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Home My WebLink About04-5383RICHARD L. MAURER, Plaintiff Vo MARY-ROSE FERDINAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. oq CIVIL ACTION - LAW IN 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 ann. ulment 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 or visitation of your children, fights important to you, including custody When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of matfiage counselors is available in rite Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. PRo/EF?T~/,Ui~EORTs~I~EA~ CLAIM FOR ALIMONY, I)IViSiON OF CLAIM ANY OF THEM. x ~-v, ~uu MAY LOSE THE RIGHT TO YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ON IF YOU DO NOT HAVE A LAWYE CE. · o OUT WHERE YOU CAN GET LEGAL ORTH BELOW TO i~IND HELP. CUMBE~D COUN'IT' B~IR ~iS. fOCi./1TiON 32 SO UTH BEDFORD C.,4RLISLE, P~I 17013 (717) 249-3166 OR (800)990-9108 RICI-L~RD L. MAURER, Plaintiff 5L'~RY-ROSE FERDINAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. O¢. ~.3 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE I. Plaintiffis Richard L. Maurer, who currenfly resides at 155 Paradise Park, New Bloomfield, Perry County, Pennsylvania. 2. Defendant is Mary-Rose Ferdinand, who currenfly resides at 21191Cupar Lane, Huntington Beach, California 92646. 3. The Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 23, 1999 at Las Vegas, Nevada· I7,OUNT I - DIVORce. 5. Paragraphs 1 through 4 of this Complaint axe incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since February 5, 2000, and continue to do so. 8. 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 such counseling. WI-I~ORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, AZOM ~ KUTULAK~S, L.L.P. DATE o south Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 I, RICHARD L. MAURER, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.; 4904 relating to unswom falsification to authorities. Uate/t Ca+ o ~/ RICHARD L. MAURER RICHARD L. MAURER, Plaintiff MARY-ROSE FERDINAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-5383 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) and 3301(d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. m~fil, certified, restricted delivery, postage prepaid, on November 19, 2004, at Carlisle, Pennsylw~nia, addressed as follows: Mary Rose Ferdinand 2212 Delaware, Apt. A Huntington, CA 92646 Return card acknowledging receipt on November 22, 2004, is attached as Exhibit "A". ABOM & KUTULAJ~IS, LLP Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 86914 Exhibit "A" RICHARD L. MAURER, Plaintiff MARY-ROSE FERDINAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-5383 CIVIL TERM CIVIL ACTION- LAW IN DWORCE NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(d) OF THE DIVORCE CODE TO: Mary-Rose Ferdinand You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the $3301(d) affidavit. Therefore, on January 19, 2005, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court ~n answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9.108 RICHARD L. MAURER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. : NO. 04-5383 CIVIL TERM MARY-ROSE FERDINAND, : CIVIL ACTION - LAW Defendant : IN DIVORCE COUNTER AFFIDAVIT UNDER .~ 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): [] (a) I do not oppose the entry of a divorce decree. [] (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): [] (i) The parties to this action have not lived separate and apart for a period of at least two years. [] (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. [] (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other irnportant rights. I understand that in addition to check (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 34904 relating to unsworn falsification to authorities. Date: MARY-ROSE FERDINAND 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 unswom falsification to authorities,. RICHARD L. iMLAURER RICHARD L. MAURER, Plaintiff MARY-ROSE FERDINAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-5383 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on February 5, 2000, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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 div~,rce 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. RICHARD L. MAURER RICHARD 1. MAURER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 04-5383 CIVIL TERM MARY-ROSE FERDINAND, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) and 3301(d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on November 19, 2004, at Carlisle, Pennsylvania, addressed as follows: Mary Rose Ferdinand 2212 Delaware, Apt. A Huntington, CA 92646 Return card acknowledging receipt on November 22, 2004, is attached as Exhibit "A". ABOM & KurULAKIS, LLP Date: 12IDL/DLt =) Kara W. Haggerty, s 36 South Hanover S et Carlisle, P A 17013 (717)249-0900 Attorney for Plaintiff J.D. No: 86914 . .