HomeMy WebLinkAbout05-5403
NANCY j, MAURER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: No, 6S" - Sl/D3
Civil Term
JOHN M. MAURER,
Defendant
: ACTION IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court, If you wish to defend against the e1aims 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,
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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
32 South Bedford S1.
Carlisle, Pa. 17013
(717) 249-3166
NANCY J, MAURER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No, DS - S</oJ
Civil Term
JOHN M. MAURER,
Defendant
ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1, Plaintiff is Nancy J, Maurer, a competent adult individual, who has resided at 16
Bentley Place, Carlisle, Cumberland County, Pennsylvania, since 2004,
2, Defendant is John M, Maurer, a competent adult individual, who resides at 1513
Country Road, Bethel Park, Pa" 15102.
3, Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4, The Plaintiff and the Defendant were married on June 18, 1960 in Allegheny County,
Pennsylvania,
5, There have been no prior actions of divorce or for annulment between the parties,
6, Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling,
7, Plaintiff and Defendant have two children together, however, both are adult
individuals,
8, Plaintiff and Defendant are both citizens of the United States of America,
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
10, The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken,
WHEREFORE, Plaintiff requests the court to enter a decree in divorce,
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C,S, 94904 relating to unsworn
falsification to authorities.
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Nan~it, Plaintiff
Respectfully submitted,
Date:
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J e Adams, Esquire
,D. No, 79465
64 South Pitt Street
Carlisle, Pa, 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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NANCY J. MAURER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
No, D~ - 5'10.3
Civil Term
JOHN M, MAURER,
Defendant
ACTION IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-
affidavit within twenty days after this affidavit has been served on you or the statements will be
admitted,
AFFIDAVIT OF SEPARATION
I. The parties to this action separated in 1982 and have continued to live separate and
apart for a period of at least two years,
2, The marriage is irretrievably broken.
3, I understand that I may lose my rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted,
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, S4904 relating to unsworn
falsification to authorities,
Date: It) -( 7-oS-
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NANCY 1. MAURER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
No, 05 - 5403
Civil Term
JOHN M, MAURER,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this October 24, 2005, I, Jane Adams, Esquire, hereby certifY that
on October 20,2005, a certified true copy of the NOTICE TO DEFEND and COMPLAINT
IN DIVORCE was served, via certified mail, restricted delivery, return receipt requested,
addressed to:
John M, Maurer
1513 Country Road
Bethel Park, MD 15 I 02
DEFENDANT
SENDER: COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
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by (Printed Name)
o Agent
E3 AdtoIressee
C. . ~ate of Delivery
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1. Article Addressed to:
D.' Is d very address different from item 1? 0 Yes
If YES, enter delivery address below: 0 No
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3. SelVlce Type
~Certified Mall
o Registered
[] Insured Mail
o Express Mail
o Return Receipt for Merchandise
o C.O.D.
4. Restricted Delivery? (Extra Fee)
.~es
2. Article Number
(Transfer from servfce label)
PS Form 3811, February 2004
7004 1350 0003 7288 4844
Domestic Return Aeceipt
102S95-02.M-1540
Respectfully Sub~itted:
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J e Adams, Esquire
I ,No, 79465
64 South Pitt Street
Carlisle, Pa, 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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NANCY J. MAURER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
No,
05 - 5403 Civil Term
JOHN M, MAURER,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this November 23,2005, I, Jane Adams, Esquire, hereby certify that
on November 12,2005, a certified true copy of the NOTICE OF INTENT TO REQUEST
DECREE IN DIVORCE and COUNTER-AFFIDAVIT was served, via certified mail, return
receipt requested, addressed to:
John Maurer
1513 Country Road
Bethel Park, Pa, 15102
DEFENDANT
/.-:./"
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Deliveriis desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach tt'p card to the back of the mailpiece,
or on th nt if space permits.
1. Article Addressed to:
D. Is delivery address different from ite ? 0 Yes
If YES, enter delivery address below: 0 No
SENDER. COMPLETE THIS SECTION
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3. S~ice Type
..-Cl Certified Mail
o Registered
o Insured Mail
o Express Mall
o Return Receipt for Merchandise
DC.a.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
2. Article Number
(rransfer from service label)
PS Form 3811, February 2004
7003 1010 0004 7818 6930
Domestic Return Receipt
102595.02-M-1540
Respectfully Submitted:
'.
