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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)