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 . .-\' -