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HomeMy WebLinkAbout02-1883LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. : CIVIL ACTION - LAW : 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 action. You are wamed that, if you fail to do so, thc case may proceed without you and a decree of divorce or annulment 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 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 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 LORI A. DANIELS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA .. v. : NO. ._ EDWARD R. MYERS, III, : CIVIL ACTION - LAW Defendant : IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe romar action con prontitud, se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divoreio o anulamiento puede ser emitido en su eontrapor las Corte. una decision puede tambien set emitida en su contra por caulquier otra queja o compensation eclamados pot el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DOMESTIC RELATIONS CODE And now comes Plaintiff, Lori A. Daniels, by and through her attorneys, Law Offices of Craig A. Diehl, and files this Complaint in Divorce, respectfully stating in support thereof the following: 1. Plainfiffis Loft A. Daniels, an adult individual who currently resides at 32 Greenmont Drive, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Edward R. Myers, III, an adult individual who currently resides at 940 Sterling Court, Enola, Cumberland County, Pennsylvania 17025. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Peunsylvania for at least six (6) months immediately previous to the filing of this Divorce Complaint. Plaintiff and Defendant were married on May 1, 1999, in Cumberland County, Pennsylvania. 5. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since Septemberl 0, 2000. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Defendant is not a member of the aimed forces of the United States or any of its allies. 8. Plaintiff avers that the marriage is irretrievably broken. 9. Plaintiffhas been advised of the availability of counseling and that Plaintiffmay have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce. Dated: LAW OFFICES OF CRAIG A. DIEHL ~ i~qu'irS~ ill, (717) 763-7613 Attorney for Plaintiff LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. .. : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, LORI A. DANIELS, verify that the statements in the foregoing DIVORCE COMPLAINT are true and correct to the best of my knowledge, infom~ation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: L~RI A. DANIELS LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1883-Civii Term ; : CIVIL ACTION - LAW : IN DIVORCE _PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Divorce Complaint in the above-captioned matter. Dated: May 16, 2002 Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL ~4iiea~rindle ROES'' Camp Hill, PA 17011 (717) 763-7613 LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 02-1883-Civil Term : CIVIL ACTION - LAW : 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 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 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : NO. 02-1883-Civil Term ._ .. : CIVIL ACTION - LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DER~CHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si deseh defenderse de las quejas expuestas en las paginas seguientes, debe tomar accion con prontitud~ se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio o anulam~ento puede set emitido en su contra pot las Corte. una decision puede tambien set emitida en su contra pot caulquier otra queja o compensacion eelamados pot el demandante. Usted puede perder din~ro, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento i~reparable del matrimonio, usted puede solicitar eonsejo matrimonial. Una lista de consejeros matlimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse~ One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, P~OPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES l~E QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DE~CHO A ~CL~ CUALQUIE~ DE ELLOS. 1 USTED DEBE LEV~ ESTE PAPEL A ~ ~OG~O D~ ~MED~TO. SO NO TIE~ O NO PUEDE PAGAR ~ ABOGADO, VAYA O L~ A LA OFIC~A INDICIA ABA JO P~ A~GU~ DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOC 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 ~TION LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE AMENDED COMPLAINT UNDER SECTION 3~01(C) OR 3301(D) OF TI-IE DOMESTIC RELATIONSCODE And now comes Plaintiff, Lori A. Daniels, by and through her lattomeys, Law Offices of Craig A. Diehl, and files this Amended Complaint in Divorce, respectfull~ stating in support thereof the following: 1. Plaintiff is Lori A. Daniels, an adult individual who currently resides at 32 Greenmont Drive, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Edward R. Myers, III, an adult individual who currently resides at 940 Sterling Court, Enola, Cumberland County, Pennsylvania 17025. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Divorce Complaint. 4. Plaintiff and Defendant were married on May 1, 1994, in Cumberland County, Pennsylvania. 5. Domestic Relations Code since Septemberl0, 2000. 