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HomeMy WebLinkAbout01-4463 '" '" '" '" '" :t: :t: :t: :t: :t: . :t: :t: :t:"':t::ti:t::ti:t: . IN THE COURT OF COMMON PLEAS . . . . OF CUMBERLAND COUNTY STATE OF . . . . . . . . . . . . DANIELLE R. CONRAD Plaintiff . . . . VERSUS JOSHUA L. CONRAD . Defendant . . . . . . PENNA. NO. 01-4463 DECREE IN DIVORCE . AND Now,_ll"'''o''_b,j' U;: , .2001 , IT IS ORDERED AND . . DECREED THAT . . . AND . na~IELLE R CONRAD , PLAINTIFF, JOSHUA L. CONRAD , 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: ~ J uL)-c ATI~ lJJ ROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . ~'.: <. .' .'" , , ~ ~ -'I:f:~~u.- - /Q/51/'1 ~~~~.~'~ _10/51/11 II DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmi t the record, together wi th the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: 3301(c) of the Divorce Code. Irretrievable breakdown under ~ 2. Date and manner of service of the Complaint: July 27, 2001, by United States Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce Code: By Plaintiff October 15, 2001; by Defendant November 06 , 2001. 4. Related claims pending: NONE. 5. Date Plaintiff's Waiver of Notice in S 3301(c) Divorce filed with the Prothonotary: November 07 , 2001 6. Date Defendant's Waiver of Notice in S 3301(c) Divorce filed with the Prothonotary: November 07 , 2001 Respectfully submitted, DISSINGER AND DISSINGER Date: 1(7/01 . ~ i&r u ren L.. Koe~ sber~ ... Attorney for Plaintiff~ Supreme Court ID # 85556 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 cc: Joshua L. Conrad, Defendant e, 0- C ~ ."'01:. 'Z.. \:!:i D J':'" (. "'/\ (,'). -, ,.J r.' \, ~< - -,"'" .--;/ ~ ," N is' ." 1 .~. "'l (1-' 1.1 DANIELLE R. CONRAD, Plaintiff vs. IN 'rHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01- 44<.,,3 IN DIVORCE NOTICE TO ])EFEND 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 Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 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 WHE~~ YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUI~ CARLISLE PA 17013 717-249-3166 II I DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in th,e above captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Prothonotary II DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. lIi- 'fiffij C i vi I IN DIVORCE CONSOLIDATED COMPLAINT IN DIVORCE 1. Plaintiff is Danielle R. Conrad, a citizen of Pennsylvania, residing at R R #1, Box 242 C, Liverpool, Juniata County, Pennsylvania, 17045. 2. Defendant is Joshua L. Conrad, a citizen of Pennsylvania, residing at 100-C Elicker Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui juris and have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife clnd were lawfully married on March 10, 2000, in Perry County, Pennsylvania. 5. The marriage is irretrievably broken. 6. There has been no prior action for divorce or annulment instituted by either of the partiEls in this or any other jurisdiction. 7. The Plaintiff has been advised of the counseling and of the right to request that the parties to participate in counseling. availability of Court require the II COUNT I Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Ilivorce Code 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elclpsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant havl: the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT II Request for Divorce Due to Irr.ltrievable Breakdown Under 3301(d) of the Divorce Code 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. The marriage of the parties is irretrievably broken. 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. II 15. Plaintiff has been advised of the, availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. COUNT II I Request for Counsel Fees, Cost:! and Expenses Under 3104, 3323, 3502 (e) and 3702 CJf the Divorce Code 16. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 17. Plaintiff has employed Karen L. Koenigsberg, Esquire of the law firm of Dissinger and Dissinger to represent her in this matrimonial cause. 18. Plaintiff is unable to pay the necessary counsel fees, costs, and expenses and Defendant is more than able to pay them. WHEREFORE, reserving the right to apply to the Court for temporary counsel fees, costs and expenses, prior to final hearing, Plaintiff requests that, afte!r final hearing, the Court order Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. Respectfully submitted, DISSINGE:R AND DISSINGER ~KO 11 VERIFICATION I, Danielle R. Conrad, verify that the statements made in the Divorce Complaint 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. .. , -It;(~-' At '- ~~lle . Conrad, Plaintiff II 'I DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND Karen L. Koenigsberg, Esquire, attorney for Plaintiff, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Plaintiff I s Complaint in Divorce in this action to the Defendant at his residence, and that Defendant did receive same as evidenced by the signed receipt dated July 27, 2001, attached hereto as Exhibit "A". ) ~~en Sworn to and subscribed befo~;;'hiS ..it) 'i4. day of , 2001. /'~ .';~ 7/~f r 6t; Y L Notary ~:d NOTARIAL SEAl. ..Ci.o.