HomeMy WebLinkAbout95-07128
~
A
1
j
~
1
i
,.,..
J
~
J
00
~
-
r-
.' .'
.~~~~~~----'-~-~~-~~~~~~)'-~~~:'~..~~~~'~'~
~. -- ~
;.
,.'
~
~
$
8
~
e
e
e
e
~
e
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA.
'I
'I
N (),.9.~~?~2..~.<::~..~. 11)
.. OONAID P. ..~IClfl'ENBERGER,
Plaintiff
,I
V('r:';lI~
w
'.'
SUSAN A. LICIfl'ENBERGER,
,;,
~
Defendant
e
~
W
0;"
DECREE IN
DIVORCE
W
0;"
el
~
~
e
8
,;,
.,
AND NOW, . .. .r:\. \I'lI ~. ::J ..29. . . .. ., 19, ..97.., it is ordered and
decreed that .. pO.ll,C\1.4 .P.'. .~j,~~~~r:. .. . . . . . . , '" ........ .., plaintiff.
and......,... ..Susao,A..t.!ctl~rn~~.,......,."............ defendant.
ore divorced from the bonds of matrimony,
8
e
~
..'
The court retains iurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
w
'"
#..~
~
None.
,~
I':'
I~
, .
I~
~ I
~ Dy The CAurl:~~. I:
e.l ~ i~ t;::, .. ., ~.';
e Alle.l: (j:'?Av~:<<:( f'. '. .6l ~ J. .' ~
~ ~t!.p;/ef.. 1-"~; CL;;{
~ f ~ Prolhonolary
~ 1*
~ _ u _ . . . . . , ''.''.'...' "..'. .. . , . ... . . . . ~
~-*~**~.~~-~--~-~-******~**~,~.~*~.
e
e
.... .... ...... ..... ......... .................... ...........................
............. ...... ...................... ............ ...
8
'"
..'
'"
.,
$
w
'"
~
e
8
e
8
.',
P,;
.',
"
8
.'~
*
~
!~
"
.,
e
e
e
~,
~
~
:..
'"
0;"
~
~
~
~
~
','
~
'.'
'p.
, .
<1-ar.f1 tie/. ~ ",;./l/~d7f~,(~
~'')11) /1pFt..a ~,~~~ ~ .
.
.'
..
DONALDP.UCHTENBERGE~
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION . LAW
NO. 95-7128 CIVIL TERM
IN DIVORCE
SUSAN A. UCHTENBERGE~
Dcfcndant
pRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit thc rccord, togcthcr with thc following infonnation, to thc court for cnUy
ofa divorce dccree:
1. Ground for divorcc: irrctricvable breakdown under ~ 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: December 16, 1995, by U.S.
Mail, postage prepaid, certified, deliver to addressee only, return receipt requested.
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: July 25, 1997;
by the Defendant: August 5, 1997.
4. Related claims pending: None.
S. (Complete either (a) or (b).)
(a) Date and manner of service of the notice of intention to file praccipe
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: July 25, 1997
Date defendant's Waiver of Notice in ~ 3310(c) Divorce was filed with the
Prothonotary: August IS, 1997.
Date: /I'~7 /.s: /9:;?
,
LANDIS, BLACK & SCHORPP
BY:~~
Edward L. Schorpp, EsqUIre
Attorney for Plaintiff
i \.0 ~
(';
-, 5
N
r~ ::c r-,~
~
CL. a~
Lf) :5*
(.!) 0:-
a:}E tu
::::l :3}o:
co; :5
15 roo
01 0
~
'.
DONALD P. LICHTENBERGER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95- 7/;;.8 CIVIL TERM
IN DIVORCE
SUSAN A. LICHTENBERGER,
Defendant
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
lose money or property or other rights important to you, including
custody or visitation with 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,
First Floor, Cumberland County Court House, carlisle, Pennsylvania
17013.
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
Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200.
".
DONALD P. LICHTENBERGER,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95- 7/28 CIVIL TERM
IN DIVORCE
.
.
v.
SUSAN A. LICHTENBERGER,
Defendant
.
.
.
.
COKPLAINT UNDER
SBCTION 3301 OP THB DIVORCB CODE
COUNT 1 - DIVORCE
1. Plaintiff is DONALD P. LICHTENBERGER, who currently resides
at 634 Holly Pike, Mt. Holly Springs, Cumberland county, Pennsylvania,
since July 14, 1995.
2. Defendant is SUSAN A. LICHTENBERGER, who currently resides at
1917 Reservoir Drive, carlisle, Cumberland County, Pennsylvania, since
1979.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six months immediately previous to the filing
of this Complaint.
4. Plaintiff and Defendant were married on July 7, 1973, in
Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties.
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 of Divorce.
".
COUNT IX - EOUITABLE DIBTRIBUTXON
9. Plaintiff and Defendant have legally and beneficially
acquired property, both real and personal, during their marriage from
July 7, 1973, until they separated in July, 1995.
10. Plaintiff and Defendant have incurred debt during their
marriage.
11. Plaintiff and Defendant have been unable to agree as to the
equitable division of said property and the allocation of debt to the
date of filing of this Complaint.
WHERBrORB, Plaintiff requests Your Honorable Court to equitably
divide all marital property.
LANDIS, BLACK & SCHORPP
BY'~~~
. Edward L. Schorpp, ire
Attorney for Plaintiff
36 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 243-3727
'.
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. S 4904, relating to unsworn
falsification to authorities.
D~U/?L~~
Donald P. Lichtenberger
Dated:
/~- d- <j~
.
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-7128 CIVIL TERM
IN DIVORCE
DONALD P. LICHTENBERGER,
Plaintiff
SUSAN A. LICHTENBERGER,
Defendant
APPIDAVIT OP SBRVICB
COMMONWEALTH OF PENNSYLVANIA )
: SSe
)
;20zt?
