HomeMy WebLinkAbout06-3598
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CRYSTAL 1. PEFFER
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
DOUGLAS R. PEFFER,
: NO. LXi ~ 3~tq g
Defendant : IN DIVORCE
CIVIL TERM
NOTICE
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 the Cwnberland County Court House, High and Hanover Streets, Carlisle.
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
HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cwnberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Phone: (717) 249-3166
.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CRYSTAL 1. PEFFER
v.
: CIVIL ACTION - LAW
DOUGLAS R. PEFFER,
:NO. oc.- 3S<if
Defendant : IN DIVORCE
CIVIL TERM
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Crystal 1. Peffer, who currently resides at 160 North Orange Street, Carlisle,
Cumberland County, Pennsylvania, since 2002.
2. Defendant is Douglas R. Peffer, who currently resides at 175 South Orange Street,
Carlisle, Cumberland County, Pennsylvania, since July 2005.
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 November 4 1995 in Las Vegas, Nevada.
5. 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 of Divorce.
.
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. S 4904, relating to unsworn
falsification to authorities.
Date: l,Q!;A ~ \ 0 Co
G~.tlf~~, P~IA
Crys L. Peffer, P .ntiff
ANDREWS & JOHNSON
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CRYSTAL L. PEFFER
v.
: CIVIL ACTION - LAW
Defendant
: NO. 06-3598 CIVIL TERM
: IN DIVORCE
DOUGLAS R. PEFFER,
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND )
AND NOW, this 29th day of June 2006, I, Ronald E. Johnson, Esquire, attorney for Crystal L.
Peffer, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint
in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter,
upon the Defendant at his residence at 175 South Orange Street, Carlisle, P A 17013 by depositing the same
in the U. S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the
return receipt card signed by the Defendant on June 27, 2006, and the track/confirm form from the
postmaster indicating service was effected, is marked Exhibit n An, attached hereto and made a part hereof.
ANDREWS & JOHNSON
Sworn and subscribed to beti re me this
291h day of June 2006.
NOTARIAL SEAL
SHELLY SEXTON, Notary Public
Carlisle .8o,ro, Cumberland County
My Commission Expires April 26. 2007
,
. CompIeIe Ilem8 1, 2, and 3. Also complete
Item 4 K _ DeHvety I. deslrsd.
. Print yout name and eddress on lI)e I1lV8I'88
so that we can l'8f:um the card to you.
. All thl. card to the back of the mallpl808,
or on front K 8plIC8 pennlls.
1. Artlde to:
Douglas R Peffer
175 South Orange Street
Carlisle, PA 17013
2. Artlclo Numbsr
(7Iansfer from -18be/)
PS Fonn 3811, February 2004
,
D. Is __"""'_11
~ YES, enter delivery _ below:
3._ SJMco Typo
.;z!I..csrtiflod Moll [J Exprsss Moll
[J Registered ~m Reoelpt for Merchandise
CJ Insured Mall D C.O.D.
4. Restricted DoIIve1y? (ExtnJ Fee) Yes
700S 2570 0000 3796 3561
DomestJc Return Recelpt 102595-02-M-1540
Exhibit A
.,.Direct Query - Intranet - "Quick" Search
Page I of 1
...... UN/TeD 5BTfS
_ :;;..0- POSTrJL ,cRVICf
Track/Confirm - Intranet Item Inquiry - Domestic
Item: 7005 2570 0000 3796 3561
Date/Time Mailed: 06/26/2006 12:55
Destination
Origin
ZIP Code: 17013
ZIP Code: 17013-2935
City: CARLISLE
City: CARLISLE
State: PA
State: PA
Class: First Class
Anticipated Delivery Date: 06/27/2006
Weight: 0 Ib(s) 1 oz(s)
Delv Rqmt: Normal
Postage: $0.39
PO Box?: N
Special Services
CERTIFIED MAIL
RETURN RECEIPT
RESTRICTED DELIVERY
Associated Labels
7005 2570 0000 3796 3561
Amount
$2.40
$1.85
$3.70
Event
Date/Time
Location
Scanner
10
POS1680013
DELIVERED
06/27/2006 17:55
HH~!iilil!liifi_R~i.j
CARLISLE, PA 17013
(A PS Form 3849, Delivery Receipt, has not been appended to this record.
If the item was recently delivered, the Delivery Receipt may not yet have
been scanned.)
NOTICE LEFT
ACCEPT OR PICKUP
06/27/200612:31
06/26/2006 12:55
CARLISLE, PA 17013
CARLISLE, PA 17013
K146502
Enter Request Type and Item Number:
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I Submit I
Version 1.0
Inquire on multiple Items.
Go to the Product Tracking System Home Page.
http://pts.usps.gov/pts/labelInquiry .do
6/29/2006
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CRYSTAL L. PEFFER
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LA W
DOUGLAS R. PEFFER,
Defendant
: NO. 06-3598 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 23,
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. 9 4904, relating to unsworn
falsification to authorities.
Date:
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CRYSTAL L. PEFFER
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LA W
DOUGLAS R. PEFFER,
Defendant
: NO. 06-3598 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 23,
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.
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CRYSTAL L. PEFFER
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LA W
DOUGLAS R. PEFFER,
Defendant
: NO. 06-3598 CIVIL 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: II / <( / 010
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CRYSTAL L. PEFFER
v.
: CIVIL ACTION - LA W
Defendant
: NO. 06-3598 CIVIL TERM
: IN DIVORCE
DOUGLAS R. PEFFER,
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER fi 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. 94904, relating to unsworn
falsification to authorities.
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CRYSTAL L. PEFFER
v.
: CIVIL ACTION - LAW
Defendant
: NO. 06-3598 CIVIL TERM
: IN DIVORCE
DOUGLAS R. PEFFER,
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. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code.
2 Date and manner of service of the complaint: June 29. 2006 bv restricted. certified mail.
3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce
Code: by the Plaintiff November 12.2006; by Defendant November 8. 2006.
4. Related claims pending: None
5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary:
I lA/II
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Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary:
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ANDREWS & JOHNSON
Date:
/2/';
I
. 2006
Ronald E. Joh
78 West Porn Street
Carlisle, PAl 7013
(717) 243-0123
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OFCUMBERLANDCOUNTY
PENNA.
STATE OF
Crystal L. Peffer
06-3598
Plaintiff
No.
VERSUS
Douglas R. Peffer
Defendant
DECREE IN
DIVORCE
AND NOW,
()t..c.e.~'nt,
, 100<0, IT IS ORDERED AND
\1.
Crystal L. Peffer
, PLAINTIFF,
DECREED THAT
Douglas R.Peffer
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT
YET BEEN ENTERED;
None.
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By THE COURT:
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PROTHONOTARY
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