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HomeMy WebLinkAbout02-0990 SAIDIS SHUFF, FLOWER & LINDSAY ATTOR/~Y~sATsLAW 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002- ~/qo CIVIL TERM ., : IN DIVORCE 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 Prothonotary 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 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff ,.v-v ?ar l J'.'L'Tn i'Ca' ;'Esquire ~ 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY A'I'TORNEYS*AT.LAW 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 - q~O CIVILTERM IN DIVORCE COMPLAINT DANIEL L. THUMMA, Plaintiff, by his attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is Daniel L Thumma, who currently resides at 43 West Louther Street, Carlisle, Cumberland County, Pennsylvania, where he has resided since at least 1990. 2. The Defendant is Christine M. Thumma, who currently resides at 43 West Louther Street, Carlisle, Cumberland County, Pennsylvania, where she has resided since at least 1990. 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 March 19, 1983 in Carlisle, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carliale, PA 6. The Plaintiff avers that 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. Date: SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff Carol O/Lin~ t'y~Esqu~"~ ID # 44693-' 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATTOR~YS*AT*LAW 26 W. High Street Carlisle, PA 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. Daniel L. Thumma SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 200~- ~c['l~ CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce in the above captioned matter Christine M. Thumma, Defendant SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 200~)- 990 CIVIL TERM .' : IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in Divorce in the captioned case. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: ~26'West High Street CaHisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATI'ORI~VS*AT*LAW 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002-990 CIVIL TERM : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 1, 2002, and reinstated on April 24, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed 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 request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Daniel L. Thumma,, Plaintiff Date: ~~' '.~2. SAIDIS SHUFF, FLOWER & LINDSAY A'rroRI~YS,,AT,.LAW 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002-990 ClVlLTERM : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 1, 2002, and reinstated on April 24, 2002. 2. The mardage of plaintiff and defendant is irretrievably broken and ninety days have elapsed 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 request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. Christine M. Thumma, Defendant Date: ~ [ ~./ (9~")' SAIDIS SHUFF, FLOWER & LINDSAY A'I'I'ORI~VS*AT.LAW 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-990 CIVIL TERM IN DIVORCE WAIVER OF NOTICE 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 dghts 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 this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Daniel L. '¢h~"mm-"~, ~ Plaintiff Date: ~/~ SAIDIS SHIJFF, FLOWER & LINDSAY ATrORI~VS*AT*LAW 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS. CHRISTINE M. THUMMA, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002-990 CIVIL TERM : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 13301(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 divome is granted. 3. I understand that I will not be divomed 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Christine M. Thumma, Defendant Date: ~//~/~ g:~ SAIDIS SHUFF, FLOWER & LINDSAY ATroRN~YS*AT*LAW 26 W. High Street Carlisle, PA DANIEL L. THUMMA, VS, CHRISTINE M. THUMMA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002-990 CIVIL TERM : Defendant : IN DIVORCE PRAEClPE 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 Section 3301 (c)vvv~'~, ,~/,/'~/~), of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant, Christine M. Thumma, on April 30, 2002, and filed May 3, 2002. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff August 8, 2002; by the Defendant August 8, 2002. 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of se~ice of the noti~ of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plainti~s Waiver of Noti~ in 3301(c) Divorce was filed with the Prothonota~: August 9, 2002 Date Defendant's Waiver of Noti~ in 3301(c) Divorce was filed with the Prothonota~: August 9, 2002 , IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF ~~.. PENNA. DANIEL L. THUMMA, Plaintiff VERSUS CHRISTINE M. THUMMA, Defendant NO. 2002 - 990 CIVIL TERM IN DIVORCE AND NOW,__ DECREED THAT AND DECREE IN DIVORCE DANIEL L. THUMMA CHRISTINE M. THUMMA ~~I~ IT IS ORDERED AND , PIA~ NTl FF, , 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 BY ATTEST: 'h e CO / J' ROTHONOTA~-Y