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Home My WebLink About00-03529 . . . . . . , -. H , ., .,.-",,,_ 1 -, " .'.-.- .' ~, ~' . . :Ii :Ii :Ii:li :Ii .. . . :Ii :Ii'" Of. . .. . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. . . . STATE OF No. 2000 - 3529 KEVIN J. MASSE . . Plaintiff DECREE IN DIVORCE J- ~sf) -; p, . VERSUS SANDRA K. MASSE r1- ~~T IS ORDERED AND . Defendant , PLAINTIFF, . . AND Sandra K. Masse , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . . . . . AND NOW . . . . DECREED THAT Kevin J. 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. . . . . . '" :-f.'" "'''' '" '" "''''''' .. . . ~" J. ~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,,,..""" ".~ '." , ;)< .J. .eX .Of ,~ ... . '. "\- M ~~-d-'4~4 ~ 1Jt~ ~ 4 ,0~~~ ~~ "",,"_""'''-I!IJI!' ,_<< """"""M' 1511~", ~~ , ~1",_,)4_~.~""!""",,, "....,~ ~~Ii!I!~,ll!l~ I ~ r lIl!._,~._~_ 0:""" ,I _ ~ - < _"~,, "",~,s--..:;,:,ji;';-2-".-,<L-"",~;" _ - ~ .__..-~-_, KEVIN J. MASSE, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2000 - 3529 CIVIL TERM SANDRA K. MASSE, Defendant, : IN DIVORCE PRAECIPE 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 Section (x)330l(c) ()3301(d)(l) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: June 17, 2000, First Class Certified Mail, Return Receipt Requested, Restricted Delivery. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Code: By Plaintiff: December 21, 2000; Defendant: January 21,2001. (b) (l) Date of execution of the Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code:~ (2) Date of service ofthe Plaintiff's affidavit upon the Defendant:_. 4. Related claims pending: None. 5. Complete either (a) (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: January 2, 2001. (c) Date Defendant's Waiver of Notice in ~33~2~ Divorce was filed with the Prothonotary: January 30, 2001. j/{lI( Hubert X. Oilr , Esquire Attorney for aintiff Broujos & Gilroy, PC 4 North Hanover Street Carlisle, P A 17013 7l.7-243-4574 ~1Iil'~iiOl~tliii!;~*il~~P<iIjP">'7l1-OOj;jSllll~lIfi~wam,~~<!ij1.:Ii!li.A La'~~.IiI'~ lJ.:L ~_ ,r _,~" ", w r ,-, . ~ .",^', ,._~ ", - , 1f~1-:"'-""ti" '" ~~if" - .L 0 0 0 ,- ~ ." ""0 53 <- ::.'J EPE] :l':!lR .~. :2:: ,'. .~'J ?:r.;". w :::;p CIJ.., ~;::.. :'-:'-;Cl C' < j v 2~: C-J -1-'-';"' .-::- ~;?2~ ~c ;r;; .I C i:5fT1 ~ :i;! f'V ::0 -<; - , . " ~ ,'I, ' ~~ -" -- ,- " -- ,_._'__ .. ,',_ .", ..e.\';" ;',",,,C''''!!j A KEVIN J. MASSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ~ NO. 2000.36J-.9cIVIL v SANDRA K. MASSE, 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office 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 LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 ,,-I :"ii . KEVIN J. MASSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v SANDRA K. MASSE, Defendant . ; NO. 2000 .3~'1 CIVIL : IN DIVORCE COMPLAINT Plaintiff, Kevin J. Masse, by his attorneys, Broujos &: Gilroy, p.e, sets forth the following: 1 Plaintiff, Kevin J. Masse, is an adult individual residing at 2 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania. 2 Defendant, Sandra K. Masse, is an adult individual residing at 474 Brooke Circle, Mechanicsburg, Cumberland County, Pennsylvania. 3 The parties were married on August 23, 1997, in York, York County, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania and Cumberland County for at least six months prior to the commencement of this action. '91 -I, '" .~' -' . 