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HomeMy WebLinkAbout06-4333 0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff : Docket No. nt. _ 42 X361 U VS. TROY A. VANDERAU Defendant : Civil Action -Law : 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 Cumberland County Prothonotary at One Courthouse Square, Carlisle, Pennsylvania 17013. Phone: 717-240-6100. 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. You must attend the scheduled conference or hearing. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISE, PENNSYLVANIA 17013 (717) 249-3166 (800) 990-9180 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU / Plaintiff :Docket No. i to iL n vs. : Civil Action -Law : Divorce TROY A. VANDERAU Defendant COMPLAINT UNDER SECTION 3301(c) and 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Katie E. VanDerau, who currently resides at 1394 Letchworth Road, Camp Hill, Pennsylvania 17011. 2. Defendant is Troy A. VanDerau, who currently resides at 146 Strodes Run Road, McVey Town, Pennsylvania, 17059 3. Plaintiff has been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 1st 2001, at Huntingdon, Pennsylvania. 5. The Plaintiff and Defendant separated on February 1, 2004. 6. The Plaintiff and the Defendant have not previously filed for Divorce in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. 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. 9. Wherefore, Plaintiff requests the court to enter a decree of divorce. - 4 I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 490 relating to unsworn falsification to authorities. t? Ka ie E. VanDerau Date --, Attorney for Plaintiff. Dere Cordier Esq. #83284 319 So Fro t Street Harrisburg, PA 17104-1621 (717) 919-4002 cl? O c w U IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff vs. TROY A. VANDERAU Defendant :Docket No. 06- 43$x- cu : Civil Action -Law : Divorce AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on February 1" 2004, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 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 unworn falsification to authorities. - _: ;? y. Y i a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff VS. TROY A. VANDERAU Defendant : Docket No. 06-q33-3-0/ Civil Action - Law Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301 (d) OF THE DIVORCE CODE 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 unworn falsification to authorities. r? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff :Docket No. 06 J'i 333 - C V VS. : Civil Action -Law : Divorce TROY A. VANDERAU Defendant 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. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on February 1" 2001, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. Q m N q DT? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff • ?j333 Docket No. 06-49333-CV vs. TROY A. VANDERAU Defendant : Civil Action -Law : Divorce COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE Check either (a) or (b): (a) _ I do not oppose the entry of a divorce decree. (b)_ I oppose the entry of a 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 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 of property, lawyer's fees or expenses if I 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. NOTICE: IF YOU DO NOT OPPOSE THE ENTRY OF THE DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. 1 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 1& Pa.C.S. ' 4904 relating to unworn falsification to authorities. Troy A. VanDerau Date a C ni"'-. Cy -cy? ." '. N 7;7 tiJ r. r^ -p :z C7 C7 2n CIO 0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff : Docket No. 06-4333-CV VS. TROY A. VANDERAU Defendant Civil Action -Law Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on July 31St, 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 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. ? K :? Date: "?s - /6- 0 7 Qt_ - 7f Rkj ANDERAU, Defendant V-4 of IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff : Docket No. 06-4333-CV vs. TROY A. VANDERAU Defendant : Civil Action -law : Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND 43301(d) 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 unworn falsification to authorities. Date: "W-16-09 ERAU, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff : Docket No. 06-4333-CV VS. TROY A. VANDERAU Defendant : Civil Action -Law : Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on July 31St, 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 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 unworn falsification to authorities. Date: 9-//-07 KA EE. VA JRA aintiff P?v 4=0 tss IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff : Docket No. 06-4333-CV VS. TROY A. VANDERAU Defendant : Civil Action -Law : Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (c) AND §3301 (d) 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 unworn falsification to authorities. Date: Q?--- TIE E. VANDERAU, Plaintiff *.a ??+} tea _ 4r- KATIE E. VANDERAU, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-04333-CV TROY A. VANDERAU, : CIVIL ACTION - LAW Defendant. : IN DIVORCE ACCEPTANCE OF SERVICE I, Lesley J. Beam, Esquire, counsel of record for Defendant in the above- captioned action, hereby accept service of the Divorce Complaint under §§ 3301 (c) and (d) of the Divorce Code, filed in the above-captioned matter, served by first class mail on the date indicated below. I certify that I am authorized to accept service for the Defendant. Date: D ?o r Lesley J?yearh, Esquire Kope & Associates, LLC ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Counsel for Defendant ? i as g Q"°e IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA KATIE E. VANDERAU Plaintiff VS. TROY A. VANDERAU Defendant : Docket No. 06-04333-CV Civil Action -Law 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: August 29, 2007, by acceptance of service. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff, September 11, 2007; by defendant, August 16, 2007; Date of filing of plaintiff's affidavit of consent, September 14, 2007. Date of filing of defendant's affidavit of consent, September 7, 2007. (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: There are no outstanding economic claims. All economic claims have been resolved between the parties. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: September 14, 2007. Date defendant's Waiver of Notice as fi ed v ' otOnotary: September 7, 2007. Respectfully Submitted by: Derek Wier, Esquire #83284 319 South Front Street Harrisburg, PA 17104-1621 (717) 919-4002 t `rv t!g IN THE COURT OF COMMON PL AS OF CUMBERLAND COUNTY STATE OF PENNA. KATIE E. VANDERAU, PLAINTIFF No. 06-04333-CV VERSUS TROY A. VANDERAU, DEFENDANT, DECREE IN DIVORCE AND NOW, () 4`0\PiC IT IS ORDERED AND KATIE E. VANDERAU DECREED THAT AND TROY A. VANDERAU ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS W ICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; THERE ARE NO OUTSTANDING CLAIMS AGAINST THE PARTIES. BY THE COURT: N?? A"..' ??A v - ATTEST: 714\ 1 J. PROTHONOTARY f jor" ov4v- 4.o, ®/ 60^ r- 8f 0