6. A previous action for divorce was filed and discontir Pennsylvania, to Civil docket number 6296 of 2001. The proceeding v The parties have been separate and apart within the meaning of the Pennsylvania ued in Cameron County, 'as discontinued on March 13, 2002, upon Praecipe to Discontinue as filed by counsel for Plaintiff in that action. A tree and correct copy of same is attached hereto as Exhibit "A" and is incorporated herein as if fully set forth. 7. Defendant is not a member of the mined forces of the United States or any of its allies. 8. Plaintiff avers that the marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling ~md that Plaintiffmay have the right to request that the court require the parties to participate in coutlseling. Plaintiffdoes not desire counseling. WHEREFORE, Plaintiff respectfully requests that this Court en{er a Decree of Divorce. Dated: LAW OFFICES OF CRAIG A. DIEHL A7 eR)t~elter,'E~squi~ ey ID No. 72963 rindle Road Camp Hill, PA 17011 (717) 763-7613 Attomey for Plaintiff EDWARD R. MYERS, III, Plaintiff IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY CIVIL ACTION - DIVORCE LORI A. DANIELS, : Defendant : NO. 6296 PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: SIR: Please mark the above-captioned action DISCONTINUED. DATE: 03/06/02 ~UIRE Attorney for Plaintiff 19 Darling Street Wilkes-Barre PA 18702-2510 570/825-5252 ~ NOW, this ~ day of ,~;£~¢3 , 200~, th. abov.- captioned action is hereby marked discontinued. PROTHONOTARY BY: Deputy 3/13/02 Copy to Linda A. Clotfelter, Esquire EXHIBIT "A" LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 02-1883-Civil Term : : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, LORI A. DANIELS, verify that the statements in the foregoing DIVORCE COMPLAINT are true and correct to the best of my knowledge, information and beli6f. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: LORI A. DANIELS LORI A. DANIELS, Plaintiff Ye EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1883-Civil Term : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, EDWARD R. MYERS, III, Defendant in the above-captioned matter, hereby accept service of the Complaint in Divorce filed by Plaintiff. Service is accepted on the ~ 57 day of -~ ~'-> ~ ,2002. EDWARD R. MYE RS, 1,0Y~efendant LORI A. DANIELS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : v. : NO. 02-1883-Civil TerTM EDWARD R. MYERS, III, : CIVIL ACTION - LA~ ¥ Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on this date, a tree and correct copy of the foregoing document was served upon the opposing parties by way of United State..: First Class Mail, postage prepaid, addressed as follows: Edward R. Myers, III 340-128 East Penn Drive Enola, PA 17025 Date: LAW OFFICES OF CRAI~ A. DIEHL By: ,~S'tepha~e A. M~re;Legal 3464 Trindle Road Camp Hill, PA 170 (717) 763-7613 Secretary LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 02-1883-Civil Term ; : CIVIL ACTION - ]LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 330 l(c) or 3301(d) of the Divorce Code was filed on April 17, 2002, and an Amended Complaint in Divorce Under Section 3301(c) or 3301(d) of the Divorce Code was filed on June 17, 2002. 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 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 and expenses if I do not claim them before a divorce is gra~ated. I verify that the statements made in this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. LORI A. DANIELS, Plaintiff LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendam : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1883-Civil Term : CIVIL ACTION - ]LAW : 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 ifI 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 tree 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: ? ~ ! LORI A. DANIELS, Plaintiff LOX A. DANIELS, Plaintiff Ye EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Linda A. Clotfelter, Esquire, counsel for Plaintiff, Loft A. Daniels, do hereby affirm that on November 12, 2002, I served the following documents upon Defendant via United States First Class Mail, postage prepaid and by Certified Mail, Return Receipt Requested, Restricted Delivery: Plaintiff's Affidavit required by §3301(d) of the Divorce Code; Notice of Intention to Request Entry of §3301(d) Divorce Decree; and Counter-Affidavit under §3301(d) of the Divorce Code. (True and correct copies of the documents as sent are attached hereto as Exhibit "A" and are incorporated herein). The above-referenced documents were sent to Defendant, as per his instructions at the following address: Edward R. Myers, III 340-128 East Penn Drive Enola, PA 17025 The United States First Class Mail, postage prepaid was not returned to the undersigned and the Certified Mail, Return Receipt Requested, Restricted Delivery was received by Defendant's Agent, Bryan J. Kolb on November 14, 2002, as per the receipt, below: · Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can tatum the card to you. Attach this card to the back of the mailplace, or on the front if space permits. 