HomeMy WebLinkAbout02-2552 IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIC J. SINGER, : CIVIL ACTION - LAW
Plaintiff, :
;
v. : NO. 0~- ~,S'~'~ CIVIL
:
LISA M. SINGER, :
Defendant. : 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 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
judgement 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 grounds 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013.
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, Pennsylvania 17013
717-249-3166
WEIGLE & ASSOCIATES. f~C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIC J. SINGER, :
Plaintiff, :
;
V. ;
;
LISA M. SINGER, :
Defendant. :
CIVIL ACTION - LAW
NO. oa..~ 53',L CIVIL
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
IRRETRIEVABLE BREAKDOWN
AND NOW, comes the above named Plaintiff, Eric J. Singer, by and through his attorneys,
Wcigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in Divorce
from the above-named Defendant, upon the grounds hereinafter more fully set forth:
Plaintiff, Eric J. Singer, is an adult individual presently residing at 105 East Main Street,
Plainfield, Cumberland County, Pennsylvania 17081, since January 6, 1999.
Defendant, Lisa M. Singer, is an adult individual presently residing at 17 South High Street,
Newville, Cumberland County, Pennsylvania, since January 2002.
The Plaintiff and Defendant are nationals and citizens of the United States of America, and both
have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of the Complaint in Divorce.
4. The Plaintiff and Defendant were married on November 11, 1995, in Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
Plaintiff has been advised that counseling is available and the Plaintiff may have the right to
request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
8. The parties have lived separate and apart since January 2002.
9. The Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the
bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled.
WEIGLE & ASSOCIATES, P.C.
By:
Richard L. Webber, Jr., Esquire (~_
Attorney for Plaintiff
Attorney ID #49634
126 East King Street
Shippensburg, PA 17257
Telephone 717-532-7388
WEIGLE & ASSOCIATES, AC. ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
VERIFICATION
I verify that the statements made in the foregoing Complaint in Divorce 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.
Dated:
Eric J. Singer,~Plaintiff
WEIGLE & ASSOCIATES, RE. -- ATTORNEYS AT LAW -- 126 EAST KING ST~REET -- SHIPPENSBURG, PA 17257-1397
ERIC J. SINGER,
LISA M. SINGER,
Plaintiff,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY~ PENNSYLVANIA
: CIVIL ACTION - LAW
_.
: NO. 02-2552 CIVIL
..
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA :
:
COUNTY OF CUMBERLAND :
SS
Patricia A. Frey, being duly sworn according to law, deposes and says that on May 31, 2002, a
true and attested copy of Divorce Complaint and Notice to Defend were served upon the Defendant,
Lisa M. Singer. Manner of service: by mailing the same postage paid, certified mail, addressee only,
and return receipt requested mail, at Shippensburg, Pennsylvania, addressed as follows:
Lisa M. Singer
17 South High Street
Newville, PA 17241
The return receipt signed by the Defendant is evidence of delivery to him and is attached hereto
as "Exhibit A."
PATRICIA A. FREY
Sworn to and subscribed before
me this 3rd day of June, 2002.
Notary Public
I Notarial Seal
I Patfl~ta L._'rome, Notary Publio
I Shil~l~u~g ~oro, Cumberland County
I ~M~.'. Commission Exoires June 7, 2004
ERIC J. SINGER,
LISA M. SINGER,
Plaintiff,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY~ PENNSYLVANIA
CIVIL ACTION - LAW
;
: NO. 02-2552
:
..
: IN DIVORCE
CIVIL
PROOF OF SERVICE
(Enclo~sement Required)
(Endorsement Required)
Total postag® & Pee8
$0.57
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05 Po~ma~
$1.50 Hem
$7.37 05/30/2002
· Comptete Items 1, 2, and 3. A~o complete
item 4 If Re~'icted Deilvmy is deeired.
· Print your name and addrea~ on the mveme
.o that we can ~torn-the card to you.