~ lWlle " 2. 8I'ld 3. Al80 .......,Aele ... 4 ~ f\eaIlIcted DelIvery 18 deeIr8d. . M1t~ nem. 8I'ld 8ddnI88 onlhe__ _that... """ retum lhe ctRI to I'<l'l. . MIIlch lhI8 cai'd to the back of the rnaIIpIace, wen the flIlnIlt apace permfta. t. __to: o AgefII o O.D8tIoof~ (f Cl. JodollMly._<IlI-.It~1Ioln17 0 Yes WYES, _daIlWI!Y__C No ~~ \Judu1f.uuJJ 2212 ~I f)..,aI'A ~ CA- q2.~'I(, - -rJOii' - ~ '\-'t~tJ..s- O. l" i~~,_~ 8. ~l.W C~_ o ~od IJIoflIIUm ~ .....".... - C~_. Ca.o.o. ,.;:~rct.{d~r&rn1W) 7003 3110 0004 5769 8273 :4l'l.jo_?.ll~Ic.Return Receipt 1I.1....I.I.ll...I..II..I...I~~e'.. Exhibit "An ~ /1,0 -- Q ~~. -r~,'-1); (';\1.:1 '~:~l 'PC ';Z 3. .-\ ...,": "','. ....n ;', ,', r:,:l ('-) -' - RICHARD L. MAURER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 04-5383 CIVIL TERM MARY-ROSE FERDINAND, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground(s) for divorce: irretrievable breakdown under ~3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: November 22, 2004 3. Date of execution of the Affidavit required by ~3301(d) of the Divorce Code: December 12, 2004; Date of filing and service of the Plaintiff's affidavit upon the Respondent: December 20, 2004 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: December 20, 2004, by first class and certified mail. Respectfully submitted, ABOM & KUTULAKIS, L.L.P DATE 01125/05 ~~I~,r:~~ 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff ill #86914 ,..., ~ C.;::.r ,'-" <- ~;o'~: ...,,,- 1'V 0' ~ -i X-rl n'I~..: t,.., ."rtl_'_J' :;J~. ""~Cl :~i:.::':H :'-''-~ ?~) ";)h-~ :':~~ :~'3 , """'0 ~? \::J 0''' - RICHARD 1. MAURER, Plaintiff IN THE COURT OF COMMONPLl~l\S CUMBERLAND COUNTY, P A ,... I v. NO. 04-5383 CIVIL TERM r.~ (..I MARY-ROSE FERDINAND, Defendant CIVIL ACTION - LAW IN DIVORCE ,. NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(d) OF THE DIVORCE CODE TO: Mary-Rose Ferdinand You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the ~3301(d) affidavit. Therefore, on January 19,2005, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 RICHARD L. MAURER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 04-5383 CIVIL TERM MARY-ROSE FERDINAND, Defendant CIVIL ACTION - LAW IN DIVORCE COUNTER AFFIDAVIT UNDER ~ 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): o (a) I do not oppose the entry of a divorce decree. o (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): o (i) The parties to this action have not lived separate and apart for a period of at least two years. o (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): o (a) I do not wish to make any claims for economic relief. 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. o (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to check (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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: MARY-ROSE FERDINAND 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: J Z D.", { (J <../ '-"'"'7 3/, "V~' / If ./ /f/ 1"??2, ~-T- /', C' c-;::.,.....-:..... RICHARD L. MAURER CERTIFICATE OF SERVICE AND NOW, this 25th day of January, 2005, I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Transmit Record upon the Defendant by depositing, or causing to be deposited, same in the u.s. mail, postage prepaid, addressed as follows: Mary-Rose Ferdinand 2212 Delaware, Apt. A Huntingdon, CA 92646 Respectfully submitted, ABOM & KUTULAKIS, L.L.P DATE OI{Zf=l /05 Kara W. Haggerty, Esqu"r 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff ID #86914 "" r:.:::t :2';; <- :r" ;;;c: 1'.) en -0 -" ,-,) c::> 0" - . . . . . . . . . . . . . . . .. '+i :t< :+.:.t';+; . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. . . STATE OF . . . . . . . . . . . . . . . . . . . . . . . . . . . AND NOW, DECREED THAT AND ~ RICHARD L. MAURER, . . Plaintiff No. 04-5383 CIVIL . . . VERSUS . . ~ MARY ROSE FERDINAND, . ~ Defendant . . . . . DECREE IN DIVORCE f~" q ,).. .;;fIO:I)"c....,tIl . ,;tJc>{', IT IS ORDERED AND RICHARD L. MAURER PLAINTIFF, MARY-ROSE FERDINAND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . . . . . . THE COURT RETAINS JURISDICTION OF THE FOL.LOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . .;; '" }-i '~~~ '~ . . . . . . . . . . . . . . . . . . . . or'.... ~ / ... ~' , , . .... , .' /' - .. - - . . ,"'. ~.... ..'", , ,.l' ~.. ........: '" ... /;- ........... -,I "l "'JfF;..... C'-' ...... .... . . < . . . ".. ~ O,j t:: By T ? .....,.- ';'" .. '-- ~ ATTEST: o~- PROTHONOTARY .. . . . . .. '+' 'f.'++. :t;:t . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . .. . ~7Z /r'?W/ ~U'-. /X:;J C' . e r~h% frv;z 1lT~~1/ ;f,;(i{;7 ,/"'P ILl C. c