Loading...
HomeMy WebLinkAbout02-2788IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND coUNTy, PENNSYLVANIA CWIL ACTION - LAW Plaintiff : : No. ~OC)~ -~'~ Civil Term V. -'~OC\ ~ %~-C~-'°\C~:IN DIVORCE Defendant : NOTICE TO DEFEND AND CLAIM RIGHTR YOU H.,I VE BEEN SUED IN COURT. If you wish to defend against the clain~s set forth' in the following pages, you must take prompt action. You are wamed 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 judgrnent 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 fights important to you, including custody or visitation of your children. When the ground for divome 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013 (7!7) 249-3166 Ee han demandado a usted a la cone. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificaeion. Usted debe presentar una apuriencia escrita o en persona o pot abogado y archivar en la corte en forma escrita sus defeusas o sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y pot cualquier que ja o alivio que es pedido en la petition do demanda. USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ~,e_XXc~ ~ ~: IN wm corot oF colonies PLUS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2002- ~-~ ~ 55Condec : ciw ^CTIOS- L^W Defendant : : IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ~O~Ci\~\\~ ~ ~l(xa~C~>~t' ,~who currently resides at Cmberl~d Count, Pe~sylvania. 2. Defend~t is W~k ~ ~e~W, who cu~ently resides at 3. Plaintiff has been a bonafide resident of ~e Co~onweal~ of Pe~sylvania for at least the six mon~s prior to ~e filing of this Complaint. 4. Plaintiff and Defen~nt were m~ed on ~ at 5. The ~ffiage is i~effievably broken, and ~e p~ies separated on 6. There ~ve been no prior acfiom of divorce or a~ulment be~een the p~fies. 7. Plaintiff, to the best ofhiffher ~owledge and belie[ avers that defendant is not in the milk~ semite of the United S~tes of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the fight to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Datel - -- Pro Se I, ~xq'~\\t~. ~ '~(t~<$q'ff~erify that the statements made in this Complaint are tree and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unswom falsification to authorities as provided in 18 Pa. C.S. §4904. Date Assisted by'~ ~ 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 ~cea~c-: IN T.E COroT OF CO~mON PLEAS oF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V Defendant : : NO. 2002- ,~ ~ : : CIVIL ACTION - LAW : 1N DIVORCE PETITION TO PROCEED IN FORMA PAUPERI.q The Petitioner, '~[J[~'~l~.,~-.~ ~x]k~2~-~_~...('-, is the Plaintiff in this action. On her behalf, I, Joan Carey, attorney for MidPenn Legal Services, do hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPerm Legal Services: MidPenn Legal Services is assisting the Petitioner in filing a divorce casepro se. The Petitioner's Financial Affidavit showing inability to pay the costs of litigation is attached hereto. Petitioner requests leave to proceed without payment of fees or costs. R~y subj~tted: . Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 0 - cr mm Defendants : AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the~0,~ in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and COrrect. (b) Social Security Number: If you are presently employed, state Em ,oyer: Salary or wages per month: Type of work: ~~ If you are presently unemployed, state Date of last employment: ~ ]"~ Salary or wages per month: Type of work: ~/~ (c) Other income within the past twelve months Business or profession: Q~ Other self-employment: 1'~ Interest: I'~ / ~ Dividends: Pension and annuities: ~ [ Social Security benefits: [h Support payments: [~ [ ~ Disability payments: Ct [ ~ Unemployment compensation and [-~ supplemental benefits: Workman's compensation: Public Assistance: I'~ / Other: (d) Other contributions to household support (Wife)(I-Iusband) Name: ~'q If your (husband) (wife) is employed, state lq Employer: ~q I h Salary or wages per month: 14 Type of work: ~ [ Contributions from children: (e) Property owned Cash: N [~ 0 Checking Account: Savings Account: Certificates of Deposit: Real Estate (including home): Motor vehicle: Make~fi~_~ Year ~\ ~ \c:~EK>? Cost _[ld2XI2~ Amount owed Stocks; bonus: Iq I~ Other: Iq (f) Debts and obligations Mortgage: H IP~ Rent? ~ ~,oO°,v Monthly Expenses:~ (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: ~x~O,C-?~C-A%Z'\~ff-'' Name: Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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. SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST /NCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL 1N THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY,S OFFICE DOCKET NUMBER: ~3~_ ~ (:~,--] ~ PLAINTIFF/PETITIONER SS# ._~0~- %%-~0 NAME: ~~~ DIVORCE INFORMATION SHEET ~URSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1,2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. ~LEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN FO THE PROTHONOTARY'S OFFICE. DOCKET NUMBER: DATE Of MARRIAGE: Danielle M. Bressler, V. Joel M. Bressler, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 2002-2788 : : CIVIL ACTION - LAW : : IN DIVORCE _PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Complaint filed in the above-captioned case. Respectfully Submitted, ~.