HomeMy WebLinkAbout02-3436Jaime M. Strayer,
IN THE COURT OF COMMON PLEAS OF
THE 39th JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
) Civil Action - Law
Plaintiff, )
Steven R. Strayer, )
)
Defendant, ) In Divorce a v.m.
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 judgment may also be entered against you for any other claim or relief requested in these
papers by the Plaintiff. You may ose money or property or other dghts important to you, including
custody or visitat on of your children.
When the ground for 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 of the Franklin County Court House, First Floor, Chambersburg, 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.
Pennsylvania Bar Association
Lawyer Referral Service
1-800-692_7375 (PA Only} or
(717) 238-6715
AMERICANS WITH DISABILITIE,g AC .
The Court of C~mm,-,,~ D~....o~ T OF 1990
the Americans with Disabilities Act of 1990. For information about accessible facilities and
....... ,~,=~ u~ rran~(Im County i~d by law to comply with
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.
Jaime M. Strayer,
VS.
Steven R. Strayer,
iN THE COURT OF COMMON PLEAS OF
THE 39~ JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Plaintiff,
Defendant,
Civil Action - Law
No. O~.
In Divorce a v.m.
COMPLAINT UNDER SECTION 3301(A) OR 3301(C) OR 3301(D) OF THE DIVORCE
CODE
COUNT I
D~VORCI~
1. Plaintiff is Jaime M. Strayer, a suijuds adult, who currently resides at 914 Baltimore
Road, Shippensburg, Cumberland County, Pennsylvania, since June 3, 2002.
2. Defendant is Steven R. Strayer, a suijuds adult, who currently resides at 324 Airport
Road, Shippensburg, Cumberland County, Pennsylvania, since October, 1997.
3. Jaime M. Strayer and/or Steven R. Strayer have been bona fide residents in the
Commonwealth for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 2, 1997 in Newville,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment of marriage between the
parties except the action represented by this Complaint.
6. The marriage is irretrievably broken.
7. Neither the Plaintiff nor Defendant is a minor or incompetent.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the court require the Parties to participate in counseling.
9. Plaintiff requests the court to enter a decree of divorce.
COUNT II
ALIMONY PENDENTE LITE~UNSEL FEES AND EXPENSES
10. The allegations of paragraphs 1 through 8 hereof are incorporated herein as fully
as though set out at large.
11. The resolution of the issues raised by this Complaint will require Plaintiff to incur
considerable additional expenses and costs.
12. The Plaintiff is without sufficient means to adequately support herself and to meet
the costs and expenses of this litigation and is unable to maintain herself during the
pendency of this action.
13. The Defendant is presently employed at Ftys Communications, Inc. with an annual
income of approximately $40,000.00.
WHEREFORE, pursuant to Section 3702, et. seq., of the Divorce Code, "Alimony
Pendente Lite, Counsel Fees and Expenses", Plaintiff respectfully requests your Honorable
Court to order Defendant to file within 30 days of service of this Complaint upon Defendant,
a complete income and expense statement, and to require the scheduling of a headng to
determine Plaintiff's entitlement to alimony pendente lite, counsel fees and expenses, and
if so, the amount.
I verify that the statements made in this Complaint are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unswom falsification to authorities.
1093307
Jaj~M. Strayer - (J ~
BARLEY, SNYDER, SENFT & COHEN, LLC.
y n ~'. MacBri.de,)Esqu~ree~'' ~ z
Attorney for Plain'fiE
Jaime M. Strayer,
VS.
Steven R. Strayer,
IN THE COURT OF COMMON PLEAS OF
THE 39~ JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3436 Civil Term
In Divorce a v.m.
ACCEPTANCE OF SERVICE
I, Richard L. Webber, Jr., Esquire, attorney for Defendant, Steven R. Strayer, in the above-
captioned matter, do acknowledge that I have received a true and attested copy of the Notice to
Defend and Claim Rights and the Complaint Under Section 3301(a) or 3301(c) or 3301(d) of the
Divorce Code filed in the above-captioned matter on July 19, 2002.
I certify that I am authorized to accept service on behalf of Defendant, Steven R. Strayer.
Date:
1095818
Richard L. Webber, Jr., Es{tuire
Attorney for Defendant
Jaime M. Strayer,
VS.
