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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 ~X.10 0257 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 ~l~C..~/ttf~d Mall I-I ~ Mall [] 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