Loading...
HomeMy WebLinkAbout02-2090IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Jill A. Danu, : Civil Action -Law Plaintiff V. No. 0.2 -.2096 Florin I. Danu, Defendant In Divorce a v.m. 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 the First Floor, Franklin County Court House, 157 Lincoln Way East, Chambersburg, 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. Pennsylvania Bar Association Lawyer Referral Services Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Jill A. Danu, V. Florin I. Danu, To the Prothonotary: Plaintiff Civil Action - Law No. Da - J09o C;u? I TT, " Defendant In Divorce a v.m. PRAECIPE Please reinstate the attached divorce complaint. Barbara B. Tow end O ? N C zLI M m Z_ N ?^ Cr `_? C7 ?rn m IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Jill A. Danu, Plaintiff : Civil Action - Law V. No. Oa - a0Ro Cau?? "flLy?? Florin I. Danu, l Defendant In Divorce a v.m. COMPLAINT UNDER SECTION 3301(c) or (a) OF THE DIVORCE CODE NOW comes the Plaintiff and for cause of action against the Defendant says: Plaintiff is Jill A. Danu, who resides in Cumberland County, Pennsylvania with a mailing address of 539 Bedford Court, Mechanicsburg, Pennsylvania 17050 since January 2002. 2. Defendant is Florin 1. Danu, whose last known residence and present whereabouts are in Borough of Shippensburg, Cumberland County, Pennsylvania with a mailing address of 206 East King Street, Shippensburg, Pennsylvania 17257 since June 1999. 3. Plaintiff and defendant have 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 August I, 1998, at Hagerstown, Washington County, Maryland. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or in any other jurisdiction. 6. The marriage is irretrievably broken. 7. The plaintiff has been advised of the availability of counseling and that the 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. XBarbara B. Town nd Attorney for PI mtiff I hereby verify that the facts set forth in the foregoing instrument are true and correct to the best of my knowledge, information and belief, and that I make this verification subject to the penalties of 18 PLC.S. 4904 relating to unworn falsification to Authority, as authorized by the Judicial Code and Pennsylvania Rules of Civil Procedure. Date: I - - ??` U L`' CTS ??!?; _ C\J ???M1 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Jill A. Danu, : Civil Action -Law Plaintiff V. : No. 02-2090 Florin 1. Danu, Defendant - trl Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA COUNTY OF FRANKLIN : SS Barbara B. Townsend, Esquire, being duly sworn according to law, deposes and says that she sent a true and correct copy of the Complaint in Divorce to Florin I. Danu, at his last known address of 206 East King Street, Shippensburg, Pennsylvania 17257, by certified mail, restricted delivery, addressee only, No. 7099 3400 0017 6228 2062, receipt attached hereto, postage prepaid on June 26, 2002, from the United States Post Office at Chambersburg, Pennsylvania. Barbara B. T nsend i Sworn nd subscribed to before me this day of L, lyzi, 20007 ? i/J,Q/ &' Notary Public Notarial Seal Teressa Bard, Notary Public Chambersburg Boro, Franklin County My Commission Expires Mar. 3, 2003 C [V ?7 tom' _ A 1 d #a 91 • • ???? si ¦ 0 ftl -- -- ------- a ?I- - " O ru N I i ti, 90 postmarks HeV ^ R u?„.41 =e r' (Ifndoi rF f p.i it dl ?.? O =esti ani, :hrt"y ee 33 0 r?ndo 'ie_ii d G7 'Tot, ??. ae 3 = as I $ 0 7 Aeo P I, ima ('lease-Print Ieady7 (to be completed by mailer -- -- ------ cka. A ----------------- -------- --------- M r ?, ">tr h._; nr O Sox No. _ ?_ _ ____.__-_._____- o is iyy 3 E I, .