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Home My WebLink About05-3896 SAlOIS lUFF, FLOWER g, LINDSAY 1TORNEYS-AT'LAW 6 W. High Street Carlisle, P A II I Natalie C. Thalhauser, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. Steven Michael Thalhauser CIVIL ACTION. DIVORCE NO.0.,5-389t CIVIL TERM IN DIVORCE Defendant 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 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 Prothonot ary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THE M. 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 32 BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By: Carol . Un ID#4 26 West High Street Carlisle,PA 17013 (717) 243-6222 SAlOIS HUFF, FLOWER & LINDSAY ATIORNEVS-,U-LAW 26 W. High Street Carlisle, PA II Natalie C. Thalhauser, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. Steven Michael Thalhauser CIVIL ACTION - DIVORCE NO. ~5- 3'Sq~ CIVIL TERM IN DIVORCE Defendant COMPLAINT Natalie C. Thalhauser, Plaintiff, by her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is Natalie C. Thalhauser, who currently resides at 35 West Louther Street, Carlisle, Cumberland County, Pennsylvania 17013, where she has resided since April 2005. 2. The Defendant is Steven Michael Thalhauser, who currently resides at Friendship Company, 177 Carlisle Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, where he has resided since April 2005. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint 4. The Plaintiff and Defendant were married on June 5, 2001, at Mechanicsburg, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. SAlOIS HUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street CarHsle, PA II \ 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAlOIS, SHUFF, FLOWER & UNDSAY, P.C. Attorneys for Plaintiff By: Date: ?!~ ~1 ZtJtJ5 VERIFICATION I, the undersigned, hereby 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. ~ 4904, relating to unswom falsification to authorities. -'~ Date: 17. /8 -o~- 9'- ~ .1;\- ~1~\ ~yo -c 'V/ C) \. o ';'~~) -"'\\ zh .~:?.." \:-{lf~_ -\'.\-~j C'."> ..)>, ...;) . ~ :.\~. -, . ~, -I"i. "~!\ - ., .~~ .- ..::; SAlOIS flUFF, FLOWER & LINDSAY AlTORNEVS.AT-LAW 26 W. High Street Carlisle, PA Natalie C. Thalhauser, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. Steven Michael Thalhauser CIVIL ACTION - DIVORCE NO. 05.3896 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, STEVEN MICHAEL THALHAUSER, Defendant above, accept service of the Complaint in Divorce in the above captioned matter. O~/ Oq/7.00"- Date' , .~. 1"1. zbi~. ./ Steven Michael Thalhauser, Defendant ? ~ 4.j~' rT\.f\ '-'7"'1: ~"';;; ;,0' ",,; u:;..-. -'-'. '".2. (. '%2: 7C :z :2. ~ ~ ~ ",4 -- (J' Q, ~~ -O~ :'0 () :> ::';1"'-' -::"'):0 ';",~ ':2. ~ ~ cf! ~ ..., - '. SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT.L\W 26 W. High Street Carlisle, PA ATALIE C. THALHAUSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 05-3896 - CIVIL TERM TEVEN MICHAEL THALHAUSER, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed on July 29, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have lapsed 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 equest entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my nowledge, information and belief. I understand that false statements herein are made subject to the enalties of 18 PaLS. 4904 relating to unsworn falsification to authorities. ::f/ _ .~'~ __ L .,. , /.. .-'// c:Y./ . ate;98oS '0,~;~: Natalie C. alhauser PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 (e) 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 cos cr 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 nd 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 are true and correct to the best of my nowledge, information and belief. I understand that false statements herein are made subject to the ate/;2- 8()~ enalties of 18 Pa.C.S. 4904 relating to un,sworn falsifi L.,/..d ,.:// t//{(~I ,~/~ ~C\,,~ " ;._~.) SAIDIS, RDWER & LINDSAY ATIORNEYS.Af'LAW 26 \Vest High Street Carlisle, PA 'I lA' ALIE C 'HALHAUSER, , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 05-3896 - CIVIL TERM TEVEN MICHAEL THALHAUSER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301 (c) of the Divorce Code was filed on July 29, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have lapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fli1:Jl Decree ir. Dil/crce 3fter ~en{jc9 of notic~ of intention to quest entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my nowledge, information and belief I understand that false statements herein are made subject to the enalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ate: 2. / j}) 0 b I ' A--___ '~1' zAYf------- Steven M. Thalhauser DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 Ie) 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 es 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 nd 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 are true and correct to the best of my nowledge, information and belief. I understand that false statements herein are made subject to the enalties of 18 Pa,C.S, 4904 relating to unsworn faisificati~~.