HomeMy WebLinkAbout06-1958
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Defendant
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CHRIS S, FUCHS,
Plaintiff
vs.
CIVIL ACTION - LAW
NO, C (; - J <; 5" ; C'",.;t '-r;.-~
DAVID J, FUCHS,
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
.
II
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Defendant
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CHRIS S, FUCHS,
Plaintiff
vs.
CIVIL ACTION - LAW
NO. Di" , jq<;y e,~d I L_
DAVID J, FUCHS,
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.
II
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Defendant
)
)
)
)
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CHRIS S, FUCHS,
Plaintiff
vs,
CIVIL ACTION - LAW
NO. Df. ' J (;.)~. ('a:;j
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DAVID J, FUCHS,
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, CHRIS S. FUCHS, by her attorney,
Samuel L, Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is CHRIS S. FUCHS, an adult individual who currently resides at
4120 Roth Farm Village Circle in Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is DAVID J. FUCHS, an adult individual who currently resides
at 31 Ashwood Avenue in Summit, New Jersey 07901.
3. The Plaintiff has been a bona fide resident 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 1 September 1991 in Key West,
Florida.
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.
II
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,
~~~
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th 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,5, 4904 (unsworn falsification to authorities),
Date:
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CHRIS S, FUCHS, ) IN THE COURT OF COMMON
PLAINTIFF ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
)
vs, ) CNIL ACTION - LAW
)
) NO. 06-1958 Civil Term
DAVID J. FUCHS, )
DEFENDANT ) IN DIVORCE
ACCEPTANCE OF SERVICE
I, DAVID J. FUCHS, hereby accept service of the original Complaint in Divorce and
acknowledge receipt of a copy of the Complaint.
Date:
'-( /10 jot",
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DAVID J. FUCH
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CHRIS S. FUCHS,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 06-1958 CIVIL TERM
DAVID J. FUCHS,
Defendant
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: Acceotance of Service filed bv Plaintiff's
counsel indicatinl! service on or about 10 Aoril 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: 17 AUl!ust 2006 By Defendant: 17 AUl!ust 2006
(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 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 17 AUl!ust 2006 and filed contemooraneouslv herewith. Date
Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 17 AUl!ust 2006 and filed contemooraneouslv herewith,
Date: 17 August 2006
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Attorney for Plaintiff
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CHRIS S. FUCHS, ) IN THE COURT OF COMMON
Pla.1nt1ff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
)
VB. ) CIVIL ACTION - LAW
)
) NO. 06-1958 CIVIL TERM:
DAVID J. FUCHS, )
Defendant ) IN DIVORCE
AFFIDAVIT OF COliSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed
on 5 April 2006 and served on 10 April 2006.
2. The ma.rr1age of Pla.1nt1ff and Defendant 18 irretrievably broken and. ninety
(90) da.vs have elapsed from the date of both the fI11ng and service of the complaint.
3. I consent to the entry of a ftDa.l decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF IRTE!1TION TO 1I.'R!QUEST lll1\1T'JlY
OF A DIVORCE DEr!1I.1llE UlmER SECTION 3301(0) OF TmP. DIVORCE CODE
1. I consent to the entry of a ftnal decree in divorce without notice.
2. I understand that I ma,y lose rights concern1ng alimony, div1s1on of
property, lawyer's fees, or expenses 1f I do not "lA,1m them before a divorce 18 granted.
3. I understand that I will not be divorced until a divorce decree 18 entered by
the oourt and that a copy of the decree will be sent to me immedJately a.fter it 18 filed
with the Prothonotary.
I ver11Y that the statements made in this AfI:ld.a.v1t 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 fA,lAtlloation to authorities.
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Dated:
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CHRIS S. FUCHS
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CHRIS S. FUCHS,
Pla.1nt1ff
CIVIL ACTION - LAW
NO. 06-1958 CIVIL TERM
DAVIDJ. FUCHS,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Compla.1nt in Divorce under Section 3301 (0) of the Divorce Code was 1lled
on 5 Apr1l2006 and served on 10 Apr1l2006.
2. The m.a.rrtage of Pla.1nt1ff and Defendant 18 irretrievably broken and ninety
(90) da,ys have elapsed from the date of both the fIl1ng and service of the compla.1nt.
3. I consent to the entry of a fInaJ. decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OlP NOTICE OF INTENTION TO BEQUEST EBTBY
OlP A DIVORCE DECREE UNDER SECTION 3301(0) OlP 'I'RlP. DIVORCE CODE
1. I consent to the entry of a fInaJ. decree in divorce without notice.
2. I understand that I ID.8iY'lose rights ooncern1ng alimony, division of
property, lawyer's fees, or expenses 1f I do not olaim them before a divorce 18 granted.
3. I understand that I will not be divorced until a divorce decree 18 entered by
the court and that a copy of the decree will be sent to me immediately attar it 18 1lled
with the Prothonotary.
I verUY that the statements made in this .Afl'l.davit 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 falAifloation to authorities.
2117 JOb
Dated:
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DAVID J. FUCHS
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
CHRIS S. FUCHS,
Plaintiff
No.
2006-1958
VERSUS
.
DAVID J. FUCHS,
Defendant
DECREE IN
DIVORCE
.
AND NOW,
~J-_{a-.
CHRIS S. FUCHS
/....
2006
, IT IS ORDERED AND
.
DECREED THAT
, PLAINTIFF,
DAVID J. FUCHS
, DEFENDANT,
.
AND
.
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:; COU:4 ~
ATTESl': tle.L~. J,
C .~:::::: 77 P'OTHONOTA"
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