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HomeMy WebLinkAbout02-4067STAcI D. GUIGER, Plaintiff vs. MATTHEw p. GUIGER, Defendant : IN THE COURT OF COMMON PLEAs OF : CUMBERLAND COUNTy, : CIVIL ACTION _ LAW PENNSYLVANIA : 2002-~/O~7 CIVIL : : IN DIVORCE You have NOTIcE TO DEFEND AND CLAIM Ri~TS 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 ] d~ment 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 COUnselling. A list of marriage COUnselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT Fi~E A CLAIM PROPERTY, LAWYER S FEEs OR FOR ALIMONy, DIVISIo~ OF OR ANNULMENT IS GRANTED, YOU MAy LOSE THE RIGHT TO CLAIM ANy OF THEM. EXPENSES BEFORE A DIVORCE 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 (717) 249-3166 STAcI D. GUIGER, Plaintiff vs. MATTHEw p. GUIGER, Defendant IN THE COURT OF COMMON PLEAs CUMBERLAND COUNTy, OF CIVIL ACTION _ LAw PENNSYLVANIA 2002- ~o~ 7 CIVIL IN DIVORCE CONPLAzNT UNDER SECTION 3301(o) OF ~HE DZVORc~ COD~ AND NOW, COmes the Plaintiff, Staci D. Guiger' by her attorney, Dale F. Shughart, Jr. and States the following COmplaint. 1.. The Plaintiff is Staci D. GUiger, who CUrrently resides at 1323 White Birch Lane, Carlisle, Cumberland County, Pennsylvania 17013, Since January, 2001. 2. The Defendant is Matthew p. Guiger, who CUrrently resides at 1323 White Birch Lane, Carlisle, Cumberland County, Pennsylvania, 17013, Since January, 2001. 3. Plaintiff and Defendant have been a bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 1999' 4. The Plaintiff and Defendant Were married on July 31, 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of marriage COUnselling and that the Plaintiff may have the right to request that the COurt require the parties to participate in COunselling. WHEREFORE, the Plaintiff requests the Court to enter a Decree of Divorce. 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: August 27, 2002 ~taci~ L'arAisle, PA ._ ~c, ~Uite 203 (717} 241_4~11~'013 Attorney I.D. 19373 STAcI D. GUIGER, Plaintiff vs. MATTHEw p. GUIGER, Defendant : IN THE COURT OF COMMON PLEAs OF : CUMBERLAND COUNTy, : CIVIL ACTION _ LAw PENNSYLvANiA : 2002- 90&7 CIVIL : IN DIVORCE WAIVER OF ~OTxcE OF INTENTION TO REQUEST ENTRy OF A DIVORCE DECREE UNDER $ 330~(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 b~ the Court and be sent to me immediately after it that a Copy of the decree will prothonotary· is filed with the 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: STACI D. GUIGER, Plaintiff VS. MATTHEW P. GUIGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002- 7 civil : : IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint. A true and correct copy thereof has been delivered to me by Dale F. Shughart, Jr., Esquire. Date: Matthew P. Guige~. 1323 White Birch Lane Carlisle, PA 17013 STACI D. GUIGER, Plaintiff VS. MATTHEW P. GUIGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 7 civil IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 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. Matthew P. Gu~er STACI D. GUIGER, Plaintiff MATTHEW P. GUIGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002- 4067 CIVIL : : IN DIVORCE AFFIDAVIT OF CO~SENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 27, 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. 4. 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 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: December iQ~%, 2002 Staci D. Guiger ~ Sworn to and subscribed before me this /~ 4A day of December, 2002. BCI~O ~ GARLI~ ~ ~0. PA I . I STACI D. GUIGER, Plaintiff vs. MATTHEW p. GUIGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002- 4067 CIVIL : : IN DIVORCE ~FFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 27, 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. 4. 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 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: December iQ-~%, 2002 Staci D.' Guiger ~ Sworn to and subscribed before me this /~ day of December, 2002. STACI D. GUIGER, Plaintiff vs. MATTHEW P. GUIGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002- 4067 CIVIL : : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF MARRIAGE COUNS~T.?.INO. 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 27, 2002. 2. The marriage of the 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. 4. 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. 5. I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. 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: December /~ , 2002 Matthew p. Sworn to and subscribed before me this /~ day of December, 2002. O~CAmJm. E, CUMaErb~CO I'A I STACI D. GUIGER, Plaintiff vs. MATTHEW P. GUIGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2002- 4067 CIVIL : : IN DIVORCE PR3IECIPE 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 ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service of Complaint on Defendant delivered by Dale F. Shuqhart, Jr. on Auqust 31, 2002. 3. (Complete either paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by plaintiff December 16, 2002; by defendant December 16, 2002. (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: ; (2) Date of filing and service of the plaintiff's affidavit upon the respondent 4. Related claims pending: N/A 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 plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: Auqust 27, 2002. Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: e~pt ember 6, 2~0~. Attorney f~ P~int~ff Dale F. Shughart, J~. 35 East High Street, Suite 203 Carlisle, PA 17013 (717) 241-4311 STACI D. GUIGER, Plaintiff VERSUS MATTHEW P. GUIGER, Defendant IN THE COURT OF COMMON PLEAS (DF CUMBERLAND COUNTY ST/~ "F E OF PENNA. NO. 2002-~067 CIVIL AND NOW, DECREED THAT DECREE IN DIVORCE STACI D. GUIGER , IT IS ORDERED AND __, PLAINTIFF, AND MATTHEW P. GUIGER 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 ATTEST: J- --~PROTHONOTARY