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Home My WebLink About01-5055ROBERT MICHAEL FALK, Plaintiff VS. TARA LYNN FALK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED 1N 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 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. 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 1-800-990-9108 ROBERT MICHAEL FALK, Plaintiff VS. TARA LYNN FALK, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DiVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) and 3301(a)(6) OF THE DIVORCE CODE The Plaintiff is Robert Michael Falk, an adult individual who currently resides at 427 Eutaw Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 and whose social security number is ! 66-68-6082. The Defendant, Tara Lynn Falk, is an adult individual, whose current address is 727 Old Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania 17055, and whose social security number is 186-54- 2055. 3. Plaintiff and Defendant were married on January 12, 2001, in West Hanover Township, Dauphin County, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are no minor children bom of the marriage. 10. Plaintiff avers (a) (b) that the grounds on which this action is based are: That the marriage is irretrievably broken, or in the alternative; That the Defendant has offered such indignities to the person of the Plaintiff, the injured and innocent spouse, so as to render his condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Date: Respectf~¢? sUbmit~d, rt ur K. Di s, Esquire 1017 North Front Street Hamsburg, PA 17102 (717) 232-9724 I.D. No. 07056 VERIFICATION I verify that the statements made in this C o ~, ?/'; ~ U 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. ~X ~- o~ ROBERT MICHAEL FALK, Plaintiff VS. TARA LYNN FALK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5055 Civil Term CiVIL ACTION - LAW IN DiVORCE PRAECIPE TO THE PROTHONTARY: Please amend the caption in the above-captioned divorce action to read the Plaintiff's name as "MICHAEL ROBERT FALK". The Plaintiff's first and middle nameswere inadvertently transposed upon the filing of the Complaint in Divorce. Date: December 27, 2001 Respec~sub~itte~f_ ~ 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Attorney for Plaintiff, Michael Robert Falk MICHAEL ROBERT FALK, Plaintiff VS. TARA LYNN FALK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5055 Civil Term CWIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) and 3301(a)(6) of the Divorce Code was filed on August 29, 2001. 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. I consent to the entry of a final Decree in 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 made herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ~ ' o7_ Michael/Robert Falk, Plaintiff MICHAEL ROBERT FALK, Plaintiff VS. TARA LYNN FALK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5055 Civil Term CiVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) and 3301(a)(6) OF TItE DIVORCE CODE I consent to the entry of a final Decree in Divorce without notice. 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. o 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 Waiver 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: ~L ,,~,~_ ¢,~ /( -~-~- Michael Robert i~alkl Plaintiff MICHAEL ROBERT FALK, Plaintiff VS. TARA LYNN FALK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5055 Civil Tem~ CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) and 3301(a)(6) of the Divorce Code was filed on August 29, 2001. 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 final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are tree and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C...S~ §4904, relating to unsworn falsifica~o~ to authorities.. Date:~b ~j} ~'~(-')'~('~..~ ¢~.,.,1~ d~' Member. [~ennsylvani~ ~Assoc%tf~ Ot Notaries MICHAEL ROBERT FALK, Plaintiff VS. TARA LYNN FALK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5055 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) and 3301(a)(6) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in 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 in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification ffauthorities. Date.'~~ q/ ~f~~ z//~/[~2~ ~ ara Lyrlff Falk, I~efendant 1,~,,~ ~' t~,~ 7~b. 14, ~ I MICHAEL ROBERT FALK, Plaintiff VS. TARA LYNN FALK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5055 Civil Term 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: Irretrievably broken under Section (X) 3301 (c) or ( ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: By certified mail on September 4, 2002. 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, February 7, 2002; by Defendant, February 4, 2002. (b) Date of execution of Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A; Date of service of Plaintiff's a~upon Defendant: N/A. o o Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: N/A; Date of filing of Waiver of Notice of Intent to herewith; by Defendant: Finalize by Plaintiff.' Simultaneously Simultaneously herewith. Related Claims Pending: None BY: 1017 North Front Street Hamsburg, PA 17102 (717) 232-9724 I.D. No. 07056 Attorney for (x) Plaintiff ( ) Defendant IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Michael Robert Falk, ~laintiff VERSUS Tara Lynn Falk~ Defendant NO. PENNA. 01-5055 Civil Term Decree iN DIVORCE AND NOW, DECREED THAT Michael Robert Falk , ~-~--, IT IS ORDERED AND , PLAINTIFF, AND Tara Lynn Falk , 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; N/A BY THE COUrt:/ )THONOTARY