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HomeMy WebLinkAbout05-0547 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. No.6')' 5 47 (J~t. LISA M. STEFFEN, 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 armulment 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 grounds 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 Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 WEJGL-E & ASSOCIATES, Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHrpPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. LISA M. STEFFEN, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 330Hc) OR 330Hd) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, Gary D. Steffen, by and through his attorneys, Weigle & Associates, P.e., and Jerry A. Weigle, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Gary D. Steffen, is an adult individual presently residing at 1466 Woods Road, Lot #33, Shippensburg, Franklin County, Pennsylvania 17257, since July 2004. 2. Defendant, Lisa M. Steffen, is an adult individual presently residing at 13 Koser Lane, Shippensburg, Cumberland County, Pennsylvania 17257, since December 2004. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on April 1, 1995, in Hagerstown, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since June 2003. WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KlNG STREET - SHIPPENSBURG, PA 17257-1397 9, The Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATE~S' P C, ( BL- Or', Je A. We' Ie, Esquire At orney for intiff Attorney ID #71577 126 East King Street Shippensburg, P A 17257 Telephone 717-532-7388 WEiGLE & ASSOCIATES. p.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SH1PPENSBURG. PA 17257-1397 . VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S, S4904, relating to unsworn falsification to authorities. Dated: / ~ ,/ S- ~ 0 5- WEIGLE & ASSOCIATES. p.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~ r~ "- -, ~ L - 0> ---J 02:) .-' ~~:} 1";~'~ GJ' () -n ~p ~ T___ ,.S\ CJ , -1 C..- .'":,'.-,-\ ::,.~~, j"'\\ r:-'~\ ;;...... r(~ <;:: > (~) -~~ :~.~. ~;;~ - '~",:\,{.~',~ t~~ . ,Jj} f"~ :',2- 0... '-I c-' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. 05-547 Civil LISA M. STEFFEN, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND Patricia A. Frey, being duly sworn according to law, deposes and says that on February 4, 2005, a true and attested copy of Complaint in Divorce with Notice to Defend and Claim Rights was served upon the Defendant, Lisa M. Steffen. Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Lisa M, Steffen 13 Koser Lane Shippensburg, P A 17257 The return receipt signed by the Defendant is evidem:e of delivery to her and is attached hereto as "Exhibit A," l2fi,c<~ ;9 ~ Patricia A, Frey- Sworn to and subscribed before me this 9th day of February, 2005. lP,J;tl~~1,. 7~ " ,.Nma:y,public NOTNlW. SIAl. PA1IIO\ l TOME Nok1ly NlIc ~~ My COl.""....l.. fxPfm./un 7. 2001 ..:",< '''.'' .::~Jy..,-';~ :.-/ '-'. ~..." '""(/ ",-:,~ , r'_ ',' ,....-." ."...... WEIG-LE '& ASSOCIATES. PC - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 "1" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. 05-547 Civil LISA M. STEFFEN, Defendant IN DIVORCE PROOF OF SERVICE US Po<,tdl Sl !\iILl CERTIFIED MAIL RECEIPT (Domestic Mall Only No Insorance Coverage Prov/(!t>r11 Ltl II'"' ru .-'I Total post&ge & Fees roo o S 3.50 $ '8'. I~ ,---"" "" ">/--~\' l;') / PO?tma?k;r:. \ ; ~ri \'. n'~1 cc_ ~ r:,,\ ,: '(;;. ""j ) fT'1 /:..\ ' Postage $ O~o\::>-tl ~ \::sE" ~rt\1ied Fee IT1 o '0 o Return Receipt Fee (Endorsement RequIred) Restricted Delivery fee (Endorsement Required) o IT1 U'1 SentTo .-'I ....mr::l....k.~.~~....~,__~.-f.ff.en..----..m.....----...----........ Cl Stre"t, Apt. No.; or PO Box No. g ..\.~..~~~c...__.kQ,rLe........m......__""""__"'''__''''''__'''__''...-- t"'- CI Sta~e,ZIP+4 1'1~1 ,~\r~, '........._ ,- . Attach this card to the back of the mailpiece. or on the front if space permits. 