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,..,
.
.
.
J,
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
. .
~l
_;}P ,'Z., /'?jJ~~?,?Vt! "rJ;t, )i/ he ;.;
fr 1- /flVJ4f td(l,;?f'1~7 _yJ)l ('5-
. I.. ...
-