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HomeMy WebLinkAbout06-2049 TAMMIE 1. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ADAM S. PETERS, Defendant CIVIL ACTION - LAW NO. 06 - .:{{YI7 CIVIL TERM IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIDLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ADAM S. PETERS, Defendant CIVIL ACTION - LAW NO. 06 - ::20'-19 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Tammie L. Peters, an adult individual, who resides at 448 Shed Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Adam S. Peters, an adult individual, who resides at 331 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on May 11,2002, in Newville, Cumberland County, Pennsylvania. S. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & WHARE Date:/l/,-; / ///2 606" / 7 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17241 (717) 241-6070 Supreme Court J.D. # 81924 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint 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: <pfn"! /IJ(fNo I TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. ADAM S. PETERS, Defendant CIVIL ACTION - LAW NO. 06 - CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certity that I this day served a copy of the Notice of Divorce Complaint upon the following by depositing same in the United States Mail, first class and certified mail with return receipt, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Adam S. Peters 331 Greenspring Road Newville, Pennsylvania 17241 Respectfully submitted, ROMINGER & WHARE Date: ;fj1r;;/ 'P / //2006 / / -----. Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17241 (717) 241-6070 Supreme Court J.D. # 81924 Attorney for Plaintiff 7C) n ~ r-_" - I"- ---- "-n tl -D ,-;' \i: ::~ \> -..l ,_-r"' . ,,;;.co_ . -- Gl ~ .1:: ~ ~ ~ --,..' . f'- ~ - - ,','"' if? -D P-~ ' ~., r-,) cD ~ C-' \ -<. ~ +-- ~;-- ~ TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 06 - 2049 CIVIL TERM IN DNORCE ADAM S. PETERS, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 11, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Dot, 7/;#&. Q , CJ ~'" (:::) ";,~;) (;;/", () "n c..J iJ (..J TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ADAM S. PETERS, Defendant CIVIL ACTION - LAW NO. 06 - 2049 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER f 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 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. -7f~ (-) "1-1 (. =' f;:cl:I) ,- .'c., ~;-~ GO " (-" TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW NO. 06 - 2049 CIVIL TERM IN DIVORCE ADAM S. PETERS, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 11, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: 7 -/3-0~ "r- - ..4-- ~~ Adam S. Peters, Defendant - 1"'."" r:-.:) C:',::l L.~'" ---; -'1'1 .-j ~- Fil ::D 1_'. '--'J (,-;: ,- j-; (.,0 ::.? -1;,. c , ,,',' ;'" .J] --<.; TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ADAM S. PETERS, Defendant CIVll... ACTION - LAW NO. 06 - 2049 CIVll... TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER * 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 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: 7-/3-~ f_ - g.~ ......J.-; _ Adam S. Peters, Defendant ,-, (,~ ::: I;'~) "" c::::::; \':,~';' c.l', G..:- .:~'J -<;; .~ i~l{r12 ~";TI . TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. ADAM S. PETERS, Defendant CIVIL ACTION - LAW NO. 06 - 2049 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behdf of the Defendant, Adam S. Peters, in the above-captioned action and I certify that I am authorized to do so. Date: . .y-#~ By: ~.. Adam S. Peters c-)(.l\..i b r+ II A" C l""' s- C:.; -r'l :::l --"- --. ij'lr=-:: _'_' rr' . ,-' ., c:') C''":: ..-- TAMMIE L. PETERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ADAM S. PETERS, Defendant CIVIL ACTION - LAW NO. 06 - 2049 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. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: April 12, 2006, certified mail, restricted delivery with return receipt, Acceptance of Service (attached as Exhibit "A"). 3. Date of execution of the affidavit of consent required by ~ 3301(c) of The Divorce Code: by the Plaintiff July 13, 2006; by the Defendant July 13, 2006. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: July 13, 2006. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: July 13, 2006. Date: July 14, 2006 Respectfully Submitted, Rominger & Wha~ 2- Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff :>, a C:,I !,--,) r::J {~;.:.:. L. """'- ""-':lI Cl " ::::J ;::~ ,,' . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. STATE OF . . . Tammie L. Peters, No. 06 - 2049 . . Plaintiff VERSUS . . Ad"m S Pet..r". Defendant . . . DECREE IN DIVORCE 'W , IT IS ORDERED AND . . . . . . . . AND NOW, . . . . DECREED THAT Tammie L. Peters , PLAINTIFF, . . AND Adam S. Peters , 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 J. PROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~ ~ ~}t, 10-~-c.. ~ ~ -? ~ 4/t;p-P') ~ tJe-L , - . . . . #:, ,,,,,......., . .. '~, t . .-\' -