COUNTY OF CUMBERLAND
AND NOW, this
day of ~CE~~<
,
1995, I, Edward L. Schorpp, Esquire, attorney for Donald P.
Lichtenberger, Plaintiff in the above-captioned action, hereby
swear that I have served a true copy of the Complaint in Divorce
in the above-captioned matter, with Notice to Defend and Claim
Rights, upon Susan A. Lichtenberger, the Defendant, at her
residence at 1917 Reservoir Drive, Carlisle, Pennsylvania 17013,
by depositing same in the U. S. Mail, postage prepaid, certified,
deliver to addressee only, return receipt requested. A copy of
the return receipt card signed by the Defendant on December 16,
1995, indicating service was effected, is marked Exhibit "A,"
attached hereto and made a part hereof.
LANDIS, BLACK & SCHORPP
BY~~~
Edward L. Schorpp, Esq.
Attorneys for Plaintiff
sworn~nd sUbscribni to be~ore)me this
t9:0 day of UlJrI..-V<A-l, 1995
N~li~~
NOI.rI.1 So.1
Susan K. GUYOI, Notary ""bile
Carlisle Doro, Cumborland County
My Commission Expire. Sepl. 4, 1999
em cr, ~nnsylvJm3 AssocIation 0 OUr IS
.i.-:.,J.;,P.-r~,;'to:~-.'..~1bA"iP??~" ~~;"':""
~> '~"-'':''q'- _.."t',.l.;:'.H;'_1".'i:i~,,!I"It~_"_I"..'A.c......c.-_,~,___....._
,.,---t,^''"-'
"
BXHIBIT A
"~_,"",".,.,,,,..~_.<...;c>-.,c~'r:,' ;"" ,i~-.._._ ". ',~ ;-...-~"
'-', --?7'_'.',
. .
DONALDP.UCHTENBEROE~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
SUSAN A. UCHTENBEROE~
Defendant
CIVIL ACTION - LAW
NO, 95-7128 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on
December 13, 1995.
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.
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, lawyers fees or expenses if! 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 and waiver 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:-.bL. ~_ Lr~.I'1"i:::> ,Q~ /' I.. ..~~t.A
If 7 ' Donald P.Licht:nberg;( Plaintiff
"
DONALD P. LICHTENBEROE~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
SUSAN A. LICHTENBEROE~
Defcndant
CIVIL ACTION - LAW
NO. 95-7128 CIVIL TERM
IN DIVORCE
IDIDA VIT OF CONSE(SI
1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on
December 13, 1997. I acknowledge receiving a true and correct copy ofthc Divorcc
Complaint, said copy bcing served upon me by Certified Mail, Restricted Delivcry, on
Deccmber 16, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
days havc clapsed 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.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
63301(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, lawyers 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 and waiver 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:
~!r;/q7
rx!l~.j(/n ,\ d . #ltr~~
'Susan A.Lichtenberge , Defendant
_...._..~.. -"...., -~ ',' ----....--
'" +--
~ 0 ~
C 7-
Q .. :-?.....
- C)l'~
~7. -
0 :c (J~
~i5 -.r :-l~
-... "-
c.:.:.: In :':"<n
u. N .12
u::~J ....J ~~
::>
r:= -, ~
LJ_ ,...
0 '" 0
"
DONALD P. LICHTENBEROE~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
SUSAN A. LICHTENBEROE~
Defcndant
CIVIL ACTION - LAW
NO. 95-7128 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~ 3301(c) of the Divorce Codc was filed on
December 13, 1997. I acknowledge receiving a true and correct copy of the Divorcc
Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on
December 16, 1995.
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.
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, lawyers fees or expenses if! 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 and waiver are true and correct. 1
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
~4904 relating to unsworn falsification to authorities.
Date:
g!/l/17
. .
rxfl' ~ 1 ~
lI.;Jtl 'it ) d . f1JlIrJ I ~
'Susan A.Lichtenberge ,Defendant~
."_",:,&:l;._
~-"-...
~ .tl ~
('7
,~ N 8~
-,
.- ~
0:: (."l~
R In f::@
i c.!l ~~
~ -.:
-
~ :;; a
e.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
,
,
,
,
DONALD p, LICHTENBERGER ,
,
Plaintiff ,
,
, File No, 95-7128 Civil
,
,
,
vs. : IN DIVORCE
:
.
,
SUSAN A. LICHTENBERGER ,
,
Defendant :
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
~gth day of August ,19 97 , hereby elects to resume the
prior surname of Mavberrv , and gives
this written notice pursuant to the prov1s10ns of 54 P,s. S 704.
~.Q rwU t2 . J:.j ;;mtJJ (U~ /
/' Sig~re (J
~ (j/tL) MA/~
Signature
DATE:
'r.,/9/o0
.
COMMONWEALTH OF PENNSYLVANIA:
: 55.
COUNTY OF CUMBERLAND
:
0/1, ) .,:)000
On the f day of I... UI'--'- ,l"T, 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
official
seal,
NOlanal Selll
Ami L. GelbJuoh NO'n'y Public
lemoVne Bora ~wnt'l!j!am1 CcuJlily
My Commlssloll E';l,fC: Lll- \[, ~ooo
"
'Il
"
J "
" 0-
.3
'J
~ '
~
!':
II
~
~
~
:>-
~
1--
l!...'\)
~~.-
IJ.(.-J
elf.
.. t, ~
u',,'
{ .:1 '~
-,
Ir.
f:
?-
.:>
C):!~
!".J?;
'" s-
.'5=
~. (I)
r'
. 'i:- :?;
:1J~
-"
::1
u
A
-
Q:
;
eTl
I
-.
~
~
<:>
t)