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HomeMy WebLinkAbout07-0209Stephen F. Swenson, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. Peggy D. Swenson, Defendant IN DIVORCE NOTICE 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 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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. Stephen F. Swenson, Plaintiff v. Peggy D. Swenson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. ©~_ ~6 ~ U v ~ 1 -1-e~.r.. IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Stephen F. Swenson, who currently resides at P.O. Box 418, Shippensburg, Cumberland County, Pennsylvania, since November 1 1, 2006. 2. Defendant is Peggy D. Swensson, who currently resides at 140 Gettle Avenue, Shippensburg, Cumberland County, Pennsylvania, since May 2003. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on December 11, 1993, in Shippensburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. ~~~~~ Respectfully submitted, ROMINGER & W).~iARE ~ ; L./ . L~/~~" ~ By: Michael O. Pa rmo, Jr., Es e Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court I.D. #93334 (717) 241-6070 VERIFICATION I verify that the statements made in this Complaint 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: ~J /t~~ , g~ ~ S Stephen F. Swenson, Plaintiff ~.., ''' o =T ' ~ ' - ..,' "{7 ~ Q V),>' `< . p X71 CJ ~ a ~ u1 := _ .<~, ~- -~ ~ ~_~j 7 c7 ~ ~ .-~ ,°~ rev 9-- ~~ Stephen F. Swensson, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. 07-209 Peggy D. Swensson, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 11, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. § 4904, relating to unsworn falsification to authorities. Date: ~ ~~ ~ S ~ , Peg ensson/Defendant n N ° Q w ~-~.j .~ __, ~ '-'-'1 ~. f` ~=' ~ ~ (('~1 . ~ Q Stephen F. Swensson, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW v. No. 07-209 Peggy D. Swensson, Defendant 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 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 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: d3' ~~ Pegg nsson, Defendant n -- "'' ° ~ o O ~-~. 'L7 t7". S> z: T-- ~7 r`- ~. m tr ~ , tv ~ «:.~_: --- fi' r i, -- ~ ..a ~, ~~ ~ t_, -a ~ r 'Y't Y~ ~ S'I :,~ N ~, rn ~ Stephen F. Swensson, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. 07-209 Peggy D. Swensson, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 11, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. § 4904, relating to unsworn falsification to authorities. Date: - ~ ~ ~ ~ ~ ~ ~ ~" ~~ Ste hen F. wensson/Plaintiff P ` ~ ' s> ~-~r.'~ ~ ~ ~~ ~ -- ~ ..~ f~ . ~ r rte :• ~, C~-.~~.. .~-- "t7 ~ ~~-'"C'1 "! .T~ Stephen F. Swensson, Plaintiff v. Peggy D. Swensson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-209 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I . 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. Lunderstand 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 unsworn falsification to authorities. Date: I a3 - ~ 00 7 ~ h~ Stephen F. Swensson,/ Plaintiff [~ ~ c, O "~ r'C ° 2s " x_ .E ir_. ~j t'7't~ " ~ ;?' ~ ' ..A. ~~' 4 ~ ~ :.,~ N O Q Stephen F. Swensson, Plaintiff v. Peggy D. Swensson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIV1L ACTIUN LAW No. 07-209 IN DIVORCE PROOF OF SERVICE ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: /°9y~ .~vP~s.~N 2. Article Number (Transfer from service X Si natu G .V ^ ~~t ~resaee B. ~ ed by (Printed ~e) C. Date of D~Ihrery ~ `'~ _~ D. s del rasa different fmm item 11 ^ Yes If YES, enter delivery address below: y~"No 3. Service Type ~Certffled Mail ^ Express Mail ^ Registered .~Retum Receipt for Merchsndieo ^ Insured Mail ^ C.O.D. 4. Restrkted Delivary7 (Ex6s Fee) 7006 2760 X002 7405 9553 PS Form 3811, February 2004 Domestic Return Receipt to25e5-o~l-M-ts~w ~~ ~" ~~ ~ ~ ,~ ~ ~-' -;--" ~' C rv r='; c.: ~ . cxr Stephen F. Swenson, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. 07-209 Peggy D. Swenson, Defendant 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: January 11, 2007, was served on Defendant by certified Mail green card signed on January 13, 2007 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by § 3301(c) or The Divorce Code: by the Plaintiff, Apri123, 2007; by the Defendant, April 23, 2007. 4. Related claims pending: None. 5. (b) Date Plaintiff s Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Apri124, 2007. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Apri124, 2007 Date: April 2S, 2007 .-----'~ Michael O. Palermo, Jr., u e 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 93334 '`'v ~S ~ ~ r~t._ ~ ~ I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. '~~.. -~ Stephen F. Swensson I{ No. 0~-209 Plaintiff VERSUS Peggy D. Swensson Defendant DECREE IN DIVORCE AND NOW, 1~tZ ~_~ , ~, IT IS ORDERED AND DECREED THAT Stephen F. Swensson ,PLAINTIFF, AND Peggy D. SWenSSOn DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD 1N THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. BY THE COURT: PROTHONOTARY ~~ ~o~ !~-s ~o. ~ s