5 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 6 In accordance with Section 3301 (cl of the Divorce Code, the marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. BROUJOS 8r GILROY, P.c. By Hubert X. Gilroy, Esquire Attorney for Plaintiff 4 North Hanover Stree Carlisle, PA 17013 717-243-4574 ~ , ~i . I verify that the statements made in the foregoing document 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: 5~;l)-c() ){A~ / ~; Kevin ). Ma~ - M1 ""',-'-1.,, ~ "-~_M' -.-.','. ~ '--'~- nl'-' '-M> _.C_o, ',__,,; ,,--~"r'" . !~~ LII' """.i->';~..--,>.i.--- u'_c','_ ~~ ~~ --\ , n'"c',. .".",""',,, . '~""n'n'"<, ~ ~ 0 D 0 C 0 <'" -"1 gJ~~ ~- c::: -,- M",," f~i~ ...ti.- el zr- I "',-2f.I] ~0/ '.0 ';r, ,n... r:::C) , " :~~J .;;;.' 'be ..,", ' " z ) .- ~?i ---'=C' . , \ )>c~ 't':' Z ~ ..... ~ U1 -..." -.j (:J :n -< 00 s:::, ~ '> '^ ~ '" ~ '-"'-'- '~- ~ ';, )..~ _..o~ , ~ '-Jiii:.h.'-.' ( ..... KEVIN J. MASSE, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2000 - 3529 CML TERM SANDRA K. MASSE, Defendant, : IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant Sandra K. Masse, by certified mail on June 17, 2000. A copy of the Certified Mai1- Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. 1/31101 # Sworn and subscribed before ithiS ~ day of2~-, 2001 ~'~~L Notary Public ' , ~~ Notarial Sea! ; Bridget Ann Corcoran. Notary Public I Carlisle Boro, Cu~b8':land County My CommiS~~~"~BS .June 10, 2002 i SENDER: . Complete items 1 and/or 2 for additional services. . Complete items 3, 4a, and 4b. . Print your name and address on the reverse of this form so that we can return this card to you. . Attach this form to the front of the mailpiece,or on the back If space does I'm! panni!. . Write "Return Receipt Requested" on the mailpiece below the article number. ! . The Return Receipt will show to whom the article was delivered and the date - delivered. S 3. Article Addressed to: ~ 5o..rldV"- /( Mo.sx f 1..(7'-( 13rool<. Ci,,-d.L " M~c..rlIL~hL.\Y~r'jJA /105J :('. '" " '0 " " li > 1! ~ " ,.. !!J I also wish to receive the following services (for an extra fee): 1. 0 Add 's Address Restricted Deli ry or1ee. 4a. Article Number Z '-();). L(~1 4b. Service Type o Registered o Express Mail tV I" COD 7. Date of Delivery .-Il-(J~ . 8. Addressee's Address (Only if requested and fee is paid) 102595-98-8-0229 Domestic Return Receipt EXHIBIT IA oj " ~ .. '" C. -a; " " 0: c ~ ~ 0: '" c '0 " ~ .e " o ,.. "" c .. .c I- .___ct. , ~ ""'~""" , 0 Q C) C ~n < '- -of,0 :f;'l\O crter: -7 , " Z.", f'-" zr W '-"," (j) )--, C) -<~;::I' r:'~) r..:: e:~, ~"t.' " , " -f"\ ~c> . .1") --. C~) >8 ;.;."; rn ::::t ?.-: ". =< f'0 :Xl -c;;;: :'-'-"-,-^-.-~;;-, t'RiJili'd ,'- ., 3301(0).001 KEVIN J. MASSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : 2000 - 3529 CML TERM SANDRA K. MASSE, Defendant : IN DIVORCE AJ?]<'IDA VIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on June 9, 2000. 2. Defendant acknowledges receipt and accepts serviceof the Complaint on or about June 17, 2000. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I lIIlderstand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. 1l1Ilderstand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy or the Decree will be sent to me immedIately after it is moo with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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 fal~ification tOflu~orities. Date: ~'ec. 1) ;ZO"rJ , "Il /A1At Kevin 1. Mas,#7Plaintiff " ~Wd;I!.j~i~liii.. L'-j.--"="'"""~"'li ~M.lfI1il:il_" r', () C <"' -ofT": Qlrf. .z :1: ~2 -~ ..J>.--. -.-" " ~MC) Pc..: 2-": -, -< " ~, ,.