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Home My WebLink About01-5200THEODORE K. WERTZ, Plaintiff WENDY A. WERTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 01- CIVIL TERM IN DIVORCE NOTICE 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 ofdivorce or annulment may be entered against you by the court. Ajudgment 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 Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNLrLMENT 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 Phone: (717) 249-3166 THEODORE K. WERTZ, Plaintiff WENDY A. WERTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-~2~VIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiffis Theodore K Wertz, who currently resides at Service Company, H&S Battalion, Parris Island, Beaufort County, South Carolina, since May of 1999. 2. Defendant is Wendy A. Wertz, who currently resides at 275 Ridge Street, Carlisle, Cumberland County, Pennsylvania, since January of 1995. 3. Defendant has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiffand Defendant were married on May 26, 1986 in Cherokee County, Oklahoma. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plalntiffhas been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling 8. Plaintiffrequests the Court to enter a Decree. in Divorce, ~ · Z/ ~//O/ ~C~o~. Cutler, Esquire 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 73471 VERIFICATION I verify that the statements made in the foregoing Petition 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: ~'~ /~ OI Theodore K. Wertz, Petitioner THEODORE K. WERTZ, Plaintiff V. WENDY A. WERTZ, Defendant : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PENL : CIVIL ACTION - LAW : NO. 01- 5200 CIVIL TERM : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you mtn:;; iiie :~ counter- affidavit within twenty (20) days after this Affidavit has been served on you or the .t~e~v.,ms will be admitted. ' AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on January 10, 1995, and have continm~d <~ i;, ~: separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division ofpropert), i,~.~ s fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I und¢,~ ~l~,_[ ,i~! thlse statements herein are made subject to the penalties of 18 Pa. C, S. § 4904 relating to unsx~ ~ ?~ i'aisii;cation to authorities. Wendy A. W~rt~, Defend~ THEODORE K. WERTZ, Plaintiff V. WENDY A. WERTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 01-5200 CIVIL TERM : 1N DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 7th day of September, 2001, I, April L. Deatrick, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by hand delivery. LAW OFFICES OF PAUL BRADFORD ORR April L. Deatrick Paralega! THEODORE K. WERTZ, Plaintiff WENDY A. WERTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01-5200 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE 1. I consent to the ent~ 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 ifI 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 aider it is filed with the Prothonotary. 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. §4904, relating to unswom falsification to authorities. Date: Wendy A. Wtertz, Defendaa~