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HomeMy WebLinkAbout00-01450 <'offlM . . . . . :Ii :Ii;f.;f.:Ii .. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . SUSAN NOGGLE, . . 00-1450 CIVIL TERM No. P1ainti ff VERSUS . . THOMAS NOGGLE, . Defendant . . DECREE IN DIVORCE NOW, ACf)JJJ- ~ 2002 , IT IS ORDERED AND . AND . . . SUSAN NOGGLE DECREED THAT , PLAINTIFF, . THOMAS NOGGLE , DEFENDANT, AND 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. j!~ PROTHONOTARY / . .. . . . :f.;f. :f.:f. if. ;f. , r ,-.W ; ~" , -,-., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ~_/,~J . .'" -,",---~ -......' "~-~, , ,-".',.", "= - !lWiJiIil\IIliiIJi '=, ~- ~"--~.~ - -, '~ Co ~ ';; , iJ'''- IWIIllI - ,.. ~" ,. f?;,)~'c1.;1 a-r-,~ ~ .w~ ~ 1-;?7'-t?.) 7f~ /W;.~ zJ74 ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN NOGGLE, vs. CIVIL ACTION - LAW NO. 00-1450 CIVIL TERM THOMAS NOGGLE, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD o THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce ecree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceptance of Service filed bv Plaintiff's ounsel indicatino service on or about 23 March 2000. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 13 Auoust 2002 By Defendant: 13 Auoust 2002 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 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 Section 3301 (c) Divorce was filed with the Prothonotary: Dated 13 Auoust 2002, filed contemporaneous Iv herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 13 Auoust 2002, filed contemporaneouslv herewith. Date: 13 August 2002 ~~~ Attorney for Plaintiff , '" ",'-, , ~ -,I " ',' .. c.' ..c.....,.." C"'. "J .'" oil c.,.> ,.......,.., '._ r- .- .', 1!II!i~!I!!I~,. (") 0 ~ ~ '" J:a :;:1 . fgOJ c:: I'll Ci') R'fJ- ::tJ 2S; I'.) va ~.. w co. - dO 0(') :.< c, "" :E-"! ~8 :ll: ,:)-H ziYj c: SlY (..:) -I ~ .,.. ~ -< III~ ""~~"".'I"- . ~_~ '1' m . ~1 ". ~ ') l " Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - /4S0 C:u~L <-y-~ CIVIL ACTION - LAW SUSAN NOGGLE, vs. THOMAS NOGGLE, Defendant 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT WISH TO 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 HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 800-990-9108 ""~I ~,~"_~ ~~~..,.",., ,.. ~~!'-l' " ~ .~, , ... < ) ( ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Ir(J ,/'6'0 ~ -/~ CIVIL ACTION - LAW SUSAN NOGGLE, vs. THOMAS NOGGLE, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c). 3301(d) and 3301(a) (6) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I 1. Plaintiff is Susan Noggle, who currently resides at 934 Herman Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 since March 4, 2000. Plaintiff's Social Security Number is 194-42-9914. 2. Defendant is Thomas Noggle, who currently resides at 1014 South Market Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 since October 1995. Defendant's Social Security Number is 172-36-0578. """"""," '" ~, - rl"-- d' , I .) ( . , 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 13, 1989, in York County, Pennsylvania. 5. The parties have lived separate and apart since March 4, 2000. 6. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. The Defendant is not a member of the Armed Services of the United States or any of its allies. 