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HomeMy WebLinkAbout05-3037 , ... MICHAEL A. STER, Plaintiff IN THE COURT of COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA v. : No. btOCJ5" - '?j:f67 BETH A. STER, Defendant CIVIL ACTION - DIVORCE NOTICE to DEFEND and CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend yourself 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 in Divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including visitation of your children. When the grounds for Divorce are indignities or the irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the office of the Court Administrator, Third Floor, Dauphin County Courthouse, Harrisburg, 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 TIDS PAPER TO A 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. COURT ADMINISTRATOR 4TIl FLOOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717)240-6200 . . ~ MICHAEL A. STER, Plaintiff : IN THE COURT of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 05-3.0.3'7 ~.J~ BETH A. STER, Defendant CIVIL ACTION - LAW IN DIVORCE Complaint in Divorce AND NOW this J '7 ~ day of June, 2005 comes Plaintiff MICHAEL A. STER, by and through his attorney, John M. Glace, Esquire, and seeks to obtain a Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff MICHAEL A. STER is adult individual with a legal address of 1433 Hillcrest Court, Apartment 804, Camp Hill (Lower Allen Township), Cumberland County, Pennsylvania 17011. 2. The Defendant BETH A. STER is an adult individual who presently resides at 209 5th Street, Second Floor, Borough of New Cumberland, Cumberland County, Pennsylvania 17070. 3. Plaintiff and Defendant were married in New Cumberland on March 6, 2002. 4. Both Defendant and Plaintiff have been continuous residents of the Commonwealth Pennsylvania for more than six (6) months. 5. There have been no prior actions for Divorce or Annulment between parties in Pennsylvania or any other jurisdiction. 6. No children were born of this marriage nor are the parties parents of any children out of wedlock.. 7. Defendant is not a member of the Armed Forces of America. Plaintiff is a member of the United States Navy; but waives herein all protection afforded by the .. .. .. Soldier's and Sailor's Civil Relief Act of 1940, as amended thereafter, and chooses to proceed .. 8. Defendant has been advised of the availability of counseling and his right to request that this Honorable Court require both parties to participate in counseling. 9. Plaintiff avers that the marriage is irretrievably broken to Section 3301 (c) of the Pennsylvania Divorce Code, Act 206 of 1990. WHEREFORE PlaintiffMICHAAEL A. STER respectfully prays this Honorable Court enter a Decree from the bonds of matrimony RESPECTFULLY SUBMITTED. THE LAW OFFICE of JOHN M. GLACE lace, Esquire of John M. Glace 13 2 13 alnut Street Harris , PA 17101-1612 ( 7) 238-5515 Supreme Court ID# 23933 VERIFICATION I verifY that the statements made in the foregoing Complaint for Divorce are true and correct to the best of my understanding and belief. I understand that false statements herein are made subject to the penalties provided by 18 Pa. CSA, Section 4904, relating to unsworn falsification to authorities. Date: &11~/otJ J ~~~-- Mi lA.SteT ~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that this 1.4~ay of June, 2005 I have served a true and correct copy of the foregoing.A4\tR...,d Complaint for Divorce, by Certified Mail, Return Receipt Requested, upon: Beth A. Ster 209 5th Street Second Floor New Cumberland, P A 17070 LAW OFFICES of JOHN M. GLACE . I ,Esquire Walnut Street ,PA.17101-1612 (7 238-5515 I entification No. 23933 Counsel for Plaintiff -~ - <;; <J) P ::$7 'v'""" <r:: --, 00 - ------ -v'< 7;J ..J\ o --= ?>- ~- @> o ~ 'b c:? <J' <- C.:, ~ @ ~ %~ -ort:' ~"q ::.~ s.?, ;......-'l;'\ (;t'; ;-",)cn ~.:~ '?s :;.<. ..."'''' ~ r:-? cf'. tJ' - "C"'-';- ~:'-~' r,,/:~ ..-," '-;.~ -- v:> ...., -:-.', ~., >,.-r; "/ ;..::. ..( . . MICHAEL A. STER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2005 - 3037 v. BETH A. STER, Defendant CIVIL ACTION - DIVORCE RETURN OF SERVICE The undersigned hereby certifies that, on the date below written, service of the Complaint in Divorce the above-captioned action was made upon Defendant, above named, pursuant to the provisions of Pennsylvania Rules of Civil Procedure, Rules 403 and 404 by Certified Mail, Return Receipt Requested on June 16,2005 The signed and dated Acceptance of Service by Defendant evidencing delivery of the Complaint in Divorce is attached hereto as Exhibit "A" The undersigned further avers that he is a competent adult individual and that the averments of this Return of Service are true and correct to the best of his personal knowledge, information, and belief. June 16, 2005 ace, Esquire alnut Street g, PA 17101-1612 8-5515 DATE OF SERVICE . I . Complete Items 1. 2, and 3. Also complete item 4 ff Restricted Delivery Is dMired. . Print your name and address on the reverse so that _ can return the card to you. . Attach this card to the back of the rnailplece, or on the front ff space permits. 