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.'7) e ams, Esqmre
LD. No. 79465
64 South Pitt Street
Carlisle, Pa, 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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NANCY J. MAURER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No, 05 - 5403
Civil Term
JOHN M, MAURER,
Defendant
ACTION IN DIVORCE
NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE
TO:
John M. Maurer
1513 Country Rd.
Bethel Park. Pa. 15102
Date: November 10. 2005
You have been sued in an action for divorce. You have failed to answer the Complaint or
file a Counter-Affidavit to the 3301(d) affidavit. Therefore, in twenty days, after November 30,
2005, the Plaintiff can request the Court to enter a final decree in divorce,
If you do not file with the Prothonotary of the Court an answer with your signature
notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree
in Divorce, A counter-affidavit which you may file with the prothonotary of the court is
attached to this notice,
Unless you have already filed with the court a written claim for economic relief, you must
do so by the above date or the court may grant the divorce and you will lose forever the right to
ask for economic relief. The filing of your counter-affidavit alone does not protect your
economic claims,
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 South Bedford St.
Carlisle, Pa, 17013
(717) 249-3166
.,
NANCY 1. MAURER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
No, 05 - 5403
Civil Term
JOHN M, MAURER,
Defendant
ACTION IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 330Hd) ofthe DIVORCE CODE
l. Check either (a) or (b):
v(a) I do not oppose the entry of a divorce decree.
_(b) I oppose the entry of a divorce decree because:
(Check (i),(ii), or both:)
_(i) The parties to this action have not lived separate and apart for a period
of at least two years.
_(ii) The marriage is not irretrievably broken,
2. Check ejther (a) or (b):
_~..<a) I do not wish to make any claims for economic relief, I understand that I may lose
rights concerning alimony, division of property, lawyer's fees, and expenses ifI do not claim
them before a divorce is granted,
_(b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees, or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my economic
claims with the Prothonotary in writing and serve them on the other party. IfI fail to do so
before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree
may be entered without further notice to me, and I shall be unable thereafter to file any economic
claims,
I verifY that the statements made in this counter-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: /r-fttv.266"-
Jo
I
NOTICE: If you do not wish to oppose the ntry of a divorce decree and you do not wish
to make a claim for economic relief, you need not file the counter-affidavit.
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NANCY 1. MAURER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
No, 05 - 5403
Civil Term
JOHN M. MAURER,
Defendant
: ACTION IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER 63301(c) AND ~3301(d) OF THE DIVORCE CODE
1. I consent to 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! 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: /1 '/'1> 'L)~-
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NANCY], MAURER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No,
05 - 5403 Civil Term
JOHN M. MAURER,
Defendant
ACTION IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO 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 &330 I (d) of the Divorce Code,
2, Date and manner of the service of the Complaint: Delivered bv certified mail. restricted-
deliverv. Delivered on: October 20.2005,
3, Date of execution of the affidavit required by ~3301(d) ofthe Divorce Code:
By Plaintiff: October 17, 2005.
Date of filing and service of the plaintiffs affidavit of separation
required by ~3301(d) of the Divorce Code on respondent:
Filed: October 17. 2005,
Served on Defendant: October 20. 2005.
Affidavit of Service filed: October 24.2005,
4, Related claims pending: No claims raised,
5, Date and manner of service of the notice of intention to file praecipe to transmit record, a
copy of which was filed of record with the Prothonotary: Served via certified mail. return receiDt
relluested. on November 12. 2005,
Respectfully Submitted:
-
Date: t '7 ~ 2 ~ 0 '::>
a e Adams, Esquire
. No, 79465
64 S, Pitt St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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IN THE COURT OF COMMON
PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
Nancy J. Maurer, Plaintiff
No, 05 -
5403
Civil Term
No,
VERSUS
John M, Maurer, Defendant
DECREE IN
DIVORCE
AND NOW,
VY::'C'" b, )
'7,
20~,-IT IS ORDERED AND
DECREED THAT
Nancy J, Maurer
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, PLAINTIFF,
AND
John M, Maurer
, 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;
None,
.
---
ROTHONOTARY
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