~j~e M. BresSler,~, Pro Se Danielle M. Bressler, V. Joel M. Bressler, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-2788 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Complaint filed in the above-captioned case. Respectfully Subrcdtted, <-D~e M. Bressler, Pl~ntiff, Pro Se DANIELLE M. BRESSLER, Plaintiff Vo JOEL M. BRESSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-2788 CIVIL IN DIVORCE PRAECIPE T_QO REINSTATE CQMPLAINT To The Prothonotary: Please reinstate the Complaint filed in the above-captioned case. Respectfully Subnfitted, ~elle M. Bress , , ' Danielle M. Bressler Vo Joel M. Bressler Plaintiff Defendant ' IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 2002-2788 : · CIVIL ACTION - LAW : · IN DIVORCE ACCEPTANCE OF SERVICE I, Joel M. Bressler, do hereby depose and say that I personally received and 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. {}4904, relating to unsworn falsification to authorities. Date Joel M. Bressler Danielle M. Bressler Vo Joel M. Bressler Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-2788 : : CIVIL ACTION - LAW : : IN DIVORCE AFFIDAVIT OF SERVICE FOR PERSONAL SERVICE I, .~Ortie...I.[,~ ~ L_2?t[5;$['C,~', do hereby swear that I have served Joel M. Bressler with a Divorce Complaint under Section 3301 (c) of the Divorce Code by personally handing him/her a copy at · (Stgeet Number and Address) at (City) (State) (Zip) t~,~0~" t0 .m. on the o~ day of ~'J~¥\ ., 200 (Time) (Date) (Month) (Year) (Name of person who performed service) , verify' that the statements made in this Affidavit of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: Danielle M. Bressler, Joel M. Bressler, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-2788 : : CIVIL ACTION - LAW : : 1N 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 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 sent to me in,mediately after it is filed with the Prothonotary. I verify that 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. Date: (,~e~l~ M. Bressler, Plai~-igff Danielle M. Bressler, Joel M. Bressler, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-2788 : CIVIL ACTION - LAW : : 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 wilhout notice. 2. I understand that I may lose rights concerning alimc,ny, division of property, lawyer's fees or expenses ifI 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 sent to me immediately after it is filed with the Prothonotary. I verify that 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. Date: 12olo_ Signature: Joe M.~er, De endant Danielle M. Bressler, Joel M. Bressler, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-2788 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on June 7, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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. Section 4904 relating to unswom falsification to authorities. ~ ~ ~ Date: 7/zS~]x~ Signature~ /~~~~'-'"~ r - - t ~ Joeld~. ]3ress~er, 15efefidant Danielle M. Bressler, Joel M. Bressler, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : N©. 2002-2788 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on June 7, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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. Section 4904 relating to unswom falsification to authorities, t~ , - ~ M. B])essl~r,'Pla~tffL) ' '~- Danielle M. Bressler Plaintiff VS. Joel M. Bressler Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN3?Y PENNSYLVANIA No. 02-2788 CW1L 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. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance of Service form on March 27~ 2003. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on July 4, 2003; by Defendant on July 20, 2003 (b)(1) Date of execution of the PlaintiWs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of filing and service of PlaintiWs Affidavit upon Defendant: N/A 4. Related claims pending: There are no outstanding claims. 5. Complete either paragraph (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: N/A. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divome was filed with the Prothonotary: July 25, 2003. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 25, 2003. Plaintiff's Social Security Number: 589-48-2880 Defendant's Social Security Number: 209-58-9847 Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. DANIELLE M. BRESSLER PLAINTIFF VERSUS JOEL M. BRESSLER DEFENDANT N O. 02-2788 CIVIL DECREE IN DIVORCE AND NOW, ~L~I~,~ , IT IS ORDERED AND DECREED THAT DANIELLE M. BRESSLER PLAINTIFF, AND JOEL M. BRESSLER , 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; ALL CLAIMS HAVE BEEN RESOLVED. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. Defendant : FILENO. ~C)C) ~ IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the ~<b day of '~k.k\ ~ ~ D03, hereby elects to resume the prior surname of and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: Sig~at~r.e~ Being resumed NOTARIAL SEAL CLAUDIA A, BREWI~AKER, NOTARY PURLIC Carlis~ B0r0. Cumberland County My Commission Expires April 4, 2005 Notary Public COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : On the ~)~c-- day of d ~gZ)]O..~// , 20 (~z.-/ before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal.