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HomeMy WebLinkAbout06-6137 ~ '" VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW CHARLES F. LOBAUGH, Defendant : NO. tJt.. &137 : IN DIVORCE CIVIL TERM 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIA nON 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 .. VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W CHARLES F. LOBAUGH, Defendant : NO. t;J(, ~ {.,/J? : IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Vickie A. Negley, an adult individual currently residing at 27 East Main Street, Newville, Cumberland County, Pennsylvania. 2. Defendant is Charles F. Lobaugh, an adult individual currently residing at 1525 Upper Bermudian Road, Gardners, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 4, 2001, in Adams County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. .. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, ~~'" It h ~ h ""1\6\ - .clL"t'\~d, l\ Hannah Herman Snyder, Esq re - , Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 4 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: /0- /',-()~ li~L, (2~_ VICKIE A. NEGLEY, PI tiff - t~ '- ~ ~ '0 " "'" ~ fJ\." ~ .' ~ ~ ~ '^' ~ '\ \~ ~ \ \ ~ ~ ~ ~ ~ () f:: ~ -rl~'::: C;:;:) 0 r'~ u} 0-- -.... f:rr. C) 'f /'i= ,::~' c-;; i! ':~) ..' --I rn ::n r.:: ' ' 1'\:> -0 f-- _> a :") Fr! .-,.' ,::j Y 2,<: ;:::; 5'; :fL~.9 ~~ .~-~~.::; , . ,. _._ C3 ;.=: F5i .:3 " C5rn '. h! o S:j --< ~ VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION-LA W CHARLES F. LOBAUGH, Defendant : NO. 06-6137 : IN DIVORCE CIVIL TERM PRAECIPE TO THE PROTHONOTARY: Please reinstate the Divorce Complaint filed in the above captioned action. Respectfully submitted, Date: \.21- Y - all> ~~_ ~T\.M.l\f\- ~N\\~l.l\ Hannah Herman-Snyder, Esqu e Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 ~ <;? % C' }- ~ ~~ .-c t:;) ~~ i.. "'?' C.>, ~::.' . -f.\ .... ....., '\ (~ (") ~1'" ("\\ ,/;::.; ;~ -~ ~ -.:> -< -... ~ u'" :;:- VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION-LAW CHARLES F. LOBAUGH, Defendant : NO. 06-6137 : IN DIVORCE CIVIL TERM ACCEPTANCE OF SERVICE I, Charles F. Lobaugh (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsifications to authorities. /Cl- b- 0'0 Date ~~~ ~HARLES F. LOBAUG ,...., <::::> = 0"\ o rt1 (""') o 11 :r!.,.., 01-..,' " -um ~T! CfJ -:;C; ,. N ~ C) (.n i, ;::.:-:; rtl VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6137 CIVIL TERM CHARLES F. LOBAUGH, Defendant : CIVIL ACTION - LA W : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301 (c) ofthe Divorce Code was filed on October 20,2006, reinstated on December 4,2006, and service was made on December 6, 2006 by Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 3-,:;v-o'? ~a.~ VICKIE A. NEGLEY, Plaintif r D ~~ r--.) = = ....... '"t:lr> :"0 ::;;":1 I w v ::J'..': o -n -f ~:D ~<1 Fn "'0 TiT i;~~O {~~ ~~ 1> ~D =< N .. .r:- ..t="" VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6137 CIVIL TERM CHARLES F. LOBAUGH, Defendant : CIVIL ACTION - LA W : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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 F ALSIFICA TION TO AUTHORITIES. DATE: .3, 'J. V-o? , 1/~~- a~ VICKIE A. NEGLEY, Plaintiff (J-- 0 ,...,;) ~ = ~~ = -..I ~ :I!.." -:1 n1- :;;::::1 -nFn I :(10 c..:> ~;~ Cl "...- -r~ -0 .>~:D 3: :<0 N 3m .. --I C' ~ +" ~ VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6137 CIVIL TERM CHARLES F. LOBAUGH, Defendant : CIVIL ACTION - LA W : IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under S3301 (c) of the Divorce Code was filed on October 20,2006, reinstated on December 4,2006 and service was made on December 6, 2006 by Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.CS. ~4904 RELATING TO UNSWORN F ALSIFICA nON TO AUTHORITIES. DATE: 3 - 31- 07 ~~~ CHARLES F. LOBAUGH, De Clant f"-o) = = ---i ~ ;;;0 I W -0 ~ N ., .4='" W ~ ~ :I::-n rl1p: -(1 pJ, -, 1 ............ :~(S ;~c. :r~ ~"~;:~ FA ':.~ '"}..... :q -.... VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6137 CIVIL TERM CHARLES F. LOBAUGH, Defendant : CIVIL ACTION - LA W : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. DATE: 3- ;15-07 ~~~ CHARLES F. LOBAUG efendant o c ;:7= -..J. c:: ~ ."" ""'-3 <= <= --.I > U :;u I W -0 3: ~ :J!-... I'll ..w r- -om ):]0 C> 1 =?~~ <5 :IJ .,.0 c:sm --I 15 -< N .. ..r:- c...:> VICKIE A. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-6137 CIVIL TERM CHARLES F. LOBAUGH, Defendant CIVIL ACTION - LAW 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. Ground for divorce: Irretrievable breakdown under 93301(c) 3301(d)(1) oftne Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by Acceptance of Service on September 20, 2006. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by 93301 (c) of the Divorce Code: by Plaintiff: 3/24/07 by Defendant: 03/31/07 (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: April 3, 2007 Date defendant's Waiver of Notice In 93301 (c) Divorce was filed with the Prothonotary: April 3, 2007 ';).1(1 1'..A.a.k ~ ~ l\~ - .s:t"f Ll'\. Hannah Herman-Snyder, Esq re GRIFFIE & ASSOCIATES Attorney for Plaintiff N = 5 :P" -0 ?V \ (.0.) '2 -;:I -...~ -0 ~ ~ :t, :D flr: -o.-n -:}o ;~i ~~~ ....~Q 0'" .-\ 55 ;...-.:: r...:> .- J:"" ...- - ;t; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY ;t; STATE OF ;t; ;t; ;t; ;t; Vickie A. Negley, Plaintiff VERSUS Charles F. Lobaugh, Defendant AND NOW, DECREED THAT PENNA. No. 06-6137 DECREE IN DIVORCE ;:In"" '/ , jlr , b(J7 ,IT IS ORDERED AND Vickie A. Negley , PLAI NTI FF, AND Charles F. Lobaugh , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. ;t; ;t; ;t; ;t; ;t; Eli THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE Eli BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. U/; Ji ;~~ PROTHONOTARY ff. J. _~ f ~- 0jf'Jd.. u:> D It ~_~ P f'- ~~..pO [0-[.1/1 ~ . ' " " .... ..f....