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HomeMy WebLinkAbout06-3503 WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle. Pennsylvania 17013 JOHN T. GLEIM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 06- 3'>03 CIVIL TERM SARA B. GLEIM, Defendant : 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. 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 CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 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 LA WYER 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 ~ f~ Wayne~e, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff JOHN T. GLEIM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 06- 35()3 CIVIL TERM SARA B. GLEIM, Defendant : IN DIVORCE COMPLAINT 1. Plaintiff in this Action in Divorce is JOHN T. GLEIM, an adult individual who resides at 312 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is SARA B. GLEIM, an adult individual and citizen of the United States of America who resides at 3 Courtyard Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. Plaintiff and Defendant were lawfully joined in marriage on October 9, 2002, in WAYNEF. SHADE Clarion County, Pennsylvania. Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 WAYNEF. SHADE Attorney at Law 53 West Pomfret Street Carlisle. Pennsylvania 17013 5. The parties have been living separate and apart since on or about December 1, 2005. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. Both parties to this Action in Divorce are legally capable of managing their own concerns. 9. Defendant herein is not a member of the armed forces of the United States of America. 10. There were no children born to the parties. -2- . WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 11. 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. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. $~k~ Wayne F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -3- . WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 170J3 I verifY that the statements made in this pleading 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: May 18, 2006 '- r_ '- '- ':''\ ~ ~ ~.' ~ ~li-.. \~ \ ~ ~ ,\ . t ~ ,~ ::i [ ~ "- w " ~ \U C) h'::' C- Zs () I';~':: v-" .} I,.t':; c :;! ITl :JJ r- ,"i"1 N o , J,.'.. -r; : ,; \._l ::::;;;: " ~.::' ~ "~-> ::y :-) (~ . ~, C) ,~:;~ -..) :.< WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 JOHN T. GLEIM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 06-3503 CIVIL TERM SARA B. GLEIM, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter. that he did, on June 20, 2006, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on June 21, :W06, as evidenced by the return receipt card attached hereto bearing Certified No. 70012510000658642465. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: June 23, 2006 ~~~a~ Wayn F. Shade Ul .lI :T nJ u') C:' E ~7: :T .lI '" Ul Postage Certtfied Fee C/o) ..0 Return Receipt Fee C (Endorsement Required) C C $1.85 $3.70 Restricted Delivery.fee (Endorsement Required) Total PolItage & Feea $ $8.58 ..... c ... Ul ru Sent To . ,.",~... "..J.., 'SiiMi:J1~~m!Lm.G.l~.;J,!!l.mmnnnm'~",."':"";:::~------'" .~':'.:t'~ur.tJl.ardn"12r"i.YiL.___.______n__""n".n..n.n. 1. ArtiaIeAd4 ~to: Sara B. Gleim 3 Courtyard Drive Carlisle, PA 17013 &-- . Cao1IIIod ... C~.4ld 0....- Moll 4. [] ~ Moll o -.", -.,.Ior Mon:hondIoe 00.0.0. 2. Miele Number ~--... .......... :1ft" __.., 70Ql 2510 0006 5&64 24&5 ---- ..- ".~ i~ ( ~= .~ ~'j~i ;",' C.J ~~ -\>~ ", ~t .-< ":, ( , W A YNF F. SHAD!: JOHN T. GLEIM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 06-3503 CIVIL TERM SARA B. GLEIM, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF JJ\TENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODE COMMONWEAL TH OF PENNSYL VANIA) ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under S3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on June 20, 2006, and served on June 20,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the {'ntry of a Final Decree of Divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property, /\ttorney at La\\ 53 West Pomtfet Street lawyer's fees or expenses if I do not claim them before a divorce is granted. Carlisle. Pennsylvania 17013 .