The URL can be used to link to this page

Home My WebLink About05-2617 . John W. Purcell, Jr. LD. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05' - .:2~t7 (LUL'l ~ffl-VY), : CIVIL ACTION-LAW : IN DIVORCE MICHELLE L. FIFE, Plaintiff PETER J. FIFE, 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 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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 John W. Purcell, Jr. I.D. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com MICHELLE L. FIFE, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05 - "}fo17 (2,~ ~ (-Tf/LI--YI. : CIVIL ACTION-LAW : IN DIVORCE PETER J. FIFE, Defendant COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Michelle L. Fife, by her attorneys, Purcell, Krug & Haller, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Michelle L. Fife, an adult individual whose current address is 150 Tory Circle, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Peter J. Fife, an adult individual whose current address is clo Pennsylvania Higher Education Assistance Agency (PHEAA), 1200 North 7\h Street, Harrisburg, PA 17105. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 23, 1995, in Enola, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there are two children of the parties under the age of 18: Hunter L. Fife, born September 16,1996 and Alexis R. Hunter, born October 4,2000. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The marriage is irretrievably broken. 10. 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. 2 Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. PURCELL, KRUG & HALLER Dated: r- jf g/ D~-- , I 3 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. S 4904, relating to unsworn falsification to authorities. Dated: May 18, 2005 Ij " ./ rJ.,'..~k_t.~tF "'; , . .~ ,I Michelle L. Fife ~ \.:) 'bQ ~ -..... ...() () -..... ...., G'- "- C"'J Cj ~ '-.:: .~) ~ vt c.n -n -< ~ ~ T iTj:::n () 0v ~ i--' -',,>'i --- ~ W ::) , :~'? ,J i:~~ 1? r:~? rTl ~ (Jl O. . ,. MICHELLE L FIFE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 05-2617 CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE PETER J. FIFE, AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Robert E. Tapper Jr., being duly sworn, deposes and says that on the 31st day of May , 2005, at 1: 30 p.M. he executed service by delivering a true copy of the Complaint in Divorce with Notice to Defend and Claim Rights in the above captioned matter in accordance with Pa. RC.P. 9 1930.4, in the manner set forth below: See attached Service of Process I certify that I have no interest in the above action, that I am of legal age and have proper authority in the jurisdiction in which this service was made. ,~~/ Robert E. Tapper Jr. Sworn ~.f1d subscribed before me this ~ day of , 2005 by the Affiant whose is rsonally known to me. ublic~EALT ~ s. ShalIer. NoIaIY Public ClIy Of Ha/riSbUIlI. 0aUIJhin CmIII!{ "" ()ornmission Expkes Jan. 12.2008 Member, Pennsylvania Association Of Nota.ries . CO~ONWEALTH OF PENNSYLVANIA SERVICE OF PROCESS Commonwealth of Pennsylvania DEFENDANT: r VS. NAME and ADDRESS 'I Robert E. Tapper Jr. Pennsylvania State Constable Phone: 717-554-9413 Docket No.: Date Filed: .J 1& L ...., )1 ~.' Served upon Pe+er -:J, (:r c::..- D 'be 0 t(" ) (Person 10 be Served) escn acumen s: , by handing a copy of ~. S/3i /2CL'S (Dale) (Aelalionship) to on , at (: 30 p/l' .M.. at '(Time) " /20(') . tv '7 -rh. 51- 1-I-1.:J (Localion) ;)4- f For LandlordfT enant complaints: Since none of the above found, served by posting a copy of the complaint conspicuously on the premises on . at .M., (Dale) (Time) at I:? OL' ,0' 7 ~h, <;:+- (L""alion) Miles Traveled: ~( /<~~ ('gnolure) ROOf'r-J- ....,.-;;,. POt) erR (Print Nanle'and Tille) Aope 624-95 ~. r---.' C'.~) <.';,.:.' ~.n ..-, :::r~1 lTl '(- ,.-.' en C7' Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-2617 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE MICHELLE L. FIFE, Plaintiff vs. PETER J. FIFE, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on May 19, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. l/)1;VJLtlt{ / ,I 1~/ Michelle L. Fife .J U WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) 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 in this Affidavit and 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: a/IO/Db L/nlulUJ-c; 1-~ Michelle L. Fife u :,,,"1 -n ~J ---- ) '..,\ -;~ ::.'M C. - MICHELLE L. FIFE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. Defendant : NO. 05-2617 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE PETER J. FIFE, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on May 19, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorc~ after service of notice of intention to request entry of the decree. ./;7 /.~ /~/q; . Peter J,Fife ; WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) 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 in this Affidavit and 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: d/f/~(7 " r:.~ C::J (1 '1'-1 .-.-t :c}~ {;-' Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P A MICHELLE 1. FIFE, VS. Defendant : NO. 05-2617 CIVIL TERM : CIVIL ACTION-LAW : IN DIVORCE PETER J. FIFE, PRAECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: I. Ground for divorce: Irretrievable breakdown under Section (x) 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Personal Service on May 31, 2005 3. (a) Date of execution of the Affidavit of Consent required by Section 330l(c) ofthe Divorce Code: by Plaintiff: February 9, 2006 by Defendant: February 10, 2006 (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: No economic claims have been raised. 5. (a) Date and manner of service of the Notice of Intention to file Praecipe to transmit record, a copy of which is attached: (b) Date of Plaintiffs Waiver of Notice in 330l(c) Divorce was filed with Prothonotary: Filed contemporaneously herewith Date of Defendant's Waiver of Notice in 330l(c) Divorce was filed with the Prothonotary: Filed contemporaneously herewith ',1 \..) ~I-I L-~ ;+,"";+,:f.;+,;+,;+,;+,:f.:f.:f.:f.:f. :f.:f.:f. , , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~:f.:f.~:f.;t;:f.:f.:f. :f.~:f.~:f.:f.:f. :f.:f.:f.:f.:f.:f.~:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.;t;~ , . . . . . . . . . . . . . . . . . . , . . , . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , :f. ~:f.~:f.:f.:f.:f.~:f.:f.:f.~:f.:f.:f.:f.:f.:f.:f.:f.:f.~:f.:f.:f.:f.:f.:f.:f.~;t;:f.:f.:f.:f.:f.:f.:f.;t;:f.:f.+:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.:f.+:f.++~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. MICHELLE L. FIFE plaintiff No. 05-2617 Civil Term VERSUS PETER J. FIFE Defendant DECREE IN DIVORCE AND NOW, 1.1. re..\:>('uC>,i"'l , IT IS ORDERED AND , 2006 DECREED THAT Michelle L. Fife , PLAINTIFF, AND Peter J. Fife , 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: ATTEST: J. ROTHONOTARY . #7/ ;:z~;' ~!, dT~ f;y ~~.~~ '767 Le. 0 c. CJd L.. e " ,t.., .. "