· Attach this olw,d~lNllB back of the mallplece,
or on the ~,c.~ if q3ace
B. Reo~ved by ( Printed lVame) C. Date of Detive~
D. I~dellveryaddmeed4famntfmmlteml? r'lyes
ff YES; enter delivery addm~ below: [] No
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[] Insured il [] C.O.D.
4. Restr~ted D~k~3~? {Ex~ra Fee) ~'Yes
7001 2510 0001 4143 9336
Pi~ 381t; AUgust 2001 ' DameSti~Retum Receipt
~HTBIT 'A'
WEIGLE & ASSOCIATES, RC, -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
ERIC J. SINGER,
LISA M. SINGER,
Plaintiff,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 02-2552 CIVIL
: IN DIVORCE
statements herein are made
falsification to authorfies.
AFFIDAVIT OF CONSENT
A complaint in divorce under § 3301(c) of the Divorce Code was filed on May 24, 2002.
The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing and service of the Complaint.
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
subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom
Dated:
Eric J. Singe~, Plaintiff
WEIGLE & ASSOCIATES, EC. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
ERIC J. SINGER,
LISA M. SINGER,
Plaintiff,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 02-2552
IN DIVORCE
CIVIL
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.
I understand that I may lose fights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
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 scm to me immediately at, er 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 unswom
falsification to authorities.
Dated:
Ed'~J. ' '~ · · - a
S~nger, Plmnt~ff
WEIGLE & ASSOCIATES, F~C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIC J. SINGER, : CIVIL ACTION - LAW
Plaintiff, :
v. : NO. 02-2552 CIVIL
LISA M. SINGER, :
Defendant· : IN DIVORCE
AFFIDAVIT OF CONSENT
A complaint in divorce under § 3301(c) of the Divorce Code was filed on May 24, 2002.
The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing and service of the Complaint.
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.
Lisa M. Singer, Defendant
WEIGLE ~ ASSOCIATES, P.C. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG. PA 17257-1397
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ERIC J. SINGER, : CIVIL ACTION - LAW
Plaintiff, :
V.
: NO. 02-2552 CIVIL
LISA M SINGER, '
Defendant· : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO RE UEST ENTRY OF A
DIVORCE DECREE UNDER 3301 e 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 fights 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 unswom
falsification to authorities.
Dated:
isa M. Singer, Defendant '
WEIGLE & ASSOCIATES, ~C. -- ATTORNEYS AT LAW -- 126 EAST KING STI:~EET -- SHIPPENSBURG, PA 17257~1397
F 52002~dchW~Singer,.Eric J~.ivorce 9416-AL3301 (c)divorce consent forms .doc
ERIC J. SINGER,
LISA M. SINGER,.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff, :
Defendant· :
CIVIL ACTION - LAW
NO. 02-2552 CIVIL
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:
o
Grounds for divorce: irretrievable breakdown under § 3301 (c) of the Divorce Code.
Date and manner of service of the complaint: May 31, 2002, by mailing postage paid, certified
mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania.
Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by
Plaintiff, September 5, 2002; by Defendant, September 7, 2002.
Related claims pending: None
Date Plaintiff's Waiver in § 3301(c) Divorce was filed with the prothonotary:
September 11, 2002
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary:
September 23, 2002
WEIGLE & ASSOCIATES, P.C.
Richard L. Webber, Jr., Esquire
Attorney for Plaintiff
Attorney ID # 49634
126 East King Street
Shippensburg, PA 17257
Telephone (717)532-7388
WEIGLE & ASSOCIATES. RC. -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397
IN ThE COURT Of COMMON PLEAS
OF CUMBERLAND COUNTY
STATE Of
ERIC J. SINGER,
Plaintiff
VERSUS
LISA N. SINGER,
Defendant
PENNA.
2002-2552
Decree IN
DIVORCE
AND NOW, ~J~¥a~L~} lE , 200~2
, IT IS ORDERED AND
DECREED THaT
AND
ERIC J. SINGER
LISA M. SINGER
, PLAINTIFF,
, 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 ThE COURT: /
-- ~lrROTH O N OTArY