10. The Plaintiff and Defendant are both citizens of the United States. 11. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. '''''" ~ - ! -1'1 ~ ~ . \ r . ":':'--" , COUN'I' II INDIGNITIES 12. Paragraphs one through eleven are hereby incorporated by reference herein. 13. The Plaintiff avers as the grounds on which this action is based is that the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 14. This action in divorce is not collusive. WHEREFORE, the Plaintiff prays Your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT III EOUITABLE DISTRIBUTION 15. Paragraphs one through eleven are hereby incorporated by reference herein. 16. Plaintiff states that Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by the court. "'-"'ffflll' . '1";_ ~ , . ".I I I "" I .. '. 17. Plaintiff requests that this court grant equitable distribution. WHEREFORE, Plaintiff prays that Your Honorable Court: (al Equitably distribute all property, personal and real owned by the parties; (bl Grant such further relief as the Court may deem equitable and just. COUNT IV ALIMONY PENDENTE LITE. COUNSEL FEES & COSTS 18. Paragraphs one through eleven are hereby incorporated by reference herein. 19. That by reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs. 20. That the Plaintiff's income is disproportionately lower than Defendant's income, and Plaintiff is without adequate funds to pay the costs and expenses of this litigation, and is, likewise, without adequate funds to maintain herself during the pendency of the litigation. 21. The Plaintiff is employed at United Concordia/Highmark and Home Depot and earns a combined income of approximately $26,000 gross annually. :-.,~-~,~, ,'j" , ; ~ ..J , ( ~" ( ~ , 'I 22. The Defendant is employed at Bethlehem Steel and earns approximately $30,000.00 gross annually. WHEREFORE, Plaintiff prays that Your Honorable Court grant an Order upon Defendant to pay Plaintiff alimony pendente lite and counsel fees and costs of litigation. Respectfully submitted, Lori K. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 ATTORNEY FOR PLAINTIFF "-~ " ~~ ' 4; 1,,- , . ", 1 1 . , . VERIFICATION I verify that the statement made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ..;3)q J Db . ~K Yl~ Susan Noggle =~N~ "~ "...........~~ . , H t05.157 REV. S.aO COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF HEALTH VITAL RECORDS RECORD OF STATE FILE NUMBER DIVORCE OR ANNULMENT STATE FILE DATE COUNTY [K] (CHECK ONE) o 09:MBERLAND SSN: 172-36-0578 HUSBANO 1, NAME (First) (Middle! Last 2. DATE 0' Month ay 9' 1014 S~ Market st., 5. NUMB ER 6. OF THIS MARRIAGE PA BIRTH 4. PLACE 0' BIRTH 7. USUAL OCCUPATION 08 12 46 THOMAS L. NOGGLE 2. RESIDENCE Street or R.D. City, Boro. or Twp. County tate ate- or ore/gn untry. 2 Mechanicsburg, RACE WHITE i[] Cumberland, Pennsylvania BLACK o OTHEOpecity) Laborer SSN: 194-42-9914 WIFE 8. MArDEN NAME (First) (Middle) K. City. Bora. or Twp. (Last) 10. RESlDENCE Street or R.D. County State 9. DATE "' BIRTH 11. PLACE 0' BIRTH OCCUPATION Month) Day} Year BOHER SUSAN NOGGLE 07 12 51 2 Mechanicsburg, 13. RACE WHITE o Cumberland, PA (State or Foreign CountrY) Pennsylvania 934 Herman Drive, '2. NUMBER OF THIS MARRIAGE PLACE OF OF THIS MARRIAGE NUMBER OF CHIL. DREN THIS MARRIAGE NUMBER OF HUSBANO WIFE CHILDREN TO 0 0 CUSTODY OF DATE OF DECREE BLACK o OTHER (Specify I o Services Rep. (Month) Day) Year) 15. (County) (State or Foreign Country) o WIFE [XI OTHER (Specifyl o DATE OF THIS MARRIAGE R HUSBAND o 05 13 89 17A. 17B. .York County, Penns NUMBER OF DEPENDENT CHIL. DREN UNDER 1B lvania o WifE 10 OTHER (Specifyl o 20. SPLIT CUSTODY o OTHER (Specify) D 22. (Month) (Day) (Year) 21. LEGAL GROUNDS FOA DIVORCE OR ANNULMENT Irretrievable Brea~down 23. DATE REPORT SENT (Month) TO VITAL RECORDS & Indignities Day Year 24. SIGNATURE OF TAANSCAIBING CLERK 1 ._='''''~'''~ .....,.,...., "1 ~I 5 ~~,~ o. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN NOGGLE, vs. CIVIL ACTION - LAW NO. 00-1450 CIVIL TERM THOMAS NOGGLE, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 13 March 2000 and served upon the Defendant on or about 23 March 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days I have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 13 August 2002 Date .y~)(P~ SUSAN NOGGLE << ","",~!IF . ~c_ ..+ _. [IlI!!i,' . "_~~__ 0 _;.,,>,_,_ ,,'W iftIl!I!!l~ ~rT~.- - ~~ 0 ~ '" X>o :;:1 ~!R c: r*j::a en 'r N n,? .~5 ~.~ c..) C)r.:.:.J -<<- <-" Q :too :J:" 5::: C>a ~g ::Jl: 9? 5"" ~ t::" ~ 0 -< -!'!..-- ,<- ~~ "-.> II .1 1 PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN NOGGLE, vs. CIVIL ACTION 0 LAW NO. 00-1450 CIVIL TERM THOMAS NOGGLE, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 13 March 2000 and served upon the Defendant on or about 23 March 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 13 AlllJust 2002 Date ~~~~ ~ " .r - ~".",~.~ ~.' IlJI'., , ~ ".. ,",-.1' . ,."<,,,1.,.' ~ , """. "~ *'!lII,. _ , "";.,;" 1""-" .~ ~~ -d~', _ __, . ~ <:::> ~ I'\;) 2:lo ~::n iflCo CS z!f; r- f;; I'\;) 'om c.:> ~g6 <- 0 --, ~ :bo rj:j ~8 :JI: 0- ?? 6?f1 <::::: --I ~ c- ~ -<:: , , --,~"'" ,', ~ -' .11- ~ '.' ", ~', ~ 'I" -- , II PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN NOGGLE, vs. CIVIL ACTION - LAW NO. 00-1450 CIVIL TERM THOMAS NOGGLE, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. 3.1 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 Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. . 13 August 2002 Date ~,~ X~(' SUSAN NOGGLE . '4 ~, ,.~ -. n 0 ffi -oi I'> %00 :..-:1 ~~ ?5 r-fi:D . r-- t5':; ~ Ji'" c..v ~. r-; i;!;., ()~ I ,,:::0 :to. ::;;IL ~O ::x i5::H I Z() ;j!;U I c 9? Om , Z -, =< r;;- 55 D -< I !O_ ~'-" " .." . IIIIII~ .c. '1' .'. ., "'''''''',,,,,,,,'',,''' ~ '-i"~ . --~'~'--' ~.~rr , " <-':"111,,,,.1 --""<'f !l PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN NOGGLE, vs. CIVIL ACTION - LAW NO. 00-1450 CIVIL TERM THOMAS NOGGLE, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 13 August 2002 Date ~~~~~ " - ~ '.,.-~ C L "c,C',C.C .~'" 1..."""c',''''C," ",,~.IIIij5,IJIIIlII~~ ~ .., """', '-" "<~ ('") 0 ~ ~ N :1>0 -.,,! iR~ c #;;::0 c;") -b'~ 2e N c....' -~, (I) <';. '5 ~-" S;l:a :<,cJ 3> ~8 ::lI: 00 ZT". s>E 9.> 8 z r;;- j; ::;;! -< nUIill "-"'''t>"~'--'.''-"''_----''-Itt - ,,~ 1- I' PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN NOGGLE, vs. CIVIL ACTION - LAW NO. 00-1450 CIVIL TERM THOMAS NOGGLE, DEFENDANT IN DIVORCE PRAECIIPE TO THE PROTHONOTARY: Please withdraw any and all economic claims previously filed by the Plaintiff in this mater, including claims for alimony, alimony pendente lite, counsel fees and expenses, and equitable distribution. 