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HomeMy WebLinkAbout05-1876d Daniel J Carl, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUN~}TY, P/ENNSY~LV~AyN-IAA Erica A Carl, :CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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 the 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 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 James Miller, Esquire Attor y for Plaintiff Daniel J Carl, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND C/OUNTY, P/E~NNSYLVANIA Erica A Carl, :CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Daniel J Carl, who currently resides at 2 Wineberry Drive, Mechanicsburg, PA. 2. Defendant is Erica A Carl who presently resides at 2 Wineberry Drive, Mechanicsburg, PA. 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 November 5, 1994 in Cumberland County, Pennsylvania 5. There has been an action for divorce or annulment between the parties filed to Cumberland County Court of Common Pleas, docket number 00-1528 which had been dismissed. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to: a) enter a decree dissolving the marriage between Plaintiff and Defendant; Respectfully Submitted, Miller Lipsitt LLC Bv: James A Miller, quire Attorney for P 'tiff 2157- et Street Camp Hill, PA 17011 (717)737-6400 VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: ~ ~~ ~~ Carl, Plaintiff `moo w 6'` ~. C C 4 n r ~, ~- ?``; J r~ ~, ~~ ui ~-~ ~, ~, ~~ ~, ~, . ~,-~ r. .~ Daniel J Carl, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA • rd~ v, NO. 05-1&~5-Civil Term Erica A Carl, :CIVIL ACTION -LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT I, Erica A Carl, Defendant in the above captioned matter do hereby on the date indicated below accept service of the divorce complaint filed by Plaintiff, Daniel J Carf, to the above term and docket. Date: Erica A Carl, Defendant '~ Daniel J Carl, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1876 Civil Term Erica A Carl, :CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 11, 2005 and service was obtained upon the defendant by defendant accepting personal service thereof on May 4 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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.A. Section 4904, relating to unsworn falsification to authorities. Date: ~w 2 3 ~Z.-F) 9 6 - ~~~-~ l Daniel J Carl c~ ~ o ~- - ~~ -~, : ;.,_; ~ -7;r ~. nor ca _,,;,; _.: ~, -r1 -r ,r, r,o _~ _ r-~ v-~ Daniel J Carl, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1876 Civil Term Erica A Carl, :CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. 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 I 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: cJ C~ 2~ L~ ~ ~`i . ,.X `~ `~~~ J Carl c> ~ ° Er. ~- .~ ~_ ;r-~, ~. ~~~ ~; `~~ , -- ~t ~ _ m ' =°._, ~ ;= ~ -. i - , _ to SU =~ ~ ~e O < Gry Daniel J Carl, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, NO.05-1876 Civil Term Erica A Carl, :CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 11, 2005 and service was obtained upon the defendant by defendant accepting personal service thereof on May 4, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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.A. Section 4904, relating to unsworn falsification to authorities. Date: r Erica A Carl C ~. ~~ t~4} rz': ~ ,.._~ t~z ~ , N ~ ~ ~- '~ .~~. >.. ~ ~~ ~ ~ Daniel J Carl, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.05-1876 Civii Term Erica A Carl, :CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c1 OF THE DIVORCE CODE 1. 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 I 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. verify that the statements made herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: ~ . Erica A Carl cs' ~. ~ ~ ~~ ~ ~ ~v --.:~ "'~3 c,.:p ~ ~ ~ ...4 Daniel J Carl, Plaintiff v. Erica A Carl, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.05-1876 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner service of the Complaint: Defendant accepted personal service of a CERTIFIED COPY OF THE COMPLAINT IN DIVORCE on May 4 2005 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: January 23 2006 by Defendant: November 10 2006 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: January 31 2006 by Defendant: November 29 2006 4. Related claims pending: There are no related claims pending. Respectfully Submitted, Miller Lipsitt LLC By: ~i4^-- _ Jarrtitis A M' ler, Esquire Attorney r Plaintiff 356 h 21St Street p Hill, PA 17011 (717) 737-6400 C~ ~. N ~ ~ ~ ~_,., ,~, ~, .i) :~~ f1. ,,.~ ._ r ~` .,..~. ~ ~-- C ~ d_~. ~. y :.~ ~ ,.. ~ .~ [ N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ^ ~ PENNA. r~ ~ ~. ~z `, _ Daniel J Carl Plaintiff VERSUS Defendant NO. 05-1876 DECREE I N DIVORCE AND NOW,_ 1 ,d `~ , ~~ lT IS ORDERED AND DECREED THAT Daniel J. Carl PLAINTIFF, AND Erica A. Carl 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; BY THE COURT: PROTHONOTARY ,emu ~o-~~ -s ~ ~"'~~" ~,,~ gip. SJ -f v~.~;y .1`s~ .y +