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Home My WebLink About06-1703 SALZMANN HUGHES, r.c. E. Ralph Godfrey, Esquire Attorney 1.1l. No. 71052 11 W. South Street Carlisle, P A 17013 Tell'phone: (717) 243-5100 Fax: (717)249-7334 E-mail: l"J;:odfrcy@}salzmannhughes.com Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA TOMMI LYNN LANTZ N/K/A AMBER LYNN LANTZ, NO.2006- nOS &;J Plaintiff vs. CIVIL ACTION -LAW IN DIVORCE DA VlD H. LANTZ, Defendant 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, 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 counseling, A list of marriage connselors is available in the Office of the Prothonotary at the Cumberland County Court House, I Courthouse Square, Carlisle, Pennsylvania 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY. MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED. 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 Lawyer Referral Service 32 S. Bedford Street Carlisle, P A 17013 (717) 249.3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA TOMMI LYNN LANTZ N/K/A AMBER LYNN LANTZ, NO.2006- /703 C-kJ 7iv-- Plaintiff vs. CIVIL ACTION -LAW IN DIVORCE DA VlD H. LANTZ, Defendant COMPLAINT IN DIVORCE I, The Plaintiff, Tommi Lynn Lantz nlkJa Amber Lynn Lantz, is an adult individual residing at 615 West Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 2, The Defendant, David H, Lantz. is an adult individual currently residing at RR I, Box 623, Port Royal, Pennsylvania, 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4, Plaintiffs social security number is: 164-58-2706; and Defendant's social security number is 177-60-0154. 5. The Plaintiff and Defendant were married on the December 5, 1998, in Cumberland County, Pennsylvania. 6. The Plaintiff and Defendant are not in the military or naval forces of the United States, 7. There have been no prior actions of divorce between the parties in this or any other state. 8. One child was born of the marriage: Adrian D. Lantz (d.o.b. 4/25/1999). COUNT I DIVORCE PURSUANT TO ~3301(c) & (d) OF THE DIVORCE CODE 9, Paragraphs One through Eight are incorporated herein by reference as if set forth in full. 10, Plaintiff avers that the marriage is irretrievably broken, 11. Plaintiff has been advised of the availability of marital counseling and that either party has the right to request that the court require the parties to participate in counseling, 12, The parties have separate and apart since September 12.2003. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree of divorce, COUNT II EOUITABLE DISTRIBUTION 13. Paragraphs One through twelve are incorporated herein by reference as if set forth in full. 14. The parties have acquired real and personal property. including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is martial property. WHEREFORE, Plaintiff requests the Honorable Court to enter a decree. which effects an equitable distribution of martial property. SALZMANN HUGHES, P.C. By: E, od, s re Attorney I.D. No. 354 Alexander Spring Road Suite 1 Carlisle, PA 17013 (717) 249-6333 Attorneys for Plaintiff Dated: 3 -,,13 -0<':' VERIFICATION !, Tomm:; L. Lantz nlk/a Amber Lynn Lantz. do hereby verify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. 4~ ti:~ Date: d-I 7 -0 ~ ~ "I-J \u "" ~ "" v. ~. ~ ~ ~ ~ ~ <:-:, "\ "\ , . f-" "" ~ ~ ~ ~ ~ IA. n (:''-..~' () C t',.-,> ."r' ~ \)I c. ~.>..... ,-, --- <:;u '\ ~ ~ .~... , - - ~ _I,. -r' --J w " '\ "- "l::, ;\\i:":. , "- ,,'-., V'\ ~ ~ , "'- j.-., ~- i \. <-'" .'/) )J , \~ ,~. ~ ~ ' ," V; ~\~ -,,~ "-.J (~.? ~_..) l ,...~ "- "', ~ ~ ~ .------ . SALZ!\lANN HlJGHES, r.c. E. Halph Godfrey. Esquire AUornl'}' 1.0. No. 77052 354 Alexander Spring Road, Suite 1 (:arlislc. PA ) 7013 Telephone: (717) 249-6333 fax: (117) 249~7334 E~nlail: rgollfrcyt'a)salzmannhughes,c()m Attorney (or Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TOMMY I.YNN LANTZ N/KJA AMBER LYNN LANTZ, NO. 2006- 110 3 Plain tiff vs. CIVIL ACTION -LAW IN DIVORCE DAVID H. LANTZ, Defendant PROOF OF SERVICE T, E, Ralph Godfrey, do hereby certify that on April 21, 2006, a copy of the Court of Common Pleas Complaint filed in the above referenced matter was served upon David H. Lantz by personal service as evidenced by the executed Affidavit attached hereto. SALZMANN HUGHES, P.c. <I-~~- tJc' By ------ E. Ralph Go rey, Ire Attorney LD, . 77052 354 Alexander Suite I Carlisle, PA 17013 Attorneys for Plaintiff SALZMANN HUGHES, P.c. E. Ralph Godfrey, Esquire Attorney J.D. 1\0. 77052 354 Alexander Spring Road, Suite 1 Carlisle, PA 17013 Telellhullc: (7\ 7) 249-6333 FaX' (717)249.7334 [-mail: rgodfrey@}salzmanllhu~hfs.com Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TOMMY LYNN LANTZ N/K/ A AMBER LYNN LANTZ, NO. 2006- '-1 [) 3 Plaintiff vs. CIVIL ACTION -LAW IN DIVORCE DAVID H. LANTZ, Defendant AFFIDAVIT OF SERVICE I, S /)jvI.