13 August 2002 ~~ Sa el L. Andes Attorney for Plaintiff Supreme Court 10 # 17225 525 North 12th Street Lem06yne, PA 17043 (717) 761-5361 ~ -, .~ ,~. '-=~ _.~ "_,_~., ~ J",.~_ _1_ILl,f!I!I ~ ,"",L,,,",.,,,, 0'- - ,~,~, ~~~ ~"!""- ~. ~" ..- - .-, , .~ - '""--. I"", 'nnr: 8 0 ~ N ;;: :J>o .,,~ ,gJ c:: :1:::0 G'") '11-- . h7" N --om ~ C'Jy W ~6 '" .....-c5 :l> ....~-f"j ~ ""::0 ~o :x ~;:o >8 S9 an"1 .."{ ~ r- :.rti c:> -< - ..!!"! ."""" ,> ?#~~rn ., . SUSAN NOGGLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-1450 CIVIL TERM CIVIL ACTION - LAW THOMAS NOGGLE, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Lori K. Serratelli, Esquire, being duly sworn according to law, depose and say that I served the Divorce Complaint in the above captioned matter, by depositing it in the United States mail, Certified Mail, Restricted Delivery, Return Receipt Requested, addressed as follows: Thomas Noggle 1014 South Market Street Mechanicsburg, PA 17055 I"~ ~ 11 ! :! The return receipt card is attached hereto. Dated: '31:J--;) rP ~t1)~ ~~~ 0 ~. Lorl. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9483 (717) 540-9170 Attorney for Plaintiff cl ;-1 Sworn and Subscribed to before me this 21st day of [M.rCV\.- , 2000. UU~ NOTARY PUBLIC \ Ny Commission Expires:3IZ~!03 Notarial Seal Usa Conway, Notary Public Susquehanna Twp., Dauphin County My COmmission Expires Mar. 24. 2003 " - :", ,,,, e I' - -'~- . Z 238 582 'BS us Postal Service Receipt for certified Mail No Insurance Coverage Provided. Do not use for IntemationaJ Mail See reverse Certified Fee Special Delivery Fee Restricted DelivelY Fee '" m Retum Receipt Showing to ..... Whom & Date Delivered .~ RetumReceiptShowingtoWhom <( Date,&Addressee'sAddress ' r:;; ~ TOTAL Postage & Fees '" E o u. ~I' .7r /, j'- $ ..), 9s-. alk or Date 3- \b~co ~.-. f' A.P" LJO Y( ,l-r"] I 'i . C~mplete ite~~ 1',' . and 3; Als'a c~'mpl~e . item 4 If Restricted Delivery I. desired. ' . Print your name and address on the referse . so that we can ,retLirn the card to you. . Attach this card to the back of the m'~i1piece, or on the front jf space permits. 1. Article Addressed to: '~DYY\o...S. .~ \ D \'-1 .;!3,00 \-\... \V\:~C\\O..~ \ c.$, PS Fonn 3811, SERVICE OF DIVORCE COMPLAINT ,. 1'-'- . 3. ~jce Type ~Certlfred Mall 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) , yes \ I . i 1\ 102595.99.M-1789 I' -~ - -, SUSAN NOGGLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2000-1450 :'1 THOMAS NOGGLE, Defendant IN DIVORCE MOTION FOR APL CONFERENCE AND HEARING AND NOW comes the above-named Plaintiff, by her attorney, Samuel LAndes, and moves the court to schedule a conference and, if necessary, a hearing on the claim I If or Alimony Pendente Lite raised in Count IV of her Divorce Complaint, a copy of which is 'attached hereto. ~~QQ Samuel LAndes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 ... I I' , , , , EXHIBIT A !"'Jl"'!'i!' "t '~j-- ^ ~'"~ . SUSAN NOGGLE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - ILlS-Q Cu~l'-r~ CIVIL ACTION - LAW Plaintiff vs. THOMAS NOGGLE, Defendant 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT WISH TO 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 HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 800-990-9108 - ~~~ f< ,,~ 1'- ~ ,~ ~ _ u ,~,_ . , ' Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0-0 . / 'I> () e e-;J --r;z <.