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HomeMy WebLinkAbout02-4651 Andrew c. Sheely, Esguire .127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA 1D NO. 62469 717-697-7050 (Phone) 717-697-7065 (FaX) RONALD F. NEY, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JENNIFER M. NEY, Defendant 02 - 4~Sj CIVIL TERM IN DIVORCE 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 against you and a decree in 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 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, Carlisle, Pennsylvania. 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 LEG~~ HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ? C1 ' BY /f1{;ift//{ U1t.utl Andrew C. Sheely, J~ PA, I.D, No. 62469 127 S. Market Stre{~t P.O, Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff .Andrew C. sheely, Esquire 127 s. Market street p.o. Box 95 Mechanicsburg, PA 17055 PA 10 NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RONALD F, NEY, JR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JENNIFER M, NEY, Defendant 02 - CIVIL TERM IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Ronald F, Ney, Jr" an adult individual who currently resides at 326 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania, 2. Defendant is Jennifer M, Ney, an adult individual who resides at 643 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 27, 1989 in Mechanicsburg, Cumberland County, Pennsylvania, 5. There have been no prior actions of divorce or annulment between the parties, 6. Neither party is a member of the armed forces of the United States of America. 7, Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling, ~ 8. The marriage between the parties is irretrievably broken. 9, This action is not collusive, 10. The parties separated on or about April 1, 2002, WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing plaintiff and Defendant absolutely. Respectfully submitted, Date: September 20, 2002 Adt,;j(J81uzi Andrew C. Sheely, Esqui Attorney for Plaintiff PA ID No. 62469 P,O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 2 . VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C,S,A, Section 4904, relating to unsworn falsification to authorities. Date: September zL, 2002 /J /,' /7, ;&; / 1./"_- //~ yy~s- .,,~ Ronald F. Ney, ~ ~ Andrew C. Sheely, Esquire 127 8. Market street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RONALD F. NEY, JR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW JENNIFER M, NEY, Defendant 02 - CIVIL TERM IN DIVORCE AFFIDAVIT Ronald F, Ney, Jr" being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S,A. Section 4904 relating to unsworn falsification to authorities, . ~ A 0 ): -. )-.l ~ ~ :R ~ v, ~ ~ ~ v. . \ ~ () C "'O~ Q)m ~:L; t~l ;?"';.: ~(;:~ .~c; ~ );:,5,:) ~--1l.. ~ ~ ""' c,> "' o I'.} (/) 1"1 U '" 0"'> o " ::;1 'Il;~ -e.tj >~(~ .!jJi ..:(') ;~lrn 5J -< @) Andrew C. Sheely, Esquire 127 S. Market street P.O. BoX 95 Mechanicsburg, FA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RONALD F. NEY, JR., plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JENNIFER M. NEY, Defendant 02 - 4651 CIVIL TERM IN DIVORCE ACCEJ>TANCE OF SERVICE L David R. Getz. Esquire. hereby accept service of the divorce complaint on behalf of Jennifer M. Ney. Defendant. and further certify that I am authorized to do so in accordance with PA. R.C.P No. 402 (b). Date: October 7, 2002 0 C) '- ) c: r~ " <'" :::::> <:)l1,: (J , :'1 nlrr --I Z:r' n 63 ~,,~~ -"1 0 -' .....,- -< ...::. ~'-,~ c:) r:: c.'~' -0 - - 'I ~'":r'. ...;.;., .~5~ ,o",,() ~<::5 .'l:..-rn N ::.) "'--C ---I Z :...:> 5:i =< (;:l -< , Andrew C. Sheely, Esquire 127 S. Market street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RONALD F. NEY, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JENNIFER M. NEY, Defendant 02 - 4651 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301 (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 decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: I~~ I Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RONALD F. NEY, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JENNIFER M. NEY, Defendant 02 - 4651 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 26, 2002. 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.A, Section 4904 relating to unsworn falsification to the authorities, DATE, I ~l, , f ~n~rew c. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA IO NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RONALD F. NEY, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JENNIFER M. NEY, Defendant 02 - 4651 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 26, 2002. I acknowledge that my attorney accepted service of the Divorce Complaint on October 7, 2002, 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 servlce 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.A, Section 4904 relating to unsworn falsification to the authorities. DATE: I IlL{ lo%' I / ~~ n~lrew C. Sheely, Esquire 127 S. Market Street P.,'). Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 71' -697-7065 (Fax) RONALD F. NEY, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JENNIFER M. NEY, Defendant 02 - 4651 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301 (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 decree 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.A. Sectio...q 4904 relating to unsworn falsification to the authorities. c DATE: I ~ / 0{6 ~ .... 1:- -/. ~ ' 711-_;' . Jenie~ey ~ J --, { ,-'; ."'-..: RONALD F, NEY, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JENNIFER M. NEY, Defendant 02 - 4651 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Di vorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2, Date and Manner of service of the complaint: Acceptance of Service by counsel filed October 10, 2002. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on January 12, 2003 and by Defendant on January 14, 2003. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 4. Related claims pending: The Separation and Property Settlement Agreement dated October 17, 2002 is incorporated but not merged in the Decree in Divorce. 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: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary, January 17, 2003. Date Defendant's Waiver of Notice in Section 3301 (C) Divorce was filed with the Prothonotary. January 17, 2003. ~. ~ee~~ire Attorney for Plaintiff 10 ~ ~ 'Z/'}Tpt/~ql, [,Jlle-/ ~ p7;~~l'J -Aj;;' r~) ['/.j,r:;,/ .... J, .