, ~e -o~ --9~, \.].:s~' .r", -"\\ ~")6 ~, (;."~{'<' .,..,.'" -"0 :.>>- ~ ~~ .- .' ~ PHILIP A. ALLEMAN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. WENDEE ALLEMAN CIVIL DIVISION 04-4985 CIVIL TERM NO. PRAECIPE TO TRANSMIT FlECORD 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 93301 (c) ~~ (Strike out inapplicable section). 2. Date and manner of service of the complaint: December 10, 2004, personal service. See Service of Process filed on 12/15/04. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent requir€'d by 93301 (c) of the Divorce Code: by plaintiff ; by defendant 8/11/05 (b) (1) Date of execution of the affidavit required by 93301 (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 93301 (c) Divorce was filed with the Prothonotary: 8/24/05 (mailed 8/23/05) Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: 8/24/05 (mailed 8/23/05) ~A~~~~~~ \ ~ -::J'.';, L!.~1.\' " {(", :? ,.., g; GJ" 2:: e;, r-.) J;:" -0 -- ...- ~ -' :r--r> rne -11\"r'1 -\}y ~~), () .,~:,~ ~-r, 1 "",.., ~J (~; >".,-f"i\ ~ ~ - o rv , " . . , , . . . . . . . , , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~. . . . . . ... . . . . :to'" :+'<f."';f. . ... .. . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PHILLIP A. ALLEMAN VERSUS WENDEE ALLEMAN AND NOW, PENNA. No. 04-4985 CIVIL TERM DECREE IN DIVORCE tk;_v :u' , ~o s-;- IT IS ORDERED AND PHILLIP A. ALLEMAN , PLAINTIFF, DECREED THAT AND WENDEE ALLEMAN , 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; . . . . HIII€ BYTHECO~R~d f~, PROTHONOTARY :f:;+''f.;fO'j.; Of :+;t; :t;'f.'f. 'f. 'f.'" :t;+::f.:+' 'lO,.,;+::f:+::f. 'f.;+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . ,~ ~ ~ r::fi?ff., ~ p ?-~ 14?/'?J YJe.'b Sv' -e'o .. '~+ .' ... '- ' y,... . #, ..' --- - ~