Steven R. Strayer,
IN THE COURT OF COMMON PLEAS OF
THE 39~ JUDICIAL DISTRICT OF PENNSYLVANIA
FRANKLIN COUNTY BRANCtt
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3436 Civil Term
In Divorce a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on July 19, 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 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. Section 4904 relating to unswom
falsification to authorities.
Date: ~i~! !0II''')~
i
e M. Strayer, PlaintifP°
Jaime M. Strayer,
VS.
Steven R. Strayer,
IN THE COURT OF COMMON PI',EAS OF
THE 39T}~ JUDICIAL DISTRICT OF PENNSYLVANIA
FRANKLIN COUNTY BRANCH
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3436 Civil Term
In Divorce: a v.m.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) or 3301(d) of the Divorce Code was filed
on July 19, 2002.
2. The marriage of Plaintiff and Defendant is irrethevably 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 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. Section 4904 relating to unsworn
falsification to authorities.
Date:
IN THE COURT OF COMMON PLEAS OF
THE 39TM JUDICIAL DISTRICT OF PENNSYLVANIA
FRANKLIN COUNTY BRANCH
Jaime M. Strayer,
VS.
Steven R. Strayer,
) Civil Action - Law
Plaintiff, ) 63
) C~
) No. 02-3436 Civil Term
Defendant, ) ~ Divorce a v.m.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 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.
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 Waiver 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:
Jai~e M. Strayer, Plaintiff
IN THE COURT OF COMMON PLEAS OF
THE 39TM JUDICIAL DISTRICT OF PENNSYLVANIA
FRANKLIN COUNTY BRANCH
Jaime M. Strayer, ) Civil Action - Law
Plaintiff, )
vs. ) No. 02-3436 Civil Term
Steven R. Strayer, )
Defend~t, ) In Divorce a v.m.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY_~ ~
OF A DIVORCE DECREE UNDER SECTION 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.
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 Waiver are tree and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
1123402
Steven R. Strayer, Defend~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Jaime M. Strayer,
VS.
Steven R. Strayer,
)
Plaintiff, )
)
)
)
)
Defendant, )
Civil Action - Law
No. 02-3436 Civil Term
In Divorce a v.m.
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: July 25, 2002 - Acceptance of Service signed
by Defendant's Attorney, Richard L. Webber, Jr., Esquire;
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
by Plaintiff, December 10, 2002; by Defendant, November 27, 2002;
4. Related claims pending: Resolved through private Agreement;
5. (a) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: December 18, 2002;
(b) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: December 18, 2002.
BARLEY, SNYDER, SENFT & COHEN, LLC
1132452
Attorney for Plaintiff
INThE COURT OF COMMON PLEAS
CF CUMBERLAND COUNTY
ST~,Te Of p~~~.~ PENNA.
Jaime M. Strayer
VERSUS
Steven R. Strayer
NO. 02-3436 Civil Term
AND NOW,
Decree IN
DIVORCE
, __, IT I$ ORDERED AND
DECREED THAT Jaime M. Strayer
, PLAINTIFF,
AND Steven R. Strayer
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
PROTHONOTARY
IN THE COURT OF COMMON PLEAS OF
THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA
CUMBERLAND COUNTY BRANCH
Jaime M. Strayer,
VS,
Steven R. Strayer,
)
Plaintiff, )
)
)
)
Defendant, )
Civil Action - Law
No. 02-3436 Civil Term
In Divorce a v.m.
NOTICE OF ELECTION TO RETAKE MAIDEN NAME
Notice is hereby given that the Plaintiff in the above-captioned matter, having been
granted a Final Decree in Divorce from the bonds of matrimony on the 30th day of
December, 2002, hereby elects to retake and hereafter use her previous name of
Jaime M. Koser and gives this written notice avowing her intention in accordance with
the provisions of the Act of May 25, 1939, P.L. 192 as amended.
Jai~ne M. Strayer
To be known as:
Jai~e M. Koser ' -
COMMONWEALTH OF PENNSYLVANIA )
)
COUNTY OF FRANKLIN )
SS:
On the ~'7/~ day of _.~~j , 2002, before me, a Notary Public,
personally appeared Jaime M. Strayer I~0wn to me to be the person whose name is
subscribed to the within document and-acknowledged that she executed the foregoing
for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
Member, Pennsylvania A..~3dafion O{ Notates
1137652