~authorities. _ . ate: 2//3/06 _~ WI. L~k_ , Steven M Thalhauser __~_w_'_'~',n (') -"'I rTJ cu '.-' -n ..,1 G' :. ~ ..-- ~;~ C.':: SAIDIS, FLOWER & LINDSAY ATIORNEYS.AT.L\.W 26 \Vest High Street Carlisle,PA ATALIE C. THALHAUSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 05-3896 - CIVIL TERM v. TEVEN MICHAEL THALHAUSER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD o the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the om plaint on August 9, 2005. An Acceptance of Service was filed with the Court on August 15, 005. 3 xecuted: Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was By Plaintiff: December 8, 2005 and filed with Prothonotary on December 12, 2005. By Defendant: February 13, 2006 and filed with Prothonotary on February 16,2006. 4. Related claims pending: The terms of the Property Settlement and Separation greement dated August 11,2005 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was executed: By Plaintiff: December 8,2005 and filed with Prothonotary on December 12, 2005. By Defendant: February 13. 2006 and filed with Prothonotary on February 16,2006. SAIDIS, FLOWER & L1N~AY ~ '! I \ I ...... ./ :' C~t'v~fr~ A ~.' Carol J. Lindsay, Es ulre \ Supreme Court I~o. 44693 26 West High Street Carlisle,PA 17013 717-243-6222 SAllIS, FLOWER & LINDSAY ATIORNE\'S.AT.lAW 26 West High Street Carlisle,I'A " CERTIFICATE OF SERVICE On this} 7ri.-day of February, 2006, I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, LOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served n the following individual, via first class mail, postage prepaid, addressed as follows: Steven M. Thalhauser 708 Hanover Manor Apartment 0-305 Carlisle, PA 17013 SAlOIS, FLOWER & LINDSAY , Carol J. Lindsay, Es ulre Supreme Court I o. 44693 26 West High Street Carlisle, PA 17013 717 -243-6222 c' '~{, -:J --,-1 ~. ('. '~ c:-: f'; \..J; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :++:+ '+' '+'~ :f.:+'l':+:+:++ :+ :+ +++++++++++++++++++++++++++~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .:+:Ii :+ . :+:1; +++:+:t: ++. +++ ++ +++:+++++ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. NATALIE C. THALHAUSER, Plaintiff No. 05-3896 VERSUS STEVEN MICHAEL THALHAUSER, Defendant DECREE IN DIVORCE AND NOW, :/dJvv ..., 7 Z vi NATALIE C. THALHAUSER ,2JfJO fa , IT IS ORDERED AND DECREED THAT , PLAINTIFF, AND STEVEN MICHAEL THALHAUSER , 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; The terms of the Separation and Property Settlement Agreement, dated August 11,2005, are incorporated, but not merged, into this Decree in Divorce. BY THE COURT: L . . . . . . . . . . J. . . . . . . . ROTHONOTARY . . . . . :++:+'+'++'1':+'1':++:+:+:+++ :+,.,;+::+ +++++:+: 'f++++:+:+ ++++:+++:++++:++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -~~ ~ ~Jt: ~.~ -? ~/ 4"" rr.9 > '".~ ~ ~.""'.~ . ~... ., -~. ." 'lv"!...e_;>= '- 517<e C' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N 0'+0\..-1-, e. C. Tk a. I ho. Ll.se ( : Plaintiff Vs File No. 05" - 3'69 ~ IN DIVORCE Ste.VU\ /"lickMI -rh.t\..\hD-.<-lSU Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or . ~ after the entry of a Final Decree in Divorce dated _ 0 ;) -.;J;;>. - 0 ~ hereby elects to resume the prior surname of.:" Ro W L E.. 'I , and gives this written notice avowing his I her intention ~urs1l;~the proisio.Jl.s c~~ 54 P.S. 704. Date: 0.5-10- 00 v//U4[<Z;Z:;;:./!2~~..-< Signature C /J ~? // , /(C" ...a:;~.ft-~ Signature of name bei esumed cOMMONWEAfTH OF PENNSYLVANIA ) COUNTY OF Ctt<<,/)t'((tlU . On the ~ day of /...J..atri1 , 200fp., before me, the Prothonotary or the notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and ac1mowledged that he~ I she executed the foregoing for the purpose therein contained. 1n Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. IwJ(:) ,./~ P othonotary or N~)tary P r __f () NOTARIAl. SEAl. CARIJSLE ~ NOTARYPlI8t./C MY~cmoe~..~UIl1'HllUsE ~'''''''''''''''''''''.2010 n .."t"" :":' 'Cf!f"j I.{;. ".' .;....t.,.~. '\':1 Y"'''I!'' ~;.i }q ....,.,<...--...... '~ _ ,'fi)l,q ", ;,\~...,;:-~: ';Ut<.<' ; '-1tL :.'.1,': .,\) l~';' ....... .~-~".- .._._~--_..~-,,,.,....,';~