~PubIIc .Uy1~ a SENDER: ; c Complet.._ 1 _co 2 for .""'_ _""". I Complete ttems 3, 48, and <lb. D Print your name and address on the reverse of Ihi8 form 80 that we can retum this can:ttoyou. C Attach this form 10 the front of the mai/piece, or on the back it space does not perm;t. , DWrtte "RstumRflCBiptR9qUIISted"onlhemallpiece beIowthrtartide number. I: C ~=~ ReceIpt will show to whom the article was delivered and the date '.3. Artfde Addressed to: 48. Artlcfe Number Joshua L. Conrad nn nn?~ , 100-C Elicker Road 4b. eMoeType o Registered CarlisleI' PA 17013 0 ElCpI'essMall o Return Rece'ipt for Merchandise I also wish to receive the follow- ing services (for en extra fee): 1. 0 Addressee's Address 2. ~ Restricte<ll Delivery ~~4n ???6 S IllICertified I. o Insured f o COD S I J 7. Da'1r;r~ol 8. Addressee'. Addred (Only /I requ08/ed and fse is paid) (""'a~ PS Form 3811, December 1994 102595-99-1:3-0223 Domestic Return Receipt EXHIBIT "A" j J , c t1 <:::.,F" ~ N o ~ II DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under 5 3301(c) of the Divorce Code was filed on July 24, 2001 and served on July 27, 2001. 2. 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 of divorce after service of the 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 herein are made subject to the penalties of 18 falsification to authorities. Pa. C.S. 54904 relating to unsworn Date: fI~/ - c ( ~1L ~c.~~ ~3hua L. Conrad, Defendant 0> ~ c: t"J C~-I ;;':,c en ,-i [;:,- 'f en () ~ )~. ~ :-:-' II DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE m:CREE UNDER S3301(C) OF THE DI~DRCE 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, alimony pendente lite, marital property or counsel fees 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 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: ;(-t- 0 I ~J;' .. /~,_~7 c-k/A: d7 #,-:.?~--/ Joshua L. Conrad, Defandant Q ~ ~ ,...J ;-'~~:l" ';;:" ~ .0:: (/. r;:" ," <:XI i::i -i:: /: ,.:'.: ;::.' t C., rC ~,,: "'.:) II i DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~ 330l(c) of the Divorce Code was filed on July 24, 2001 and served on July 27, 2001. 2. 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 of divorce after service of the notice of intention to r:equest entry of the decree. 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 unsworn falsification to authorities. Date: {a (\'Slot ~Ii ~ Dt'!~ielle R. o ~ '" < .J ;-}~ ~~i~ (}-' ;s 'i":';, \l<> ~ -l>- ::... ~ C--C:( ....-'>C~ CJ :<i :-:0 .;:.- II , DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE m:CREE UNDER S3301(C) OF THE DI~~RCE 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, alimony pendente lite, marital property or counsel fees 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 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: \0 \ ":S \~ l .... ~ffie~ ~e~e R. Conrad, Plaintiff 0. c o < -J 00 Q i=' :.. " , /_- --1 -< ~:;. II DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE PRAECIPE To the Prothonotary: Please withdraw Count III Request for Counsel Fees, Costs and Expenses from the Consolidated Complaint in Divorce filed July 24, 2001. Respectfully submitted, DISSINGER & DISSINGER Date: 'IpJ/ .' c, / ,'./ t.. ,. i/ " /;... / r.' '..c "' 1/1./0>;( \. ,-.:x/.'A,' l. -.lc /J_ cJ !~aren L. Koenigsberg, squire Attorney for Plainti Supreme Court ID # 85556 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 cc: Joshua L. Conrad 0 c c: ~ -, <- .-J f'> : ',,) . , N "<, cr, V'> t II DANIELLE R. CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. JOSHUA L. CONRAD, Defendant CIVIL ACTION NO. 01-4463 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff, Danie11e R. Conrad in the above matter, having been granted a Final Decree in Divorce on the 15th day of November , 2001, hereby elects to resume the prior surname of Van Horn and gives this written notice pursuant to the provisions of 54 Pa.C.S.A. s704. DATE: wJ'~\a\ . <'l: - ~c9na ture COMMONWEALTH OF PENNSYLVANIA ~~ ~ ~gnature 0 O..uie lie. If eing resumed VAil> I-!Ott'N ss COUNTY OF O~~ On the ~ day of M~/"L- ,2000, before me, a Notary Public personally appeared Danielle R. Conrad known to me or satisfactorily proven to be the person whose name is subscribed to the wi thin document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. \.J/1~ ~ ~'a- Nota Public ~ "4"::",':I;;.;J;.'JiiI:J,', l NARTF!'" /- '"",1 f'Ub!lc ~Hiliilc , . .", /~ j _aimndsaiOii'~x~~~~;!.~l~. ~ c) 0 c ?"~': --:-7 r R ~o, ; ~ flii,' ~ Z..i. ;.: : " r 0-, '- -{:' , . ~ .,,- r:.--:: - N ~ ::-~ .J:\ .." / -<: t > " ~ U\ "<;) :.:1 VI en ;