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Home My WebLink About06-0489SUSAN R. TOBIAS, Plaintiff Vs. STEVE J. TOBIAS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. aG - 41?`J IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 in 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 Courthouse 1 Courthouse Square Carlisle, PA 17013 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 SUSAN R. TOBIAS, Plaintiff VS. STEVE J. TOBIAS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ?Jto- yy9 &ud 7"t, IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. SUSAN R. TOBIAS, Plaintiff vs. STEVE J. TOBIAS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. o6„- 'I F9 C-<a 77? IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, SUSAN R. TOBIAS, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is SUSAN R. TOBIAS, an adult individual who currently resides at 1112 Wansford Road in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is STEVE J. TOBIAS, III, an adult individual who currently resides at 1475 Valley Road in ETters, York County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 17 September 1994 in Shiremanstown, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. v+ Samuel L. A des Attorney for Plaintiff Supreme Court ID U 17225 525 North 12m Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ? i SUSAN R. TOBIAS ?y.,,,? `? , ?_ - ? ? - -, ,?. ?.: - ,? i?? ? ?a ? ? ?. '1 0 ?, __TI, ?? ? ? ? 'y,`'?`?\ :ti ? ?? (n, ?. .., ;, r 0 SUSAN R. TOBIAS, Plaintiff ) VS. ) STEVE J. TOBIAS, III, ) Defendant ) 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-489 Civil ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint in this matter and acknowledge receipt of a copy of the same. Date: =- V )U ----- Steve J. Tobia§Ill 1475 Valley Road Etters, PA V SUSAN R. TOBIAS, V. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE STEVE J. TOBIAS, III, Defendant To the Prothonotary: NO. 06-489 CIVIL PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearance of Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire and Beckley & Madden, of Counsel, on behalf of the Defendant, Steve J. Tobias, III, in the above-captioned matter. DATED: March 31, 2006 Thomas A. eckley, Esquire Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, Pennsylvania 17108 (717) 233-7691 EXizab'eth'S. Beckley,'-Esquire/ Attorneys for Defendant I r CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing document was served upon the following and in the manner indicated below: VIA FIRST CLASS MAIL Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 Dated: March 31, 2006 rl rya - > r ;:. - r. ,. . 'tl ?. :-i .-r..? ' .1 ? C:) JJ ?....? SUSAN R. TOBIAS, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-489 CIVIL TERM STEVE J. TOBIAS, III, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 25 January 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 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. Section 4904 relating to unsworn falsification to authorities. Dated: SUSAN R. TOBIAS ?i P"^T .. } '?,,. ...J ...?.{ {.. ? r_. ?;:. ?ti.# ? ..? ?1 _ SUSAN R. TOBIAS, Plaintiff VS. STEVE J. TOBIAS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-489 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 25 January 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 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. Section 4904 relating to unsworn falsification to authorities. t Dated: STEVE J. TOBI S, III C . ?3 CD LL s C"D `?7 SUSAN R. TOBIAS, VS. Plaintiff STEVE J. TOBIAS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-489 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. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceptance of Service filled by Plaintiff's counsel indicating service on or about 14 March 2006 on Defendant. 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 Plaintiff: 1 October 2007 By Defendant: 18 September 2007 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (a) or (b) : (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached : (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 1 October 2007. and filed on 8 Q Ober 2007. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 18 Sgptember 2007, and filed on 8 October 2007. Date : Y6 October 2007 B Sam eI L. Andes Attorney for Plaintiff f ^s f l" 1y W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SUSAN R. TOBIAS, Plaintiff VERSUS STEVEN J. TOBIAS, III, Defendant 2006-489 No. DECREE IN DIVORCE AND NOW, N D V C. w aty- ,7007IT IS ORDERED AND DECREED THAT SUSAN R. TOBIAS _ PLAINTIFF- AND STEVE J. TOBIAS, III ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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 THE COURT: PROTHONOTARY % ?W,-?rm -r-PVJ4 4a-e,)t /r *,P*' 4?1 - IV 41?1 - 25P , I I