-w.--/ CIVIL ACTION - LAW SUSAN NOGGLE, vs. THOMAS NOGGLE, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301 (c), 3301 (dl and 3301 (a) (6) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I 1. Plaintiff is Susan Noggle, who currently resides at 934 Herman Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 since March 4, 2000. Plaintiff's Social Security Number is 194-42-9914. 2. Defendant is Thomas Noggle, who currently resides at 1014 South Market Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 since October 1995. Defendant's Social Security Number is 172-36-0578. 'ii''''iir~~ ,.-.- r I'. ~ ~~ ~ - , , , 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 13, 1989, in York County, Pennsylvania. 5. The parties have lived separate and apart since March 4, 2000. 6. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. The Defendant is not a member of the Armed Services of the United States or any of its allies. 10. The Plaintiff and Defendant are both citizens of the United States. 11. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. .. ,..---------~-~_.-.- - ----- - _ __ _____d__ "-'- ". - -~._- . '- . . ." - - ---^"--- ;,,"'~ ~ ~~. iT- " ~ , '"'' . ".~ ., . COUNT II INDIGNITIES 12. Paragraphs one through eleven are hereby incorporated by reference herein. 13. The Plaintiff avers as the grounds on which this action is based is that the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 14. This action in divorce is not collusive. WHEREFORE, the Plaintiff prays Your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT III EOUITABLE DISTRIBUTION 15. Paragraphs one through eleven are hereby incorporated by reference herein. 16. Plaintiff states that Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by the court. --------,-'--~ "'it"1~ -~ : I ~~ ~-'"~'"I<"~ ,.."~ ~="""" 17. Plaintiff requests that this court grant equitable distribution. WHEREFORE, Plaintiff prays that Your Honorable Court: (a) Equitably distribute all property, personal and real owned by the parties; (b) Grant such further relief as the Court may deem equitable and just. COUNT IV ALIMONY PENDENTE LITE. COUNSEL FEES & COSTS 18. Paragraphs one through eleven are hereby incorporated by reference herein. 19. That by reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs. 20. That the Plaintiff's income is disproportionately lower than Defendant's income, and Plaintiff is without adequate funds to pay the costs and expenses of this litigation, and is, likewise, without adequate funds to maintain herself during the pendency of the litigation. 21. The Plaintiff is employed at United ConcordiajHighmark and Home Depot and earns a combined income of approximately $26,000 gross annually. ",,*~..~~~,.,Jilfl IT ~ . ~''''', --= 22. The Defendant is employed at Bethlehem Steel and earns approximately $30,000.00 gross annually. WHEREFORE, Plaintiff prays that Your Honorable Court grant an Order upon Defendant to pay Plaintiff alimony pendente lite and counsel fees and costs of litigation. Respectfully submitted, Lori K. