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Home My WebLink About06-1342EVELYN E. SOEHNER, Plaintiff V. THOMAS E. FINK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. (2y - 13yd,_ (?t U r C? 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 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. 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 (717) 249-3166 (800) 990-9108 EVELYN E. SOEHNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW / NO. THOMAS E. FINK, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, EVELYN E. SOEHNER, by and through her attorneys, Butler Law Firm, and seeks to obtain a Decree in Divorce from the above-named Defendant, THOMAS E. FINK, upon the grounds hereinafter set forth: 1. Plaintiff is EVELYN E. SOEHNER, an adult individual, residing at 788 Brentwood Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is THOMAS E. FINK, an adult individual, residing at 1045 Brentwood Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 23, 1980, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of United States of America. 7. The Defendant is not a member of the Armed Services of the United States. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that he may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff, EVELYN E. SOEHNER, respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code. DATED: 31L ' ° & Respectfully submitted, BUTLER LAW FIRM Attorneys for Plaintiff d By: onald D. Butler, Esquire I.D.#09865 500 N. Third Street, 12`" Floor Harrisburg, PA 17101 (717) 236-1485 VERIFICATION I, EVELYN E. SOEHNER, hereby certify that the facts set forth in the foregoing Complaint in Divorce are true and correct according to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Evelyn' . Soehner /r Dated: 11 A, -6a d W w EVELYN E. SOEHNER, Plaintiff V. THOMAS E. FINK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1342 IN DIVORCE AFFIDAVIT OF RETURN OF SERVICE BY NIAIL 1, Jana Butler Toole, Esquire, hereby certify that I mailed a true and correct copy of the Complaint filed in the above-referenced matter by certified mail, return receipt requested, to Defendant, Thomas E. Fink, Defendant, at 1045 Brentwood Road, Camp Hill, Pennsylvania 17011. Thomas E. Fink, signed the return receipt upon delivery on March 18, 2006. The return receipt is attached hereto as Exhibit "A". 1 , A Jain Butler Toole, Esquire Attorney for Plaintiff I.D. #80574 500 North Third Street, 12`? Floor P.O. Box 1004 Harrisburg, PA 17108 (717) 236-1485 EXHIBIT "A" cr .-• H o m ° D v s c? 00?33O C .`'.. ?p P. a S w A$ mr?c m 3 CT n A y N ? ti d ? 0 ?.:. o ?, N I ? . S m < v ° 8 . g' n n CD ~ m S 0 0 0 O 5 S2 9X Postal F y r • CERTIFIED MAIL p N m m m co (Domestic Only; No Insurance Coverage Provided) M W R c O ^J 3 o a m Postage 3 '! O ? ?? m wa ft fn O O aemfled Fee OLD' I 1 ? O O c m m y a O _ Postmark Return Reeeipf Fee S 5 ere t„dors='ent Required) / lIl '^ Q , w $ C3 O O HesMgetl Delivery Fee fEndnrsemen[gequlred? _ it ? ? 7 ,? n ? m^ C Z o ry ry Total Postage 8 Fees 4 9 D - 3 -15 Ob o . 3 O m a aanq r nt r R' ---- 11OCn.LI? -. ?.--- ?LY? ---- ------ t t f' ? tir eet A No F p - Poae.N 1Qz4 5 3 f J'B d v n Ka reA ou ?a,nfl l II. PA 1-7011 $ R o ° EVELYN E. SOEHNER, Plaintiff VS. THOMAS E. FINK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1342 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 9 March 2006 and served upon the Defendant thirty days thereafter. 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. I 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. 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 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. c Dated: THOMAS E. FINK RLED-L't'E" CE O rrIE THwTARY 209 SEP -8 AM 10: 5 5 CLWBERli.Yu Cf)ONTY MAISY..VANIA. EVELYN E. SOEHNER, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) CIVIL ACTION - LAW THOMAS E. FINK, ) NO. 06-1342 Civil Tenn Defendant ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 9 March 2006 and served upon the Defendant thirty days thereafter. 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. I 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. 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 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: EVELYN E. SOEHNER RSD-QWAQE OF THE TAW 2009OCT -2 AM 11:26 CUi vw "lu 'til ? Oj'N`fY € ENNSYLVANIA EVELYN E. SOEHNER, Plaintiff VS. THOMAS E. FINK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA } CIVIL ACTION - LAW NO. 2006-1342 CIVIL TERM 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 Section 3301(c). 2. Date and manner of service of the Complaint: Acceptance of Service indicating service on or about 23 March 2006. 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. 28 September 2009 by Defendant: 10 August 2009 Code: (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce (2) Date of filing and service of the Plaintiff's 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 28 September 2009 and filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 10 August 2009 and field on 8 September 2009. Date: 29 September 2009 By wsts? uSafhuel L. Andes Attorney for Plaintiff RUD-OFFIOE OF nrovwr 2009 OCT -2 AM If: 2 7 PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EVELYN E. SOEHNER, V. THOMAS E. FINK, DIVORCE DECREE AND NOW, 2430 , it is ordered and decreed that EVELYN E. SOEHNER, plaintiff, and THOMAS E. FINK, defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, hk-?- Attest: J. rothonotary NO. 2006-1342 ,o1 /? 1c,g ?L4Gl. ? t?7 ` cc,+ 4o M4`1 L? Cory ryt •a