< ? S 7 r- \ ) Certified Mail Provides: ¦ A mailing receipt ¦ A unique identifier for your mailpiece ¦ A signature upon delivery ¦ A record of delivery kept by the Postal Service for two years Important Reminders: ¦ Certified Mail may ONLY be combined with First-Class Mail or Priority Mail. ¦ Certified Mail is not available for any class of international mail. ¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, please consider Insured or Registered Mail. ¦ For an additional fee, a Return Receipt may be requestCd to provide proof of delivery. To obtain Return Receipt service, please complete and attach a Return Receipt (PS Form 3811) to the article and add applicable postage to cover the fee. Endorse mailpiece "Return Receipt Requested". To receive a fee waiver for a duplicpliic required. ate return receipt, a USPS postmark on your Certified Mail receipt is ¦ For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mailpiece with the endorsement "Restricted Delivery". ¦ If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when making an inquiry. PS Form 3600, February 2000 (Reverse) 702595-99-M-2087 ¦ 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 return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: FI(jri n Z lJanl? Dl? Easy- kiln S?. Shy (??'Jer?s?Ur? eA as-l A. Received by (Please Print C ally) B. D e of elivery C. Si re 3/ ? Agent X ? Addressee D. Is delivery a dress 'tent from item 1? ? Yes If YES, enter delivery address below: ? No VW I3. Ser?v' Type G Certified Mail ? Express Mail ? Registered ? Return Receipt 'or Merchandise rl Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Copy f m service label) :3 a99 ?tno ??aa ao? PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 UNITED STATES POSTAL SERVICE First-Class Mail Postage & Fees Paid LISPS Permit No. G-10 • Sender: Please print your name, address, and ZIP+4 in this box • `Y AtAP? RA13. To," ,nn 32 WFNIET LAS- j CI iAkBERSBUR-' PA - 01 t& I I I I I I I I I t I I t I I I 113% 3 111 11 111 3 11 1 1 1 I I! I I I% 19 11 11 11 11 $ 19111113! IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Jill A. Danu, : Civil Action -Law Plaintiff V. No. 02-2090 Florin I. Danu, Defendant In Divorce a v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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 Waiver are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 6 a Jill anu, Plaintiff c ° CD R 65 r •' ) 1 jy? ??I ????• G? __1 IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Jill A. Danu, : Civil Action - Law Plaintiff v : No. 02-2090 Florin 1. Danu, Defendant In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed on April 29, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. 1 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 Pa. C.S. 4904 relating to unsworn falsification to authorities. / Date: In Defendant c7 c? c-> c r? ?? o '? rr n ? ; .,= --a = -' .: .-, r s_ .,., ;> _.. ?_; ,.. -:? ? _- -7 C PLEAS OF THE IN THE COURT OF COM OF PENNSYLVANIA 9TH JUDICIAL DISTRICT Cumberland County Jill A. Danu, : Civil Action -Law Plaintiff v : No. 02-2090 Florin I. Danu, Defendant In Divorce a v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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 Waiver are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: / ?9 ®02 Florin I. Danu, De c r.; c? n; r ? j IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA Cumberland County Jill A. Danu, : Civil Action -Law Plaintiff V. : No. 02-2090 Florin I. Danu, Defendant In Divorce a v.m. NOTICE OF INTENTION TO RESUME MAIDEN NAME NOTICE is hereby given of the intention of Jill A. Danu, Plaintiff, in the above-captioned action, to resume her maiden name of Jill A. Wintermoyer, she having been granted a decree in divorce in this action on November 5, 2002 4;A a. Jill . Danu 41,0 Q. DY,. tiei !L Jill A. Wintermoyer Plaintiff STATE OF PENNSYLVANIA COUNTY OF FRANKLIN : SS On this the day of 0 6V M V \e , 2002, before me, a Notary Public, the undersigned officer, personally appeared Jill A. Danu, (known to me or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have re nto set my hand ano official seal. u A. a,_, otary Public ho O,-d S0,11I Rill }t; ?a er he i'ti 1 Paot,ry pu r Cf3Clo,l r?14Fi'li ttaril? 2:y ' .:;3 S4 1 I'VV^ W t I i ?' L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. N O. 02-2090 ILL A. DANU VERSUS FLORIN I. DANU DECREE IN DIVORCE r 2,fo 3- ? Boaz AND NOW, jf? 57 IT IS ORDERED AND DECREED THAT JILL A. DANU , PLAINTIFF, AND FLORIN I. DANU 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 0 • A Es J. PROTHONOTARY ti p, 7if/ ?/