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HomeMy WebLinkAbout05-1288 1\ " In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) No. 0-)' /';'<:(,1 vs. ) of200S ) DENISE J. ETTINGER, ) CIVIL TERM 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 divorce is indignities or irretrievable breakdown of the marriage. you may request marriage counscling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 A T 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 II. In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) vs. ) No. of 2005 ) DENISE J. ETTINGER, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Comi of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office. 13 North Hanover Street, Carlisle. Pennsylvania. You are advised that this list is kept as a convenicnce to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. .1. Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill. PA 170 II (717) 731-9509 In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) vs. ) No. of 2005 ) DENISE .J. ETTINGER, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plainti ff, by his attorney Michael S. Travis, respectfully represents: I. Plaintiff is Roy C. Ettinger, Sr., who resides at 341 Maple Lane, Carlisle, Cumberland County, Pennsylvania, 17013, since April, 2004. 2. Defendant is Denise J. Ettinger, who resides at 77 Big Spring Terrace, Newville, Cumberland County, Pennsylvania, 17241, since March, 2002. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pcnnsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 22, 1992, at Perry County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequcnt time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) ycars. 8. Plaintiff has been advised that counseling is available and that Plaintiff may havc the right to request that the court require the parties to participate in counseling. I. 9. Neither party is in the Military Service in the United States. 10. PlaintltT requests the court to enter a decree of divorce. false statements herein are made subject to the penalties of 18 Pa. C.S. Ii 4904, relating to I verify that the statements made in this Complaint are true and correct. I understand that unsworn falsification to authorities. Date: 3/10 (or d}4Y =ttinger, Sr., Plaintiff . hael S. Travis Attorney for Plaintiff J.D. # 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 ~(\ ~ ~ '- ~ ~. '-... ~ (J \.J\ t, .., 'N '- () ~ "'i\ ~ f".:) C",' i '.:.~'. ;:;:..J"'\ -,.,.. -"'" S':,':',,) o 41 _rJ -n r\"ll-'-"-"~ .T',i~n ".;..~ ',""-' ~' 'T' I" ,I _'. S,,' :::h. _J -~l /', ::;1 \0 w In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) vs. ) No. 05-1288 ) DENISE J. ETTINGER, ) CIVIL TERM Defendant. ) IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. ". \ , 1\ t J/ U:Jf "i / lDenise J. Ettinger /' address: 77 Big Spring Terrfc'e Newville, PA 17241 Date(S/q~5 ;../] (1 ) i .-j-'- ~~"C;-'r"r\,"! 'f'-~ D;)."'.~..:)\.'.'..;;I..-l .0.. ....J.. .., "" '"'I 3!d!/O?J\' 0 ...., = 0 C .::;:l -0 .,.- <J' ~h' ::u: ~:o '~.;. \ r: : :- 2.:'"' :;0 fl1,* zro, N -;jm .u.,')., :g~ ~:':- w c-:'. ~_""IC <'- :r::.ti ;?:n. -,. b~-\ ~ C)-f-.~ ;p " ~M c:: Z ~ :) N .~ v:J ..-< . , In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) vs. ) No. 05-1288 ) DENISE J. ETTINGER, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must Ie a cuunlcr-at1idavil within l"enty days after this atlidavit has been served on tou or the statements will be admitted: I I I AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on or before December. 1995l and hav to live separate and apart for a period of at least two years. I I I 2. The marriage is irretrievably broken. continued 3. I understand that I may losc rights concerning alimony, division fproper '. lawyer's fees or expenses if! do not claim them before a divorcc is granted. I verify that the statements made in this affidavit are true and corree. I un del stand that false statements herein are made subject to thc penalties of 18 Pa.C.S. S 49 4 rclatin to unsworn falsification to authorities. Date: ,3/;Z rj O!>- . . Ettinger, Sr., Plaintiff i~'~j ,J~I'Ji "iL~~ki.ll:Q.~ Jr. vs. In the Court of Common Pleas of Cumberland County, Pennsylvania ) ) ) ) ) Defendant. ) Plaintiff, ROY C. ETTINGER, SR., No. 05-1288 DENISE J. ETTINGER, CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER S 3301(d) OF THE DIVORCE CODE 1, Check either (a) or (b): '..J (a) I do not oppose the entry of a divorce decree. ..J (b) I oppose the entry ofa divorce decrec because (check (i), (ii) or both): o (i) The parties to this action have not lived separate and, part for period of at least two years. o (ii) The marriage is not irretrievably broken. 2. Check eithcr (a) or (b): o (a) I do not wish to make any claims for economic relief. I under tand that I may losc rights concerning alimony, division of property, lawyer's fees or expenses if do not claim them before a divorce is granted. o (b) I wish to claim economic relief which may include alimony, IVISlon 0 property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file II of mv eonomie elaims with the prothonotary in writing and serve them on thc other party. If! Jail to do so belorc the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce ecree may be entered without further delay. I verify that the statements made in this counter-affidavit are true aJ d correct I understand that false statements herein are made subject to the penalties 01 18 Pa. c.,'. S 4904 relating to unsworn falsification to authorities. I I Denise .T. Ettinger, De~endant - ___ I NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECON RELlEF, YOlJ SHOULD NOT FILE THIS COlJNTER-AFFIDA YlT Date: IVORCE lIC In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) VS. ) No. 05-1288 ) DENISE .1. ETTJNGER, ) CIVIL TERM Defendant. ) IN DIVORCE CERTIFICA TE OF SER VICE I, Michael S. Travis, certify that I have this day served a true and cor ect copy r the Affidavit under Section 3301(d) of the Divorce Code by first class maiL po tage prep id. on the following person(s), addressed as follows: Denise J. Ettinger 77 Big Spring Terrace Newville,PA 17241 Date: J- .;2";. 