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Home My WebLink About05-1795 SHEILA BREIT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE . /,/ : NO. 05- ,qCIVIL TERM HANS PETER BREIT, Defendant 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 reliefrequested 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 LA WYER 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 Bedford Avenue Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. SHEILA BREIT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE . -- : NO. 05- 1"1 q!:J CIVIL TERM HANS PETER BREIT, Defendant COMPLAINT UNDER ~~ 3301(c) and (d) OF THE DIVORCE CODE, 23 Pa.C.S. &&3301(c) and (d) The Plaintiff, Sheila Breit, by her attorneys, the Family Law Clinic, sets forth the following cause of action: DIVORCE 1. Plaintiff is Sheila Breit, who currently resides at 308 Second Street, Enola, Cumberland County, Pennsylvania. 2. Defendant is Hans Peter Breit, who currently resides at 711 Sheaffer Street, Enola, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on February 14,2000, in Renovo, Pennsylvania 5. Plaintiff and defendant have lived separate and apart since January 1,2005. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 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 counseling. Burgess C. Bradshaw Certified Legal Intern WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. Date 0"1-0'-05 4+y-- c::. dA-<L.//~ ~,~ OBERT E. RAINS THOMAS M. PLACE Supervising Attorney ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 717/243-2968 Date rf- / - ()~ ~~ (j~ Sheila Breit, Plaintiff VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me tot he penalties of 18 Pa.C.S. @4904, relating to unsworn falsification to authorities. ..", -;$- .., r:-. ::.. Q.. q,-n \""\""\~ :?;e? ~q, ........ -<;, 6:1:'2 ~/ (\' '5 ";;.:~ ~)., ',7. ~ , -f'\ Q ~i: -;.--\ -t!,\.'^ C) ~.~. ..':_:;. ,~ 1{~~~C '};It s::~J' ..c.-:, ::.{. ~ ~ ~ ?' ~ .... Date D -1-0,-6 S d.~ c 4~ Burgess C. Bradshaw Certified Legal Intern SHEILA BREIT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE . ,/ : NO. 05- /1'PCIVIL TERM HANS PETER BREIT, Defendant To the Prothonnotary: PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Sheila Breit, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Jetd- L ~~ ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 717/243-2968 (') ,..> (') = c = -n ~~V" "'" '~Qi:j:; ~ ~-:!J n1ff': -;;'." ::0 rl1-- ~7 ,..- V VJ"<'~" I :g~ -:::1 "-::: U1 gel ~~\_:; -0 -~c_: :t{ - :;ie', :l~ ',)c-) , :pc~ 7.' fS1 ;>")rf1 C '::::' ~ ~" .x;:- ~ -J SHEILA BREIT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE HANS PETER BREIT, Defendant : NO. 05-1795 CIVIL TERM CERTIFICATE OF SERVICE I, Burgess C. Bradshaw, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Complaint for Divorce on Hans P. Breit, at 711 Sheaffer Street, Enola, Pennsylvania 17025, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested on April 5, 2005. Service was complete upon receipt by Hans P. Breit on the day of April II, 2005, as evidenced by the attached green card. d'~c~ Burgess C. Bradshaw Certified Legal Intern THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Office: (717) 243-2968 Fax: (717) 243-3639 . Complete items 1, 2, and 3. Also complete item 4 jf 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 mailpiece, or on the front if space permits. o Agent o Addressee D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 1. Article Addressed to: -,I) c"v~:,ol ROY) (.I.. ^J d 7// S/u/c'l{..<-2 c).b~::t P. TZ <<.f "', j7/j / -) (J;)S \,\ 3. Service Type ::S" ~ertified Mail 0 Express Mail ~egistered '----S'Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Copy from service label) -} QOd 0 ;?(.76 6 C'> <') I S g> <;/7 J' --;, 7 ~ PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 f...."., ":~:'< -,~j" -.,,,. c> :.-{\ -);) / t.f" ,.J 'r~' V SHEILA BREIT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE HANS PETER BREIT, Defendant : NO. 05-1795 CIVIL TERM PRAECIPE TO WITHDRAW DIVORCE COMPLAINT To the Prothonotary: Please withdraw the Plaintiffs Complaint for Divorce Under ~~ 3301 (c) and (d) in the above-captioned case. Respectfully submitted, Date 7 f1q J05 I I THO ROBERT . RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys THE F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 --( c.:J <'",' c~ C~ .-.11 c--: J;::: l'~ c.1 --r.' p..:, {";\ - ", L " "