1. Article Addressed to: . Received by ( Printed Name) D. Is del1ivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No M(~ ,L~A.. M. S-kPf'ef) 13 Koser' la.ne -:')n'ppen'i>bu.fl) pR ''1a51 3. Service Type l:id' Cel'tlfred Mall b Registered o Insured Mail o Express Mail 1!J Return Receipt for Merchandise o C.O.D. 4. Restric:ted Delivery? (Extra Fee) J( Yes 2. Article Number rr"'nsferfromservicolabel) '70015- l530- 000,3- 5Ll03- 1d.95 PS Form 3811, August 2001 Domestic Return Receipt 102595-Q2-M-154Q I!':XHIBIT "A" WEIGLE & AS50ClATES. Pc. _ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 ~, r" C) c.: r .,~I (J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. 05-547 Civil LISA M. STEFFEN, Defendant IN DIVORCE 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. Grounds for divorce: irretrievable breakdown under S 3301(c) of the Divorce Code. 2, Date and manner of service of the complaint: February 4, 2005, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. 3, Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by Plaintiff, May 18,2005; by Defendant May 15,2005. 4. Related claims pending: None 5. Date Plaintiffs Waiver in S 3301(c) Divorce was filed with the prothonotary: May 20, 2005 Date Defendant's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: May 20, 2005 Jerr A. Weig Esquire Attorney for Plaintiff Attorney ID #01624 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 Ii .,"" - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. 05-547 Civil LISA M. STEFFEN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on January 31,2005, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 made subject to the penalties of 18 Pa, C,S, S 4904 relating to unsworn falsification to authorities, Dated: 5-/o-C!) WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 -- -:. - - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. 05-547 Civil LISA M. STEFFEN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 3301(d) OF THE DIVORCE CODE I. 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! 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, S 4904 relating to unsworn falsification to authorities, Dated: S- /5'- 0--> D, Steffen, Plaintiff WEIGLE & ASSOCIATES, PC - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~, - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. 05-547 Civil LISA M. STEFFEN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on January 31, 2005, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry ofa 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 made subject to the penalties of 18 Pa, C.S. 9 4904 relating to unsworn falsification to authorities. Dated: 5 - ) 5~ ()5 ;i:sm //J5;!z .&/0 10 sa M, Steffen, Defend~77 WEIGLE & ASSOC!ATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 ~ ' / - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARY D. STEFFEN, Plaintiff CIVIL ACTION - LAW v. NO. 05-547 Civil LISA M. STEFFEN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 3301(d) OF THE DIVORCE CODE I, 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! 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, 9 4904 relating to unsworn falsification to authorities, s c:. Dated: - ) 5 - 0,) i;' j&;"~' ~ .' -, , / ' / " ' "., A / iLYLi 1;1 "'~. i' (.. '-Llsa M, Steffen, Defendant WEIGLE & ASSOCIATES. P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBLJRG. PA 17257-1397 IOf~ ( -.,~ ..._1 -.) ,".' ",'Ii"':+: . . . . . . . . . . . . . . . . :+:;1;";'" "':+: :+:'" ;Ii:+: . :+: ;!iiti:+: "':+::+: "':+: "':+: :+:'" :+::+: :+::+: "':+: .. "':+::t.:+: . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. GARY D. STEFFEN No. 05-547 Plaintiff . . . ~ VERSUS . . : LISA M. STEFFEN . . . Defendant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . DECREE IN DIVORCE AND NOW, ~ ?.~ , IT IS ORDERED AND 2005 DECREED THAT GARY D. STEFFEN , PLAINTIFF, AND LISA M. STEFFEN , 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 F'OR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE ~ BY T . . . . . :t;e+;:+: :+:e+;:+: :+:e+; . . . .. .. . . :+::+: iti Of,.., . . . 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