1~4~nt D. Isde~a [] Yes If YES, enter dellvmy address I:mlow: [] No ~ i ~Ce~fled Mall [] Express M~II [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. /~~) ~Yes 2. A~i Numbe~ (Copy from service/abe/) PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0g52 The undersigned understands that the statements herein are made subject to the penalties of 18 P.S. § 4904 relating to unswom falsification to authorities. LAW OFFICES OF CRAIG A. DIEItL Dated: lter, E~qui~e · 72963 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 LORI A. DANIELS, Plaintiff EDWARD R. MYERS, lII, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 3rd day of December, 2002, the undersigned hereby certifies that a true and correct copy of the foregoing AFFIDAVIT OF SERVICE was served upon the opposing party by way of United States first class mail, postage prepaid, addressed as follows: Edward Myers III 340-128 East Penn Drive Enola, PA 17025 LAW OFFICES OF CRAIG A. DIEHL ./Stel~han~ A. P~re ,z~Le~ Secret~ 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 LORI A. DANIELS, Plaintiff EDWARD IL MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on September 10, 2000, and they have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 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 unswom falsification to authorities. Date: LORI A. DANIELS, Plaintiff NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1883-Civil Term CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (C) OF THF~ 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 ifI 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. LORI A. DANIELS, Plaintiff LORI A. DANIELS, Plaintiff Vw EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on June 17, 2002, a tree and correct copy of the Amended Complaint in the above-captioned matter was served upon the opposing party by way of United States First Class Mail, postage prepaid, addressed as follows: Edward R. Myers, III 340-128 East Penn Drive Enola, PA 17025 LAW OFFICES OF CRAIG A. DIEHL Date: 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 LORI A. DANIELS, Plaintiff Ve EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Kindly transmit the record, together with the following information, to the Court for entry of a divorce The ground for divorce is irretrievable breakdown under Section 3301 (d) of the Divorce Code. Date and manner of Service of the Complaint: The Complaint was filed on April 17, 2002. It was reinstated upon praecipe on May 20, 2002 and was served on June 1, 2002, by Acceptance of Service of Defendant, Pro Se, as evidenced by the Acceptance of Service filed on June 17, 2002. An Amended Complaint was filed on June 17, 2002. The Amended Complaint was served on Defendant, Pro Se, via United States First Class Mail, postage prepaid on June 17, 2002, as per the Certificate of Service filed December 3, 2002. Date of execution of the affidavit required by §3301(d) of the Divorce Code: November 4, 2002, by Plaintiff. ' ' · Plaintiff's Affidavit was served upon Defendant/Respondent on November 12, 2002, by both United States First Class Mail postage prepaid and Certified Mail, Restricted Delivery, Return Receipt Requested, as per the Affidavit of Service filed December 3, 2002. The affidavit required by §3301(d) was filed December 3, 2002. Related claims pending: None. Date and manner of service of notice of intention to file praecipe with counter-affidavit as required, a copy of which is attached: Both United States First Class Mail postage prepaid and Certified Mail, Restricted Delivery, Return Receipt Requested on November 12, 2002, as per the Affidavit of Service filed December 3, 2002. Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date:, ~A' o~Aey, iC. ~t ~lot ~r~ 2E;6q;ir e"~or Pla~t) 3464 Trindle Road Camp Hill, PA 17011 (717) 763-7613 LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF §3301(d) DIVORCE DECREE TO: EDWARD R. MYERS, III, DEFENDANT You have been sued in an action for divorce. You have failed to answer the Complaint or file a counter-affidavit to the §3301(d) affidavit. Therefore, on or after December 2, 2002, the other party can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above-date, the Court can enter a final Decree in Divorce. A counter-affidavit which, you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the Court a Written claim for economic relief, you must do so by the above-date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LORI A. DANIELS, Plaintiff EDWARD R. MYERS, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1883-Civil Term CIVIL ACTION - LAW IN DIVORCE ' COUNT.__ER-AFFIDAVIT UNDER ~OF THE DIVORCE CODE Check either (a) or (b): I do not oppose the entry of a divorce decree. I oppose the entry ora divorce decree because (Check (i), (ii) or both): ~ (i) The parties to this action have not lived separate and apart for a period of at least two (2) years. (ii) The marriage is not irretrievably broken. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division &property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the Divorce Decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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: EDWARD R. MYERS, III, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS' COUNTER-AFFIDAVIT IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PENNA. LORI A. DANIELS~ Plaintiff EDWARD R. VERSUS MYERS, III, Defendant PLEAS N o. 02-1883 DECREE IN DIVORCE AND NOW, ,'~,~~'", IT IS ORDERED AND DECREED THAT LORI A. DANIELS , PLAINTIFF, AND EDWARD R. MYERS, III , 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. BY TH ATTES : rOTHONOTAri'