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Home My WebLink About02-1139Jeannie E. Sweitzer, Plaintiff Chades Sweitzer, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA · NO. 0,~.- /IT CIVIL TERM : CIVIL ACTION :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 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 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 Ist 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 LAVVYER AT ONCE. IF YOU DO NOT HAVE A LAVVYER 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 (717) 249-3166 Jeannie E. Sweitzer, Plaintiff Charles Sweitzer, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 0~- /I..~ · CIVIL ACTION · IN DIVORCE CIVIL TERM COMPLAINT 1. Plaintiff is Jeannie E. Sweitzer, an adult individual, currently residing at 61 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Chades Sweitzer, an adult individual, currently residing at17 Glennwood Road, #3, Dillsburg, York 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 December 24, 1997 in Cumberland County. 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. 9. Plaintiff and Defendant are citizens of the United States of America. The parties have lived separate and apart since June 6, 1999 and continue to live separate and apart as of the date of this Complaint. 10. The parties marriage is irretrievably broken. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce. Respectfully Submitted TURO LAW OFFICES Date Robert J'. I~lulderig, Esquir'"E4 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for VERIFICATION I verify that the statements made in the foregoing Divome Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa. C,S. §4904 relating to unsworn falsification to authorities. Date a'n~[e E. S~ei~e~' ~" Jeannie E. Sweitzer, Plaintiff Charles Sweitzer, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. ~//o~ CIVIL TERM · CIVIL ACTION · IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. Jeannie E. Sweitzer, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01- CIVIL TERM Charles Sweitzer, Defendant : CIVIL ACTION :IN DIVORCE PLAINTIFF'S AFFIDAVIT UNDER §3301{D) OF THE DIVORCE CODE 1. The parties to this action separated on June 6, 1999 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 rights concerning alimony, division of marital property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF PA. C.S. {}4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Jeannie E. Sweitzer, Plaintiff Charles Sweitzer, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1139 CIVIL TERM : : CIVIL ACTION :IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Divorce Complaint and Plaintiff's Affidavit filed in the above captioned case upon Chades Sweitzer, by certified mail, return receipt requested on Mamh 8, 2002 addressed to: Chades Sweitzer 17 Glenwood Road, #3 Dillsburg, PA 17019 and did thereafter receive same as evidenced by the attached Post Office receipt card dated March 15, 2002. 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. Date TURO LAW OFFICES Robert J.~vluld~rig, Esqur~-r.~ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff C~mp~e #en'm 3, 4a, and 4b. 0 print your name and address on the reveme of this form so that we can return this card to you. 1. [] Addressee's Address Delivery 0 ~'Retum Receil~ Requested" on the mallweoe below the ~ num/oer. Q 'llm R~urn Receipt wifl show to whom the af~,cle was d.~ a~d the date 3. Alticle .N:ldressed to: . I [] Express Mail [] Insured .~ .RetumReceipt for Merchandise [] COD ; 8. Acldmssee's Address (~ ~y req d fee/s pa/d) Jeannie E. Sweitzer, Plaintiff Chades Sweitzer, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1139 CIVIL TERM : : CIVIL ACTION :IN DIVORCE DEFENDANT'S COUNTER AFFIDAVIT UNDER §3301(D) OF THE DIVORCE CODE Check either (a) or (b) ~"X'(a) I do not oppose entry of a Divorce Decree. __.(b) I oppose the entry of a Divorce Decree because: (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. Check either (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 or expenses if I 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. VERIFICATION I verify that the statements made in this Counteraffidavit 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. Date Jeannie E. Sweitzer, Plaintiff Charles Sweitzer, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1139 CIVIL TERM : : CIVIL ACTION :IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF 3301(D) DIVORCE DECREE TO: Chades Sweitzer, Defendant You have been sued in an action for divorce. You have filed a counter affidavit to the 3301(d) affidavit dated March 9, 2002. Therefore, on or after April 10, 2002, the other party can request the court to enter a final decree in divorce. 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 the form 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Respecffully submitted, ~u r w~oU I~u i re~/~/~ ~' 28 South Pitt St. Carlisle, PA 17013 (717( 245-9688 Attorney for Plaintiff Jeannie E. Sweitzer, Plaintiff Charles Sweitzer, Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1139 CIVIL TERM : : CIVIL 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: 1. Ground for divorce: irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail on March 15, 2002. 3. (a) Code: (b) Date of execution of the Affidavit required by §3301(d) of the Divorce February 22, 2002 Date of filing and service of the Plaintiff's Affidavit upon the Respondent: March 15, 2002 by Certified Mail Related claims pending: None. Date and manner of service of the Notice of Intention to file the Praecipe to Transmit the Record, a copy of which is attached: March 19, 2002 ' R(~ber~. Mulderig, ~quir~ Attorney for Plaintiff iN THE COURT OF COMMON PLEAS OF CUMBERL~ND COUNTY STATE Of PENNA. Je~_nnie E. Sweitzer VERSUS Charles Sweitzer N O. 02-1139 DecrEe IN DIVORCE DECREED THAT Jeannie E. Sweitzer Charles Sweitzer AND ~ IT IS ORDERED AND , PLAINTIFF, , 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; NOW By At J. / ~/ PrOTHONOTarY