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Home My WebLink About05-1025 DONALD R. SPINCKEN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. oS- - fC>~S (2'(/ ~ CI'UL"1 THERESA M. BEHRENS-SPINCKEN, 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: CUMBERLAND COUNTY COURTHOUSE ICOURTHOUSESOUARE CARLISLE, PENNSYLVANIA 17013 IFYOUDO NOT WISH TO 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 DONALD R. SPINCKEN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. Df: - 10;;'$ C; u 1 't- 82...l THERESA M. BEHRENS-SPINCKEN, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 330J(c) AND 330J(d) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, DONALD R. SPINCKEN, and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth: I. Plaintiff is Donald R. Spincken who currently resides at 6280 Carlisle Pike, Lot 520, Mechanicsburg, Cumberland County, Pennsylvania 17050 since April 2003. 2. Defendant is Theresa M. Behrens-Spincken who currently resides at 73 Roop Street, Apt. 1, Highspire, Dauphin County, Pennsylvania 17034 since September 2002. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 4, 1998 m Dauphin County, Pennsylvania. 5. Plaintiff has been advised of the availability of counseling and that he may have the right to request the Court require the parties to participate in counseling. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Defendant is not a member of the Armed Services of the United States or any of its allies. 9. Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. Date ;}-/6- 05 Respectfully submitted, ','') ') . i. " I i - l ecJf:L___ Donald R. Spincken, Plam . se 6280 Carlisle Pike, Lot 520 Mechanicsburg, PA 17050 (717) 790-9036 2 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. Section 4904, relating to unsworn falsification to authorities. Date (), -/ :j"-05 ~a~.' /~, , DoDard R. Spincken --.-... ..fA. -r:J ~ - \t-\? _ \) VI ..- "<z1 0- - \ t~f 1f- -.J:::.- 1'-':' ,~.."' ", :';', ~.' ,) I ~,,_. ," '~ -- (..0 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-1025 IN DIVORCE DONALD R. SPINCKEN, v. THERESA M. BEHRENS-SPINCKEN, Defendant AFFIDAVIT OF SERVICE AND NOW, this 9~day of March, 2005, personally appeared before me, a Notary Public in and for the State and County aforementioned, Nancy E. Roach, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce in the above-referenced divorce action was served on the Defendant on March 4, 2005 by Certified Mail No. 7000 1670001285555949, return receipt requested, restricted delivery, as evidenced by the return receipt card attached hereto and made a part hereof. / N~~y ~ ~;9h -:7 . . / /1 ~/ 7'1' c . / .. /__________ ) 1../' Sworn to and sl~~,Ftibed to before me this 'Y~ day of __j)'1!\f'C ~ -,2005. '--' I (z. I U c_ f' (;., .J..oV ~otary Public cOMMONWEi\Uj' OF PENNSYLVANIA Notaliat Seal Marcia E. Gales. Notary Public City Of Harrisburg. Dauphin County My Commission Expires Aug. 15.2007 Member. Penn$Vlva..ia -As::;cciation Of Notaries Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: 7if,A?5A ;1/. /3?rI/?~",J:: /'3 ^{lD/'5TKf~ A/rT 1!1,~.dS/'/~!' ; S/I;"xt<f / ~EsiR'(CTE DEl\VERY _.--'~ Is delivery address different from ite 1? If YES, enter delivery address below: 3. Service Type ,.Or( Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) ~Yes 2. Article Number (Copy ;r~m sen/ice label) 7oot'J /&7i> tJ,?!/d'. t'?;,-S-S- ,"1'1'11 PS Form 3811, July 1999 Domestic Return Receipt 102595.QQ-M.Q9S2 DONALD R. SPINCKEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1025 THERESA M. BEHRENS-SPINCKEN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 330HC) OF THE DIVORCE CODE (I) A Complaint in Divorce under Section 330I(c) of the Divorce Code was filed on March I, 2005. (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. (3) I consent to the entry of a fmal decree of divorce without formal notice of the intention to request entry of a divorce decree. (4) I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if! do not claim them before a divorce is granted. (5) 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 I 8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date xl f.,LuJ 146 )' V ,.f ~>~(~l'^A_W! &L1J1/1'- ~Yh;';L Theresa M. Behrens-Spincken Defendant Q ~,;: ...., <'" c:;,?> GJ' s~ - N , , >; ~ :2. - - Q. ~--r. n1p -rJ f'; :9'( (._) ( ,1 ::f. :h '~.';~'~l?j .:~' ;; =-< <.11 o - DONALD R. SPINCKEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1025 THERESA M. BEHRENS-SPINCKEN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) OF THE DIVORCE CODE (1) A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March I, 2005. (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. (3) I consent to the entry of a fmal decree of divorce without formal notice of the intention to request entry of a divorce decree. (4) I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if! do not claim them before a divorce is granted. (5) I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree wiIl 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. Daf<1"~Q I C"J Z<lo.5 d?xAa~~cA~M nald R. Spincken " Plaintiff pro se (') S~; ..'" r--' = = .:;:.>"1 o ." -l X-n It'c.: -nl" '.""Y --..) " .~~ ~l~;l~' 0' ..--\ \:.>- ~~ '- C..::.... N Ul c:: - DONALD R. SPINCKEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1025 THERESA M. BEHRENS-SPINCKEN, Defendant CIVIL ACTION - LAW 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. Ground for divorce: 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery on March 4,2005. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on June 16,2005 and by Defendant on June 10,2005. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: June 21, 2005; Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: June 21,2005. ~ a 'r-th / . Date v~1 J, J &Q5 :.:]' r--) ~~~ C"..Tl (- , t-~-- o -n :;J I~::l~] 12] !"\,) C:> --r: ,....,) c.n . . . . . . . " . . . . . . . . . ~'f.;+: :+' . . . . . '+; ;f.:+.:f. . . . ;f.:+; ,.,:t:'f.'t;:t; +.:+: 'l':t: :f. :+.:+.:+ .. +: ~ Of +. +. +. + ;+: :f 'f. +0+ . . . . . . . IN THE COURT OF COMMON PLEAS . OFCUMBERLANDCOUNTY . . . . . . . . . . . . . . . . . . . . PENNA. STATE OF DONALD R. SPINCKEN No. 05-1025 VERSUS THERESA M. BEHRENS-SPINCKEN . . . . . DECREE IN DIVORCE AND NOW, 2005 , tT IS ORDERED AND ~7 DECREED THAT Donald R. pincken , PLAINTIFF, . . . . . . Theresa M. Behrens-Spincken AND , 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; None. /<7<:/ / , / / . . . . . . . . . . . . . . 'f';+:'I''''''' "" J. . . . . . . . . . . . Of +.;f Of +. ++ PROTHONOTARY '+''l'+'I'''' . .. Of+."+, +.'" +: .. :t:+ "" :+>" +. +. . 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