05 ~..-/~ J?y ~ ~ . ichael S. Tra 'IS II> No. 77399 3904 Trindle oad Camp HilL PA 17011 (717) 731-950 Attorney ror P aintill -------/ , . -, , ,. ~-". ' -' -.,..,. (.,'; ~) <.. ,-, ~ In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) vs. ) No. 05-1288 ) DENISE J. ETTINGER, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF S 3301(d) DIVORCE DECREE TO: Denise J. Ettinger 77 Big Spring Terrace Newville. P A 17241 Y Oll have been sued in an action for divorce. Y Oll have failed to answer the complaint or tile a counter-affidavit to the S 330] (d) affidavit. Therefore. on or after May 10.2005. the other party can request the court to enter a final decree in divorce. Ifyoll do not file with the prothonotary of the cOUJi 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: YOlllllust do so by the above date or the court may grant the divorce and you will lose forever the right to ask Ii)!" economic relief. The filing of the forlll 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 HELl'. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle. P A 17013 (717) 249-3166 vs. In the Court of Common Pleas of Cumberland County, Pennsylvania ) ) ) ) ) Defendant. ) Plaintiff, ROY C. ETTINGER, SR., No. 05-1288 DENISE J. ETTINGER, CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER S 3301(d) OF THE DIVORCE CODE I. 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 [ may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 checking (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!ntention to Request Divorce Decree, the divorce decree may be entered without further delay. 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. S 4904 relating to unsworn falsification to authorities. Date: Denise J. Ettinger, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) vs. ) No. 05-1288 ) DENISE J. ETTINGER, ) CIVIL TERM Defendant. ) IN DIVORCE CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy oCthe foregoing document by first class mail, postage prepaid, on the following person(s). addressed as follows: Denise J. Ettinger 77 Big Spring Terrace Newville, PA 17241 Date: L/_ / q. 0-5 Michael S. Travis II> No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 Attorney for Plaintiff (] t::"^--'~ '0\ ::",-~ l;;\ .--\ <;t; ::;,_, - .....0 , "'F-; {}\ - , Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill. PA 170 II (717) 73 1-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) VS. ) No. 05-1288 ) DENISE J. ETTINGER, ) CIVIL TERM 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. Ground for divorce: irretrievable breakdown under Ii 330 I (d)( I) of the Divorce Code. 2. Date and manner of service of the complaint: Complaint was accepted for service by the Defendant on March 19,2005, a copy of which was tiled with the Court on March 23. 2005. 3. Date of execution of the affidavit of consent required by Ii 3301 (d) of the Di voree Code: by Plaintiff 011 March 25. 2005; (b) Date of filing and service of plaintiffs atTidavij upon the respondent: March 29, 2005 (tiled), March 29, 2005 (servcd) 4. Related claims pending: No claims wcre raised. 5. Date and manner of service of the notice of intention to tile praecipe to transmit record, a copy of which was filed April 19, 2005: Aprill9, 2 :. US Majl lirst class postage prepaid. ~ Date: :J _11_ 0 5'" , In the Court of Common Pleas of Cumberland County, Pennsylvania ROY C. ETTINGER, SR., ) Plaintiff, ) vs. ) No. 05-1288 ) DENISE J. ETTINGER, ) CIVIL TERM Defendant. ) IN DIVORCE CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document was served on the below persons by first class U.S. Mail, postage prepaid, or the means specified: Denise .J. Ettinger 77 Big Spring Terrace Newville. PA ]7241 / , Date: 5',//.C..'J Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 ~_"l (~?... '~) "I' '.:.:.01 ~~ :~< -.- -- ~- :t~_.:'. ~''l.... ~;- ,. J~ t<) ,.;:+::+:+:+:+:+:+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f:+; ;+;:+ :+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+ :+:+::+:+:+:+:+:+:f.:+:+:+:+:+:f. :++:f.+:f.:+:+:++:+:f.:+:f.+:+ +:+::+:+:+:+++:+:+::+:+:+++~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+::f. :+ :+::+::+:+:+:+::+::+::+::+::+:+:+: :+:+:+::+:+::+:+::+:+::+:+::+:? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. STATE OF ROY C. EITINGER. SR.. No. 05 - 1288 Plaintiff, VERSUS DENISE J. EITINGER, Defendant. DECREE IN DIVORCE ,~ AND NOW,~ 11 ~, IT IS ORDERED AND DECREED THAT Roy C. Ettinger, Sr. , PLAINTIFF, Denise J. Ettinger , DEFENDANT, AND 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. ~,I'~" ATTEST: . p OTHONOTARY .. .. . +:+:+:+: . .. ... . J. 5(.1 fJi S / .50P( S Jrp tIJ. ~ ~/:( ~~ ~ ..t(- PfJ'~'vf !h(6!J' YO " '-:. ....