Loading...
HomeMy WebLinkAbout02-2488DOUGLAS E. SWARTZ, KATHY J. SWARTZ, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. CIVIL TERM : IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the clam 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 divome 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 Cumberland 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 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 Carlisle, PA 17013 Phone: (717) 249-3166 DOUGLAS E. SWARTZ, Plaintiff V. KATHY J. SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Douglas E. Swartz, who currently resides at 31 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania, since approximately 1996. 2. Defendant is Kathy J. Swartz, who currently resides at 431 North Hanover Street Apt #4, Carlisle, Cumberland County, Pennsylvania, since 1999. 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. Plalntiffand Defendant were married on September 26, 1991, in Carlisle, Cumberland County, Pennsylvania. 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. Plaintiffhas been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 8. Plaintiffrequests the Court to enter a Decree in 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. § 4904, relating to unswom falsification to authorities. Date: By:. Karl E. Rominger, Esquire Attorney for Plaintiff 155 Sot/th Hanover Street Carlisle, PA 17013 (717) 241-6070 DOUGLAS E. SWARTZ, Plaintiff V. KATHY J. SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 2488 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Kathy J. Swartz, in the above-captioned action and I certify that I am authorized to do so. DATE: ~//~ q//d2~ By: DOUGLAS E. SWARTZ, Plaintiff V. KATHY J. SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 02 - 2488 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaim in Divorce under Section 3301(c) of the Divorce Code was filed on May 21, 2002. 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 tree 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: Douglff_s E. Swartz DOUGLAS E. SWARTZ, Plaintiff V. KATHY J. SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 02 - 2488 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 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. Oate: Dot~glas E?Swartz, Plaintiff DOUGLAS E. SWARTZ, Plaintiff V. KATHY J. SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 2488 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 21, 2002. 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 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: DOUGLAS E. SWARTZ, Plaintiff V. KATHY J. SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 02 - 2488 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(e) 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. DOUGLAS E. SWARTZ, Plaintiff V. KATHY J. SWARTZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 02 - 2488 CIVIL TERM : IN DIVORCE 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service. Dated May 24, 2002. 3. Date of execution of the affidavit of consent required by § 3301 (c) of the Divorce Code: by the Plaintiff September 15, 2002; by the Defendant, September 9, 2002. 4.Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 20, 2002. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 20, 2002. Date: September 20, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 iNThE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~ PENNA. DOUGLAS E. SWARTZ Plaintiff VERSUS KATHY J. SWARTZ Defendant NO.02-2488 CIVIL TERM DECREE iN DIVORCE AND NOW,~ 3 DECREED THAT Douglas E. Swartz , it IS ORDERED AND , PLAINTIFF, AND Kathy J. Swartz , 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 B Y~F'td e ~: /A~ V L~J~ '~% j. ~OT~--O~OTA~