HomeMy WebLinkAbout94-04953
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: IN THE COURT OF COMMON PLEAS :
8 OF CUMBERLAND COUNTY .
8 .
8 ,~ .
8 STATE OF ~~ PENNA. 8
8 .
8 8
RICHARD C. DIETZ,
: Plaintiff l'; ()'H,,~~,5}H c::~YJ.L I') 94 :
8 \"'I'SlIS .
~ CONNIE S. DIETZ, 8
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Defendant "
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8 DECREE IN :
:l D I V 0 R C E ~J..O',/~A~8
: AND NOW.. b..1:.......... "OI.S' It I, o,d.,.d ond ;
fI decreed that, , , , , ,RICHARD, C,,, ,DIE:r:Z, , , , , , , , , , , , , , , . , , . , , . . '. plaintiff. 8
, .
. and, " " , , " , " , "co~un~, ,~, ,P,I,E;':\'L " " " " " , " , " , " .. " defendant. .
8 are divorced from the bonds of matrimony. 8
· 8
8 The court retains jurisdiction of the following claims which have 8
8 been raised of record in this action for which a final order has not yet
8 been entered;
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RICHARD C. DIETZ, I IN THE COURT OF COMMON PLEAS OF
I
plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I 41S3
VB. I 94 - CIVIL TERM
I
CONNIE S. DIETZ, I LAW - DIVORCE
I
Defendant
NOTICI TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you l~ish to defend
against the claims set forth in the following pages, you must take
prompt action. You are w~rned 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 Courthouse,
First Floor, Carlisle, Pennsylvania 17013, Telephone: (717)-240-
6195.
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.
Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle, Pennsylvania 17013
Telephone (717)-240-6200
RICHARD C. DIETZ, I IN THE COURT OF COMMON PLEAS OF
I
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
VB. I 94 - CIVIL TERM
I
CONNIE S. DIETZ, LAW - DIVORCE
I
Defendant I
DIVORCI COMPLAINT
COUNT I - SICTION 3301 (0)
The plaintiff by his attorney, R. MARK THOMAS, ESQUIRE, brings
this action in divorce for a Decree of Divorce from the bonds of
matrimony and respectfully represents:
1. The plaintiff is RICHARD C. DIETZ, an adult individual,
who currently resides at 512 S. Market street, Mechanicsburg,
Cumb~rland County, Pennsylvania 17055.
2. The defendant is CONNIE S. DIETZ, an adult individual,
who currently resides at
233 S. Hanover street, Carlisle,
Cumberland County, Pennsylvania 17013,
3. Plaintiff and defendant are both bona fide residents of
the Commonwealth of Pennsylvania and have been for at least six (6)
months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on July 24, 1970
in Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The plaintiff avers that the marriage is irretrievably
broken.
7. The plaintiff requests the Court to enter a Decree of
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RICHARD C. DIETZ, I IN THB COURT OF COMMON PLEAS OF
I
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I 94 - 'f95.J
va. I CIVIL 'rERM
I
CONNIE S. DIETZ, I LAW - DIVORCE
.
.
Detendant I
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) ot the
Divorce Code was tiled on september 2, 1994.
2. The marriage ot plaintitt and detendant is irretrievably
broken and ninety (90) days have elapsed trom the date ot tiling ot
the Complaint.
3. I consent to the entry ot a tinal decree ot divorce.
4. I understand that it a claim tor alimony, alimony pendente
lite, marital property or counsel tees or expenses has not been
tiled with the court betore the entry ot a tinal decree in divorce,
the right to claim any ot them will be lost.
I, RICHARD C. DIETZ, verity that the statements made in this
Attidavit are true and correct. I understand that talse statements
herein made are subject to the penalties ot 18 Pa. C.S. 14904,
relating to unsworn falsitication to authorities.
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~ICHARD C. DIETZ
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RICHARD C. DIETZ, I IN THE COURT OF COMMON PL!AS OF
I
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v.. I 94 - 4953 CIVIL TERM
I
CONNIE S. DIETZ, I LAW - DIVORCE
I
Defendant I
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 5 3301(c) of the Divorce Code
was tiled on September " 1994.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing of
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that it a claim for alil'1ony, alimony pendllnte
lite, marital property or counsel fees or expenses has not been
filed with the court before the entry of a final decree in divorce,
the right to claim any of them will be lost.
5. I have been advised of the availability of marriage
counseling and I understand that I may request that the court
require that my spouse and I part~cipate in counseling.
6. I understand that the court maintains a list of marriage
counselors at its Domestic Relations Office, which list is
available to me upon request.
7. Being so advised, I do not request that the court require
my spouse and I participate in counseling prior to a divorce decree
being handed down by the court.
8. I acknowledge that I received a copy of the Divorce
Complaint on September 22, 1994, which Complaint was hand delivered
by Richard C. Dietz.
I, CONNIE S. DIETZ, verify that the statements made in this
Affidavit are true and correct. I understand that false statements
herein made are subject to the penalties of 18 Pa.C.S.54904,
relating to unsworn falsification to authorities.
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CONNIE S. DIETZ
,3>)3 )9S'
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IN THE COURT OF COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
94 - 4953 CIVIL TERM
LAW - DIVORCE
RICHARD C. DIETZ,
plaintiff
CONNIE S. DIETZ,
Defendant
.TIPU~'1'IOII
The parU.. hereto hereby stipulate to the filinq of an
Amended Complaint for the tollowinq reasons:
1. A Complaint in Divorce was filed by the Plaintiff on
Sept.J't~r 2, 1994.
2. In Paraqraph 4 ot that Complaint the date of marriaqe i.
indicated as July 24, 1970.
3. The correct date ot marriaqe is in tact January 24, 1970.
4. The parties hereto hereby aqree to the filing of the
attached Amended complaint which set. forth the correct date of
marriage.
5. The Defendant, connie S. Dietz, hereby waives service of
the Amended Complaint on her pursuant to the Rules of Civil
Procedure inasmuch as she already accepted service of the original
Divorce Complaint on September 22, 1994.
6. Since it has been more than 90 days since the filinq of
the Complaint and both parties aqree to the entry of a Divorce
Decree as evidenced by the attached Affidavits of Consents, both
parties aqree that the Divorce Decree may be entered upon the
filing of the Amended Complaint and the other appropriate
documents.
RICHARD C. DIETZ, I IN THE COURT OF COMMON PLEAS or
I
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v.. : 94 - JjQ"3 CIVIL TERM
,j...
:
CONNIE S. DIETZ, : LAW - DIVORCE
:
Defendant :
AHIIIrDID DIVORCJ COIIPLAIII'1'
COUKT I - IIOTIO. 3301 (0)
Th. plaintiff by hi. attorney, R. MARK THOMAS/ ESQUIRE, bring.
this action in divorce for a Decree of DivorGe from the bond. of
matrimony and respectfully represents:
1. The plaintiff is RICHARD C. DIETZ, an adult individual,
who currently resides at 512 S. Market street, Mechanicsburq,
CUmberland County, Pennsylvania 17055.
2. The defendant io CONNIE S. DIETZ, an adult individual,
who currently resides at
233 S. Hanover Street, Carlisle,
Cumberland County, Pennsylvania 17013.
3. Plaintiff and defendant are both bona fide residents of
the Commonwealth of Pennsylvania and have been for at least six (6)
months immediately previous to the filinq of this Complaint.
4. The plaintiff and defendant were married on January 24,
1970, in Mechanicsburq, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The plaintiff avers that the marriaqe is irretrievably
broken.
7. The plaintiff requests the Court to enter a Decree of
Divorc..