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HomeMy WebLinkAbout06-3598 , " 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 By: ~~p ~~ ~~ -- ~ ~ ~ C) \,") C ."n ~ .-4 (,: ~ ;+1 r'-' La -'.' r;;> _,.' r"-;:l .-<. 0', . A 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 $3.70 Event Date/Time Location Scanner 10 POS1680013 DELIVERED 06/27/2006 17:55 HH~!iilil!liifi_R~i.j CARLISLE, PA 17013 (A PS Form 3849, Delivery Receipt, has not been appended to this record. If the item was recently delivered, the Delivery Receipt may not yet have been scanned.) NOTICE LEFT ACCEPT OR PICKUP 06/27/200612:31 06/26/2006 12:55 CARLISLE, PA 17013 CARLISLE, PA 17013 K146502 Enter Request Type and Item Number: Quick Search :clio) Extensive Search ~~~$~ ":,, ",,:, "':;,,,/, '''''''''1'" /, ,;,',,', ",,' );" ,,',,:',;" 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 ,. ',j -oj 1'.:' ["";' r.,,~ r ~ _.U .'<, 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: I' It;, /0 fp CJ ~ 'fj. f6 c:-> \ tf\ -0 '::> - .. o -r\ :t-o P"\r==:. -dm ~.-".' t:) _;J, ~i... ,.}\y .-ot'- 1 \ _,_ -'f'"<. ;~B ,:;:. rti .\~ ~ ~ J;:" - 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. Date: \ \ \ \ ~\ Olo \ \ () ~; ~~~- .,..." = = cr. o M (""') I U1 o -n ~ I'n ?-J ]38 ,-" I .~Cl @~ :-'1 .? :-.0 -< ~ .;::- tv 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 I I /"-..,) c:.o c:.o Ch o P1 C") I c.n -0 :x o -n :r! m.::D r- ....,...,m :0C;~ .;~35 5~C) :,5f1i ~:-i :b -< - h ,J:- N 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. Date: \ \ \ \1- \ 0 \..c \ \ (') ~ ~ c:;;) = c:;:r. o PI CJ I U1 -0 ::r: o ." --f ::r:.." m- r- -0 fT'l <-?'T c)( ) .:;j'T' ~~ )> ~:o -< .~ N 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 / / Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: /l/J-;/~ , / ANDREWS & JOHNSON Date: /2/'; I . 2006 Ronald E. Joh 78 West Porn Street Carlisle, PAl 7013 (717) 243-0123 ,...." <C;:l c:;:;) (;;:f"\ '=' rrt n r c.n -0 :2: o " ~ n1~ :-om "'J r-l ':.::) 'y" :::f ~) "1: -r, ":.J ,"j ~? (") ~-"5 m ~ > ::0 -< .- w if'f. ~ lti~ lti ~ ltiltilti~ ~~ lti lti lti ltiltilti~lti~ltiltiltiotiltilti ltilti lti ~lti~ ltilti~~ltioti~lti~;fif. if ~ :f. IN THE COURT OF COMMON PLEAS lti :f. :f. :f. :f. :f. lti :f. :f. :f. :f. ~ ~ lti ~ lti :f. :f. :f. :f. :f. if 'to lti 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. ~ ~ ~ ~ ~ ~ ~ ~ ~ 'to 'to 'to ~ :f. :f. :f. :f. :f. J. 'to :f. :f. :f. :f. By THE COURT: ~ ~ G~ / PROTHONOTARY y y "'t :f.~:f.ltiif'f. 'f. ~'f.'f. 'f.'f.~~~~'f. 'f.if'f. 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