HomeMy WebLinkAbout05-6015
.
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05- ?t'l5 CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
Henry John Thielemann,
Plaintiff
Diane Marie Thielemann,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
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 will proceed without you and a decree in divorce or annulment may 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 First Floor, Cumberland County
Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
1'1
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: /
: NO. 05- t-o/~ CIVIL TERM
v.
Diane Marie Thielemann,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Henry John Thielemann, an adult individual, currently residing
at 203 S.Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is Diane Marie Thielemann, an adult individual, currently
residing at 12 South Filbert Street, Apt C-8, Mechanicsburg, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing
of this complaint.
4. Plaintiff and Defendant were married on September 20, 1981 in
Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the
parties.
6. The Defendant is not a member of the Armed Forces of the United States
of America, or its Allies.
7. The Plaintiff has been advised of the availability of counseling and the
right to request that the Court require the parties to participate in counseling. Knowing
this, the Plaintiff does not desire that the Court require the parties to participate in
counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties have lived separate and apart since October 18, 2005 and
continue to live separate and apart as of the date of this Complaint.
10. The parties' marriage is irretrievably broken.
'11
11. Plaintiff desires a divorce based upon the belief that Defendant will, after
ninety days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce.
/ / At t~
Date
Respectfully Submitted
TURO LAW OFFICES
I ~----
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Ron Turo, Esquire
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
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VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and
correct. I understand that false statements herein made are subject to the penalties of
Pa.C.S. 34904 relating to unsworn falsification to authorities.
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Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint in Divorce on behalf of myself.
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Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on
November 22,2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
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.
:; -;2.7-0~
Date
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II
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under g3301 (c) of the Divorce Code was filed
on November 22, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of the final Decree in Divorce after service of Notice of
I ntention to req uest entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. g4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
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II
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION -- LAW
: IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~ 3301 cg 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 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 it is filed
with the Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
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.
;:( -?-7 -0(;
Date
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ohn Thielemann
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II
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~ 3301(c) 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 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 it is filed
with the Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 34904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
~~6
II :JL~ .
~e Marie Thielemann
-..,.
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I,
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05- 6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION - LAW
: 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:
1. Ground for divorce: irretrievable breakdown under 9 (3301 (c)) of the
Divorce Code.
2. Date and manner of service of the complaint: Acceptance of Service by
Diane Marie Thielemann delivered on or about November 23, 2005.
3. Date of execution of the Affidavit of Consent required by 93301(c) of the
Divorce Code.
By Plaintiff: February 27, 2006 By Defendant: February 23, 2006
4. Related claims pending: None.
Date the Waiver of Notice in 93301 (c) divorce was filed with the
Prothonotary:
By Plaintiff: March 6, 2006
By Defendant: March 6, 2006
v//
II
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION- LAW
: IN DIVORCE
AFFIDAVIT OF SERVICE
I HEREBY CERTIFY THAT I served a true and correct copy of the Complaint In
Divorce filed in the above captioned case upon Diane Marie Thielemann, by Personal
Acceptance of Service on November 30,2005 addressed to:
Diane Marie Thielemann
and did thereafter receive same as evidenced by the attached Acceptance of Service
Document.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,
INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN
MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
/
<i7/X?
Date
TURsrIAW OFFICES
o uro, Esquire
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
~
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
~j
'._-.,
Cj
ACCEPTANCE OF SERVICE
I accept service of the Complaint in Divorce on behalf of myself. _.3
------
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
Henry John Thielemann
Plaintiff
VERSUS
D;~ne M~rie Thielemann
Defendant
AND NOW,
PENNA.
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No.
os
60'15
DECREE IN
DIVORCE
4;:T ~~5f.A .
f/t~
If
, 2006 _, IT IS ORDERED AND
DECREED THAT
Henry John Thielemann
, PLAINTIFF,
AND
Diane Marie Thielemann
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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
N~
ATTEST:
ROTHONOTARY
-----
J.
_ Jk.l 'l, ,/'/tl'O: ?~u, ;}LJY' ['
C">P r P ~ 4".J"'? 'Jl..Sf"
.' .
. .
Henry John Thielemann,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-6015
CIVIL TERM
Diane Marie Thielemann,
Defendant
: CIVIL ACTION -LAW
: IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
NOTICE IS HEREBY GIVEN that the Defendant in the above matter, having
been granted a Final Decree in Divorce on the 14th day of March, 2006, hereby elects
to resume the prior surname of Diane Marie Hoy, and gives this written notice pursuant
to the provisions of 54 P.S. 9704.
1/LI;i
Date
Ii U4\L, 7(lL/f-~ .1h.A./
'Diane Marie Hoy ~
)
(S'
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
On the a I ,")1 day of rich Ie. n , 2006, before me, a Notary Public,
personally appeared Diane Marie Hoy, known to me or satisfactorily proven to be the
person whose name is subscribed to the within instrument, and acknowledge that she
executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
NOWIW.IEAI.
.-:AA. HOClI"EASMJI(
Noby I'UbIIc
OM'--IOIOU&H. CUMlfltNC)cot.MY
IiIIv co............ ElCpRI Dee 22. 2001
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