~ . WAYNE F. SHADE Attorney at La,," 53 West Pomtret Slreet Carlisle, Pennsylvania 17013 5. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy 0 ('the Decree will be sent to me immediately after it is filed with the Prothonotary. 6. I have been advi .;ed of the availability of marriage counseling and of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counselin.s. 7. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, whicn list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I participate in counselins prior to a Divorce Decree's being handed down by the Court. 9. I verifY that the ~,tatements 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. 94904 relating to unsworn falsification to authorities. Date: November 3, 2006 ~~ Joh . GleIm r-.;) c::> C.:J c:;r. , -~ ~:~ C'f) o cr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN T. GLEIM No. 06 3503 CIVIL TERM Plaintiff vs. SARA B. GLEIM Defendant IN DIVORCE AFFTllA VIT OF CONSF.NT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 20, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the initial 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. 4. 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. 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:: \,h'}\~\' ~ --~~ "- Sara B. Gleim ------------- ~ ~ .::.--:.., ..::..y..... I ....J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN T. GLEIM No. 06 3503 CIVIL TERM Plaintiff vs. SARA B. GLEIM Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~~~Ol ~} OF TIm DTVORCF. CODF. 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 in 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. Date: ,()\~~loCt s "'-~ --.J.::;J. D L .-1M. - Sara B. Gleim r, r;."- ~-;;: . t'-.;l C-:'1 c-;~:> c:r> C:) 11 --.. en a (7, WAYNE F. SHADE Attorney at Law 53 West Pomtret Street Carlisle, Pennsylvania 17013 JOHN T. GLEIM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. 06-3503 CIVIL TERM SARA B. GLEIM, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 93301(c) of the Divorce Code. 2. The date and manner of service of the Complaint were June 20, 2006, to Defendant by United States certified mail, return receipt requested, addressee only. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention to Request Entry ofa Divorce Decree under 93301(c) of the Divorce Code by Plaintiff was November 3,2006, and by Defendant was October 22,2006. 4. Related claims pending: None. Date: November 3, 2006 ~~*~ Wavn F. Shade " Attorney for Plaintiff ~ 0 = -n ~~.; :r'f~:i - ..:- c;? o -,.~ <:J ::< --' "''''''' "''''''''''''''''''' '" "'~"'~~~~'" '" ~"'''''''''''''''''''~~ ~~"'~"'~ ~~'" ~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. JOHN T. GLEIM, Plaintiff No. 06-3503 CIVIL TERM VERSUS SARA B. GLEIM, Defendant DECREE IN DIVORCE AND NOW, l.\ 0" - l~ ,2006 , IT IS ORDERED AND DECREED THAT JOHN T. GLEIM , PLAI NTI FF, AND SARA B. GLEIM , 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 ATT PROTHONOTARY '" ~ "'~"'~"''''~ ~ ~ "''''~ ~ J. . ~ fr'.7 ~ '?!)!'J1. %" I'C"/I ~r?-~ ~~ 1f}' I~II . '\ IN THE COURT OF COl\1MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G\e\W\ ~\'\T Plaintiff File No. Ja'J(P - O-SSJ S IN DIVORCE Vs G lov\~\ ~C\1S Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or -t- after the entry of a Final Decree in Divorce dated ~ hereby elects to resume the prior surname of .Me \ s ; Y\~ -e r , and gives thi~ written notice avowing his / her intention pursuant to the provislOns of 54 P .S. 704. Date: ,,/21/0<,; Sa'ltt ~_ Signature COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF Cum,j~&.<J) - . < ~ fIVlL<Lu.u ""'- Signature of name being resumed S<:A. ,0.. M e. '\ So \ v'\~ e. r On the ;Z 7~ day of '11AKJ.J "1" l.n~ , 200~ before me, the Prothonotary or the notary public, personally appeared the above affiant mown to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. NOTARIAL SEAL. PROnfONOTARY, NOTARY MUD CARUSlE CUMBERlAND COUNTY COUR11fOUSE Prothonotary or Nntl'lry Public MY COMMISSION EXPIRES JANtMY 4, 2010 l' 0 ~ :.~~ , .-1 ftJ '" , -....J ,~- ~ ~ <II c:::.. f'.~) r c -.J "- ~ ~ \/\ ~ -.' ~ tJ ~ c;, " ~""1 :."'...,.......--':,~--.--._. ,.,.~ ,~), :; ,t JA~t~A\ U~~ :II.'" 'j '''Pit; iJI1Y :J.', .~. ",": ""'l'li, ""fTl1\,,QO fit ~ ,\'r' ; :\ l{\.V:"\i. i'l~J ~Y:~f;.~; '.'