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Home My WebLink About06-1029IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, NO. Plaintiff vs. CIVIL ACTION - LAW BETH ANN FAGER, Defendant 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 may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. Ajudgment may also be entered against you for any other relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the grounds 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, 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 ASSISTANCE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 AVISO PARA DEFENDER Y RECLAMAR DERECHOS USED HA SIDO DEMANDADO EN LA CORTE. Si desea defederse de las quejuas expuestas en las paginas siquientes, debe tomar accion con prontitud. Se le avisa que si not se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades y otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, Carlisle, Pennsylvania 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO Y OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telefano: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, NO. ?? - 16.2 9 010 i Plaintiff l vs. CIVIL ACTION - LAW BETH ANN FAGER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 15th day of February, 2006, comes the Plaintiff, Timothy R. Fager, by his attorney, G. Patrick O'Connor, Esquire, Office of G. Patrick O'Connor, Esquire, and files the following Complaint in Divorce whereof the following is a statement: 1. The Plaintiff, Timothy R. Fager, is an adult individual who currently resides at 645 Saint John's Drive, Camp Hill, Cumberland County, PA 17011. 1 The Defendant, Beth Ann Fager, is an adult individual who currently resides at 108 S. High Street, Mechanicsburg, Cumberland County, PA 17055. 3. The Plaintiff and Defendant were married on or about October 3, 2000 and separated on or about January 11, 2006. 4. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment between the parties. 6. 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. Both the Plaintiff and Defendant are sui juris and are citizens of the United States. 8. The Plaintiff avers as the grounds upon which this action is based is that: (A) That the Defendant has offered such indignities to the Plaintiff, including the injured and innocent spouse, including adultery, as to render her condition intolerable and life burdensome, or in the alternative: (B) That the marriage between the parties hereto is irretrievably broken. WHEREFORE, the Plaintiff request your Honorable Court to enter a decree divorcing the Plaintiff and Defendant absolutely. Respectfully submitted, G. Patrick O'Connor 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 ID No. 64720 Attorney for the Plaintiff VERIFICATION I, TIMOTHY R. FAGER, state that I am the PLAINTIFF in the above-captioned case and that the facts set forth in the foregoing are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unworn falsification to authorities under 18 Pa.C.S. See. 4904. J .? X Timothy R. Fager Date: ,, n ? ?? ?? ? '-, :, ,> ? d ? ?. ?' a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, NO. 06-1029 Civil Term Plaintiff VS. CIVIL ACTION - LAW BETH ANN FAGER, Defendant IN DIVORCE REQUEST FOR MARRIAGE COUNSELING To: The Prothonotary of the Court of Common Pleas Cumberland County, Pennsylvania Timothy R. Fager, plaintiff in the above captioned case, pursuant to §3302 of the Domestic Relations Code, Rule 1920.45 of the Pennsylvania Rules of Civil Procedures, and Local Rules of Court 1920.45-3 and 1920.45-4, requests that the Court order that up to three (3) marriage counseling sessions. The plaintiff requests that the first session be scheduled for Thursday, March 23, 2006 at 2:00 p.m. at the offices of Hoffman Psychological Associates, 3029 North Front Street, Harrisburg, Pennsylvania. The plaintiff further requests that he be provided the option to schedule up to two (2) additional sessions following the completion of the above scheduled counseling session. Please forward a copy of this request to the Court so that the Court may enter an appropriate order. A proposed order to attached. Thank you for your consideration. l Respectfully submitted, ' av iG. Patrick O'Connor, Esq. Attorney I.D. #64720 3105 Old Gettysburg Rd. Camp Hill, PA 17011 717-737-7760 Attorney for the Plaintiff Dated: February 22, 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. EAGER, NO. 06-1029 Civil Term Plaintiff VS. CIVIL ACTION - LAW BETH ANN EAGER, Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I have this day served a copy of the foregoing Request for Marriage Counseling upon the person indicated below, by first-class U.S. mail, postage- prepaid, from Camp Hill, Pennsylvania, to: Beth Ann Fager 108 S. High Street Mechanicsburg, PA 17055 DATED: February 23, 2006 Respectfully submitted: G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 ID No. 64720 Attorney for the Plaintiff r-,? ?? ?? ..? i-'. ? t. T'' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, NO. d (o - f D 2 9 C v. % %K Plaintiff VS. BETH ANN FAGER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Timothy R. Fager, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. I hereby request that the court require that my spouse and I participate in marriage counseling and that the Prothonotary provide me with a list of marriage counselors. 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. lO?Ow Jet o 1/?(? Date: Timothy R. Fager (?: ?i __. ? _t _.. -I _....... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-1029 CIVIL CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT Pursuant to §3302 of the Domestic Relations Code, Rule 1920.45 of the TIMOTHY R. FAGER PLAINTIFF V. BETH ANN FAGER DEFENDANT Pennsylvania Rules of Civil Procedures, and the Cumberland County Rule of court 1920.45-3 and 1920.45-4, IT IS HEREBY ORDERED AND DIRECTED: 1. That the parties above shall attend a marriage counseling session on or before March 31, 2006 at a time convenient to both parties. The defendant is ordered to cooperate in the scheduling of the required counseling session to ensure that it is completed prior to March 31, 2006. 