{)rt:!. Sctl.J vr-! l- , hereby certify that I served a copy of the Complaint in Divorce on David H. Lantz on April 21, 2006, I further state that I am not a party to this action and am over the age of 18. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are madc subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. '\ ~~ n -< r ~., C,' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TOMMI LYNN LANTZ N/K/ A AMBER LYNN LANTZ, Plaintiff NO. 2006- I ~~ '3 V5. CIVIL ACTION -LAW IN DIVORCE DAVID H. LANTZ, Defendant AFFIDAVIT OF CONSENT I. A Complaint in divorce under S3301(c) of the Divorce Code was filed on March 23, 2006, and served on April 21, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint 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. S 4904 relating to unsworn falsification to authorities. Dore.J \, '\(010 J.tw:&:~ Tomml Lynn ant a e Lynn Lantz I '4 I '.", . .. , ~: (') ...., CJ => c_~ t:,C:> "'r1 c-:.,--.. :::::\ l"'. f-,) 0'1 C",) <" -....:..., I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA TOMMI LYNN LANTZ N/KJA AMBER LYNN LANTZ, Plaintiff NO. 2006- rhl 3 vs. CIVIL ACTION -LAW IN DIVORCE DAVID H. LANTZ, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER &3301(C) AND & 3301(D) 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! 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. S 4904 relating to unsworn falsification to authorities. Date:],/l-I./ {Of. Tommi L. Lantz tz >-1 .+ ,.\ I 1. I ,0 1\.' " ::::j ", ~" GJ ......., :~~J --.;;; .~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA TOMNULYNNLANTZ~IDAAMBER LYNN LANTZ, Plain tiff NO.2006- I'h3 V5. CIVIL ACTION -LAW IN DIVORCE DAVID H. LANTZ, Defendant AFFIDAVIT OF CONSENT A Complaint in divorce under ~3301(d) of the Divorce Code was filed on March 23, 2006, and served on April 21 , 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint 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. ~ 4904 relating to unsworn falsification to authorities. Date:-2fZ.'t \<20 S~.f,,1 ~ ;b David H. Lantz ~ <i.~:::' , I , 1 j i I 1 ] " I 1 1 1 :::1 -~ r-..) (..i; I..' \'" .'i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TOMMI LYNN LANTZ N/K/A AMBER LYNN LANTZ, Plaintiff NO. 2006- "~b '3 vs. CIVIL ACTION -LAW IN DIVORCE DAVID H. LANTZ, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER &3301(C) AND !! 3301(D) 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! 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. S 4904 relating to unsworn falsification to authorities. Da;~:" /2.'-t !Olp f~.~ 1/1. ~ David H. Lantz 0 ~.', " I --::-1 ~, ( . ~ r'< '\ ~ .... IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TOMMI LYNN LANTZ N/KJA AMBER LYNN LANTZ, Plaintiff NO.2006-I-lil~ VS. CML ACTION -LAW IN DIVORCE DAVID H. LANTZ, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entIy of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under ~3301(c)(I) of the Divorce Code. 2. Date and manner of service of Complaint: SeIVed upon Defendant: Personal services, on April 21, 2006. Affidavit of Service filed on April 25, 2006. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiff's and Defendanfs Affidavits of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request EntIy of a Divorce Decree under Section 3301(c) of the Divorce Code, pursuant to Pa.R.C.P. 1920.42(e)(I): Plaintiff - 7/24/06 Defendant - 7/24/06 ~ ... (b)(1) Date of execution of Plaintiff's affidavit required by Section 330 I (d) of the Divorce Code: N/A; (2) Date offiling and service of Plaintiff's affidavit upon the respondent: N/A. 4. Complete the appropriate paragraphs: (a) Related claims pending: All claims have been resolved by a signed Marital Settlement Agreement. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: N/A (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: 7/25/06 (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 7/25/06 . alp Godfrey, Esq . e I.D. No. 77052 354 Alexander Spring Road Suite I Carlisle, P A 17015 (717) 249-6333 Attorneys for Plaintiff , .. CERTIFICATE OF SERVICE AND NOW, this '2.( day of l.J \'-1 ,2006 I, E. Ralph Godfrey, Esquire, . of Salzmann Hughes, P.C. attorneys for Plaintiff, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed to: David H. Lantz RRl Box 623 Port Royal, P A 17082 SALZMANN HUGHES. P.C. ~ .' ., I I ! q f-:'> ,:~-_ '.l '--'.? ,>-, .~ :-j Ui -"-~ ,'..,-: _--.\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . f TOMMI LYNN LANTZ NIK/ A AMBER "," LYNN LANTZ No. 06 - 1703 P laimiff . VERSUS DAVID H. LANTZ Defendant DECREE IN DIVORCE . . . AND NOW,-.Q"j"'<:' t t . 2.60 (. , IT IS ORDERED AND TOMMI LYNN LANTZ N/KI A AMBER LYNN LANTZ DECREED THAT , PLAINTIFF. . DAVID H, LANTZ . AND , 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; . . . . . . . . . . . . . . . . . .~ . . (~Spfr~~l . ~ !1 t'fr(J'1MI ~J.l, ?(J' (jf-} lIP ~ ~ 4;.n ?JfJ' Of-})