~', ;; , I ! , (,'".:) o '-\1 , :'.."'" ;;,:f:. i";"" (...:;> _v (' ~-r~ ~-) t.:sn'l =-;! 3'~ -, N ,'..} en ~""""-","i ~ .' . + ...... KEVIN J. MASSE Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2000 - 3529 CIVIL TERM SANDRA K. MASSE Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 9, 2000. 2. Defendant acknowledges that a copy of the Complaint was served by acceptance of service on or about June 17,2000. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed, both from the date of the filing of the Complaint, and from the service of the Complaint. 4. I consent to the entry of a final Decree of Divorce without notice. 5. 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. 6. 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. ---c i. , , 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: !(;)//O/ ~;! ff!(UJJlQ Sandra K. Masse, Defendant SS# 0211~ 19511 ~~~ . , - , , "~ ~4k- , ",-, N~~. " KEVIN 1. MASSE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - 3529 CIVIL v SANDRA K. MASSE, Defendant : IN CUSTODY COURT ORDER AND NOW, this { t" ~ day of D J'O Lx. J , 2000, upon consideration of the attached Stipulation of the parties in the above matter, it is ordered and directed as follows: 1. The Mother, Sandra K. Masse, and the Father, Kevin J. Masse, shall enjoy shared legal custody of Corey M. Masse born June 8,1994. 2. Physical custody of the minor child shall be shared equally between the parties in accordance with the existing schedule which the parties have implemented. 3. The minor child shall attend the Cumberland Valley school district unless agreed otherwise by the parties. 4. In connection with this shared custody arrangement, the parties shall equally share the costs of daycare and also equally share the costs of various usual and unusual expenses as agreed upon by the parties. Furthermore, nothing in this agreement shall prevent either party from seeking child support in accordance with appropriate Pennsylvania rules on support. 5. This Order is entered pursuant to an agreement by parties as evidenced by the attached stipulation. In the event either party desires to modify this Order in the future, that party may petition the Court for a modification of this Order at which time the matter will be referred to a Custody Conciliator for a Conference. BY THE COURT, cc: Hubert X. Gilroy, Esquire Carl G. Wass, Esquire , J. [apl'DO ~~ jO-/7-00 RK3 II ......-~ J ,=' iBq 0;: .:'! f" 0',"" , "I, Ud.., I "'I :\[\;\ 1\: LO .". "1'1 ,",- " ", -I - ""u'~' 1\I-r,1 t...Ulv,b:l"IL.r-,,\U '...) ,,~,' ~ , PENt,iSYLVI\i\i!A . , ,.-_IlIM1l....,..~ .,jf'F~~~J!i1,I]'~9fIB~W"='<!11W'!,~"~"!{!.~;m'~~~~.~-~ f'-""" ~- ~ ~ ...~ - 'J"'..;i.,;,~ , ; - :~~ J:!i.~~Miliij-'1 ! .' ') " KEVIN J. MASSE, Plaintiff v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - 3529 CIVIL SANDRA K. MASSE, Defendant : IN CUSTODY STIPULATION ON CUSTODY The parties to the above captioned action hereby agree and stipulate that the attached Custody Order may be entered by Order of Court upon the filing of this Stipulation without any requirement for a Court hearing or any further proceedings. Date: q~(J! OD /L I~ Kevin J. MassV Date: \ 0 /0 /0 C f ,,~~ ~ rn~ Q.--...O.i ~L Carl G. Wass, Esq Attorney for Defendant ~"..:;j ""-"--lI/l~_~;jW!Ijj~!;l;:jli:-i&'~",',",rll~!j~,,;,i;1?L~~!li;jJffij*,~llilil'-~~<'-ltii!. ' p ,,,"' I' I~ ':;,,"';-,' h =._~ ~ .-~"~ ," 0 C c: C~) ;?'~ 0 L1 ~ rr; ~J nl 1...::.' -l Z r-"j ~ ~~~:. I',', ~~~ ~'T~ ,--,,; Z " :S::; -~.j j.) --< (.I'i .-< " . r '_ i'l