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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 ~---- lii# q Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff !'I 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. // /dJ /tJ.>~ Date <11 ~ ~~ '\. ~~ ~. -- Q] ~~ v \::) "'^' '- .'^ "\\ ,\ "\ ~) ~'~ ~ \ ~= '" :--~, ~~~ ~ ~ " ~ ~".. ..~ , ') -~ C) --n ::-1 ", r..J f'.; \~.) c"' 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. (--) .o.:rl r~,) C::J ~~...J - 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 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 n \ rr~ r_'. (-::; 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. d~t- :"-J ~: 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 k / Vr1 fvf/'- ohn Thielemann (' ...~:. ~ 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 -..,. <,. 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 ------ 'I'~:+:;+' :+: + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . . . . +.:+::+::+::+::+:~:+::+::+:+.+.:+::+::+::+: .. +:+:++.:+::+: + +:+: +. + :+: + + + ++ . . . . . . . . . . . + . . . + . . . . . . . . . . . + . . + + + . + . + + + + + . . . + + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + + + + + . + . :+:+.+:+::+::+:+:+:+:+:+++.++++.++.++:+:++~+:+:+++++++++++.++ ++.~++:+:++.:+:++:+::+::+::+::+::+::+:++.+:+:+++++++++.+++.+. 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. '\t' . + + + . + + . . + . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . + . . . . . . . . . . . + + . ~++:+::+:++:+:+++++:+:+++++++:+:++:+:+.+++++++~++:+:+ 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 (") '"" 0 ~ ~ --{. c:;:, F:'-- ~ <:::'\ ,~, ~c~ ,= -n , ~ c~ ~' r-- -''(.1 -"- :r.!.." I" ~-.-l :r- r' ;;;0 rnp e' 1'0 -::;iTl -' r "::3~:, '-", " --0 (j;:? ......~ ::s: " '" (~rll ('" ~ :---t ~;; 1'0 ";0 c.; -<. ;AU ;J.I-d,lCM >,i;lti -.,,~)il.()H J~ ~-j.a-... ~'lv" ",)I"::V! '< iI' ~,.I",}i: >'l~.~' ~,~~-H()iilC#f !)tt~",1 >It:~: ,\ ",'..;.iH.~",~j 1~~.UI('l\rm") ~