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 ATTORNEY FOR PLAINTIFF "-:~~ '-I' -~, ,---~~--""" . VERIFICATION I ve~ify that the statement made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: --31<1 J 0 D . ~K YL~ Susan Noggle :'^c_'l1#~iIIlII - "~ -,. r- '"~" ._~! . . I i:' rl 105_157 REV.8-.80 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF HEALTH VITAL RECORDS RECORD OF OR ANNULMENT OIVORCE 'COUNTY CUMBERLAND [K] STATE FILE NUMBER STATE FILE DATE (CHECK ONE) o NAME (First) (Middle) " SSN: 172-36-0578 THOMAS L. ,. RESIDENCE StreetorR.D. City, 80ro. or T wp. 1014 S. Mechanicsburg, RACE WHITE ID Market St. 5. NUMBER OF THIS MARRIAG E 2 BLACK D SSN: 194-42-9914 HUSBAND Last Month ~, 2. DATE 0> BIRTH 4. PLACE 12 46 NOGGLE 08 COunty ate or orelgn untry ." Cumberland, 0> BIRTH I. USUAL OCCUPATION Pennsylvania PA OTHEOPeCifYI Laborer WIFE ,. MAIDEN NAME {First! (Middle) NOGGLE 07 12 BOHER SUSAN K. lQ RESIDENCE StreetorR.D. City. Boro. or Twp. 934 Herman Drive, Mechanicsburg, 1'3. RACE WHITE BLACK IX] 0 ICoumy} " NUMBER OF THIS MARRIAGE PLACE OF OF THIS MARRIAGE NUMBER OF CHIL. PREN THIS f,IIARRIAGE NUMBER OF HUSBAND CHILDREN TO 0 CUSTODY OF OATE OF DECREE (Day! (Year! 2 (LasrJ Way) (Year) 51 (Month) 9. DATE 0> BIRTH 11. PLACE 0> BIRTH OCCUPATION County State (State or Foreign Country) Cumberland, Pennsylvania PA I" Services Rep. (Month) (Day) (Year) OTHER ISpecify) o Customer (St<tte or Foreign Country) 05 13 89 York Countv, Pennsvlvania I17B. NUMBER OF DEPENDENT CHILr1S. PL.AINTIFF DREN UNDER 18 HUSBAND WIFE o 0 D rn WIFE SPLIT CUSTODY OTHER (Specify) ODD " 17A, " (Month) " 24. $IGNATURE OF fRANSCRIBING CLERK OTHER (Specify) o 16. DATE OF THIS MARRIAGE I r . H~~a~~D' WIFEI U OTHER (Specifv) 1'0 D 21. LEGAL GROUNDS FOR DIVORCE OR ANNULMENT Irretrievable BreaRdown 23. DATE REPORT SENT (Month) TO VITAL RECORDS & Indigili ties (Day! (Year) """'i"''"'"''"''''''''' .~" I" ~" ............,~" ~"--=, ~~ DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER: Susan K. Noggle DOB: July 12, 1951 SSN: 194-42-9914 ADDRESS: P.O. Box 608 DilIsburg, PA 17109 PHONE: ATTORNEY: Samuel L. Andes, Esquire PETITIONER'S EMPLOYMENT: United Concordia HOW LONG: 6 years P.O. Box 890089 Camp HilI, PA 17011 NET PAY: I PER: JOB TITLE: OTHER INCOME (AMOUNT, SOURCE): RESPONDENT: Thomas L. Noggle DOB: August 12, 1946 SSN: 172-36-1578 ADDRESS: PHONE: ATTORNEY: L. Rex Bickley, Esquire RESPONDENT'S EMPLOYMENT: Bethlehem Steel HOW LONG: 10 years NET PAY: I PER: JOB TITLE: OTHER INCOME (AMOUNT, SOURCE): WHEN MARRlED: May 13, 1989 I WHERE: York, PA DATE SEPARATED: March 2000 WHERE LAST LIVED TOGETHER: FOR DRS INFORMATION ONLY I '~1~l;W '-, . . ,~ ". ,>--' '-"'I '"_ ,[ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SUSAN K. NOGGLE ) Docket Number 00-1450 CIVIL Plaintiff ) vs. ) PACSES Case Number 160103671 /D3Cl865 THOMAS L. NOGGLE ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 29TH DAY OF OCTOBER, 2001 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or (i) Other ALIMONY PENDENTE LITE filed on JULY 16,2001 in the above captioned matter is dismissed without prejudice due to: PETITIONER WITHDRAWING HER REQUEST FOR ALIMONY PENDENTE LITE. o The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: DRO: RJ Shadday xc: plaintiff defend;mt Samuel An:les. Esquire L. Rex Bickley. Esquire ~ : I;') -:JfI-b( Service Type M Form OE-506 Worker ID 21005 M;I I ["- . " I'I'!"'" ..,.,..,.".",~!lilMI~l1M ~ . ~~., ~".".,...,,~~.= "", I...... ". ~ ~-, ~ -- ,- ~,. 'h ,.,"" t ~'" ,-"~,,,-,,- 0 0 () c: ?" 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