2. That the Plaintiff may schedule up to two additional counseling sessions, at his discretion, at times mutually agreeable with the defendant. 3. That a report shall be made by the qualified professional counselor to this Court verifying the attendance of the parties. 4. That all costs of the requested counseling shall be borne by the Plaintiff. By the Court, 11A -? M. L. Ebert, Jr., J. `i ?.; ? ?.'? .?.. G. Patrick O'Connor, Esquire Attorney for Plaintiff Beth Ann Fager Defendant -1- 66 bas TIMOTHY R. FACER, Plaintiff V. BETH ANN FAGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1029 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Keith O. Brenneman, Esquire and Snelbaker & Brenneman, P. C. as attorneys for the Defendant Beth Ann Fager in the above-captioned action. SNELBAKER & BRENNEMAN, P. C. BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 Date: March 7, 2006 (717) 697-8528 Attorneys for Defendant Beth Ann Fager LAW OFFICES SNELBAKER & BRENNEMAN, P.C. CERTIFICATE OF SERVICE. I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: G. Patrick, O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 Keith O. Brenneman, Esquire SNELBAKER & BRENNEMAN, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Date: March 7, 2006 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. AFFIDAVIT State of Pennsylvania ) ) SS: County of Dauphin ) Before me the subscriber personally appeared John P Chronister to me known, being duly sworn according to law, doth depose and say that on February 21, 2006 @ 2.15 PM I served a copy of a Complaint In Divorce in person to Beth Ann Pager at her residence of 108 S. High St., Mechanicsburg, PA 17055 in the matter of Timothy R Fager vs. Beth Ann Fager, Court of Common Pleas of Cumberland County, Case No. 06-1029 Civil Action - Law in Divorce and further deponent sayeth not. 7R,ohn P. Chronister 5235 N. Front St. Harrisburg, PA 17110 Sworn and subscribed before me this ,9 1X.11. day of 2006 Notary Ptfy13Lc COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wendy M. Johnston, Notary Public Susquehanna Twp., Dauphin County My Commission Expires Oct 24„2008 Mombor, PennsYt'wnla Aa.oaiatien of Neta,!". r--Ol ? 0 -n i:' "ts IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, NO. 06-1029 Civil Term Plaintiff ; vs. CIVIL ACTION - LAW BETH ANN FAGER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 21, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and date of service of the Complaint. 3. I consent to the entry of a final decree of 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. 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. DATE: I/?2 Timothy R. Fa er, Plaintiff ,- M r? Z7 N) Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, Plaintiff VS. BETH ANN FAGER, Defendant : NO. 06-1029 Civil Term CIVIL ACTION - LAW IN DIVORCE 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 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 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. DATE: 1J`2-7-07 Timothy R. F ger, Plaintiff t? C -a7 ? n 3,: rn S :s mom rri N P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, Plaintiff VS. BETH ANN FAGER, Defendant NO. 06-1029 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 21, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATE: Beth Ann Pager, Defendant r-3 -on G7 ?-n n s?? 1' t r.?? ?-.'JI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, Plaintiff VS. BETH ANN FAGER, Defendant : NO. 06-1029 Civil Term CIVIL ACTION - LAW IN DIVORCE 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 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 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. DATE: 1 3 _? a,- ? O Beth Ann Fager, Defendant e-% rya O C= ?rt rVI -t- !J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TIMOTHY R. FAGER, NO. 06-1029 Civil Term Plaintiff VS. CIVIL ACTION - LAW BETH ANN FAGER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD Grounds for divorce: ? Section 3301(c) of the Divorce Code Section 3301(d) of the Divorce Code (a) Date complaint filed: February 21, 2006 (b) Date of service of the complaint: February 21, 2006 (c) If service 30 days after date of filing, date complaint reinstated: (d) Manner of service of the complaint: Certified mail, restricted delivery to and return receipt signed by defendant First-class mail-not returned, certified mail refused, 15 days have elapsed Date of mailing: Date certified mail refused: Personal service by Sheriff and/or Deputy Sheriff ,C Personal service by competent adult other than Sheriff Acceptance of service (Copy attached) By publication pursuant to Order of Court (Copy of Order attached) (a) Affidavit of consent required by Section 3301(c) of the Divorce Code: Date of execution: plaintiff November 27, 2007 defendant: November 27, 2007 Date of filing: plaintiff contemporarily herewith defendant: contemporarily herewith (b) Plaintiffs affisdavit required by Section 3301(d) of the Divorce Code: Date of execution: Date of filing: Date of service upon defendant: Manner of service: Related claims pending: (a) Date of service of the notice of intention to file praecipe to transmit, a copy of which is attached: Manner of service: (b) Date waiver of notice to file praecipe to transmit was filed with the Prothonotary: By plaintiff. contemporarily herewith By defendant: contemporarily herewith VERIFICATION I verify that the statements made in this praecipe are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: ??- Zf -Zd0 T Attorney for Plaintiff ?. Q ?? ;? t° xa N .,, ?.> t> ? ? ^ <? ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TIMOTHY R. FADER ` NN N O. 06-1029 Civil VERSUS BETH ANN SAGER Defendant DECREE IN DIVORCE AND NOW, 0 2ctmbtf 3I , 1007 , IT IS ORDERED AND DECREED THAT Timothy R. Fager , PLAINTIFF, AND Beth Ann Fager , 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 THE COURT: PROTHONOTARY 17 /.' C/ s?k 2 M