1. ArlIcleAdd_to: ~ 1: S'Jp~ I '?Dt] 5- rfvB@/ $PCIJt1 ~ r (t:eV> /." . N w ~h fit. fcl1'1rJ {VA.-- /1D7-o 2. Article Number (Copy from set'IIoelllbel) x D. Is ffYES. o Agent 0_ OVos ONe 3._T_ o CertifIed _ 0 Express Mall o Reg_ 0 Return Receipt for Men:handise o Insured _ 0 C,Q,D. 4. _lleIIvery? (Extra Foe) 0 Ves 7004 0750 0002 3292 6720 . ;U , . DcmestIc Rebm Receipt PS Form 3811. July 1999 1~"'" ----- 0 ~ 0 c~ ~ .." ~'.-'" ~. , <...-. '1..." ., '. '~ ' s; r~" i:: rt1 r: .z "r\ ..,i-.. ..,..)rrJ &~:~ \:~.~ N ::pO - O~ , .. ;:?q, c.:. , ')> :;~'" ,--n ': :.c^::. ':"4(') .' ,5,<1 'J:".- , Cf! -\ -Z :r ::~'5 :2. - ~ MICHAEL A. STER, Plaintiff IN THE COURT of COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA v. BETH A. STER, Defendant No. "2 f)O~ -~ 03 7 CIVIL ACTION - DIVORCE Affidavit of Consent 1. A Complaint in Divorce was filed under Section 3301 (c) onJ ~l\l' (?f,-ZOOt) and served on Defendant by } 1I\M1/~ 1. off] by Certified Mail , Return Receipt on ' J IA it f' I ~ -1 Z 00 ~ I / 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice 4. 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. 5. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. I verify that the statements made herein 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. cr 17), /v; ~~ #"Michael A. Ster Date o r;; r-"' = = i:;.:..f""l o CO,! -;~ \ C'" -0 ~ <.-) c...;; MICHAEL A. STER, Plaintiff IN the COURT of COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2 Dot; - 3031 BETH A. STER, Defendant CIVIL ACTION - DIVORCE Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301 (C) of the Divorce Code 1. I consent to the entry of a fmal 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 that Decree is filed with the Prothonotary. I verify that the statements herein are made 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. ~~2_ Michael A. Ster (j ~~~ l" r'--"> ~ = c.n o .1 ::;:! C) (---, ---;; ! c-. -0 :I;,;; N W W MICHAEL A. STER, Plaintiff IN THE COURT of COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA v. BETH A. STER, Defendant No. 2005 -3037 CIVIL ACTION - DIVORCE Affidavit of Consent 1. An Amended Complaint in Divorce was filed under Section 3301 (c) on June 13, 2005 and served on June 16,2005 by First Class mail, Return Receipt Requested. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice 4. 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. 5. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. I verify that the statements made herein 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. o{jd-U I 0:; ~~,~w Beth ~. Sr' ';;:'; 0 c;...? --rl cJ'" Co C') _\ \ Cf\ -,,':) _-'.011' ,..;.~,... r::' (,.,r:*' v2< ------.. MICHAEL A. STER, Plaintiff IN the COURT of COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005 - 3037 BETH A. STER, Defendant CIVIL ACTION - DIVORCE Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301 (c) 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 that Decree is filed with the Prothonotary. I verify that the statements herein are made 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. Of /?-.~ / OS Dr I ~ Ql- / o ",- r-' = = Cor> c? c:' -~ 0' -j --r='" --- N (..0 <.".:; -------------- Plaintiff IN THE COURT of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA, MICHAELA STER, v. No. 2005 - 3037 BETH STER, CIVIL ACTION - DIVORCE Defendant PRAECIPE to TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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 of Service of the Complaint: Certified Mail, Return Receipt Requested served on June 6, 2005. 3. Date of Execution of Affidavit of Consent required pursuant to Section 3301(c) of the Divorce Code: a. By Plaintiff: September 26, 2005 b. By Defendant: September 26, 2005 4. Related Claims Pending: None 5. Date of Plaintiff's Waiver of Notice in Section 3301(c) Divorce filing with Prothonotary: September 26, 2005 6. Date of Defendant's Waiver of Notice in Section 3301(c) Divorce filing with Prothonotary: September 26, 2005 Respectfully Submitted, THE LAW OFFICEi. JOHN M. GLACE J i, . lace, Esquire Supr~l ' ourt I.D. 23933 132-134 Waln et, Harrisburg PA 17101-1612 (71 ) 238-5515 ".) => CJ C"';-l c:, C--, -~ (~~ "'" --- -~ fv <:'-0 .-. ",,- ~~~~~~+~~~~~~+~~~+~~~++~+~++++++++:+.+:+.+:+.:+.+:+.+~ + + + + + + + + + + + + . + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +:+.+:+:~+++++++:+::+.:+::+.++~++? .' .. . . . . + + + . . . . . . . . . + . + + . . . . . . + + . . + . . . . . . . + . . . . + . + . + . . . . . . . + + . . . . . . . . . . + . . . ++;f.:+: . . ++:+:+++ . . .. . .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Michael A. ster. Plaintiff No. VERSUS Beth A. Ster, Defendant DECREE IN DIVORCE AND NOW, o;t/11(d- Michael A. ster DECREED THAT Beth A. ster AND ARE DIVORCED FROM THE BONDS OF MATRIMONY, PEN NA. ~oo<; ,03? ...r 7:t,'a ,\.M ,'Jo()(" , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None . . . . . . . . . . . . . + . . . . . + + . . . + :+:+ :+: :+. :+. :+. :+: :+. + ", ... + +:+. ++:+.+:+.+ ++:+. ++:+:+:+::+.:+::+::+::+. +:+: +:+::+::+::+:~:+: +:+::+::+: +;+: + . PROTHONOTARY J, >~.z ~~~4 5c?- [i ',,// r~~~~~>rv 5l7-[('(// . . . . . ~,..; ,.