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HomeMy WebLinkAbout00-03843 -"; ',' , ~ -' '}:C~::)>>}(,:~~~~~)~~: )::+::{ ~.'~ ~ ~~~ ~ i.~ ~ "" ~~~ ~ ',,>' ~ ~.~ ~.; * ",.", w ~.~ ".", w ~.~ ~ ~.; ~ ~.S ~ ~.S ~ ;",; ~ J 8 ~'s ~ i4 i !>.~ ~ 'ii.~ N ~ i \i'.~ ~ i~i I >",- ti I ~ f,.~ s ~ "" ~ .,+', ;..; ~ ~ ~ . ~i a ~.~ ;..; ~ ~~ ~ ~ J:'~ ~". ~.", ~ ~ ~.~ I I i ~ AJ):;: ~::c~;::~::,~>>::(-;~>>::~~-~g:.:::,~~(,:~~::*r~~>>x)>>::~;;:,:,:~>>::.;::::::~:::c~;;:,xc~;r::~~~;::-X+X)~()>>::~:J*8{~;)~~:mrxc::g~3:,,;~-:~>>:}[{~~::c~t::'{.}fr~~~*,{(,~ti, i ~ ? ~ ~;~~ w ~:~ , ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. "J,"ll"e" ,~ll""GE!1:1:E!:L"" Plaintiff N o. ...~999...::...~.~43,................~ Civil Term Versus ,~~Il"l~,G. Ge1: 1: E!:L, Defendant DECREE IN DIVORCE AND NOW, . . . . . >w~. . ,~ . . . . . X1'9 )QQQ., it is ordered and decreed that ....,....... .:r"I).~~. 9"~. q~H~t. . .. . . . .. .. . .. . . .. . . ., plaintiff, and. . . . . . . . . . . . . )l.P!'!':L? .G... .G.e.t.t.e.l. . . . . . , . . . , . . . . . . . . . . . . . . . . " defendant, 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; .,..,.,...",........ .N.o,n..e,..,....",.",.."."...".....,.."....,...,..., By Attest: Prothonotary ~ ~~~~~~~~~~~~~~~~~~~ ~ ~ )>>::.::::::-::.::(::~:..::<>::.::.: :::.::.::. ::;.::.::~:..:..::.::.. ::'::"::<::'.::.;.. >.>>;~;' , "..", ~ ~.~ ~.~ ~ t~ ,,'s ~ i f,.~ ~~~ . ~~~ ~ .':, ~ ~ ~ ;'.s ~ ~ ~ ~~~ ~ ~~~, ~ ~ ~ t~ i ~.~ ~'s . "', ~'s ;, :;:) ~ ~.~ ";,< ~ ~.~ ~'S . ,'" ~ ~.~ 0,' ~ ~.I ~ ~.: *- ~.~ ~ ~.~ ~ ~.~ ~ ~.~ J. ~ ... $ ~ v ~ ~i' . I I I r -,,,,-'",, . '-," --" - .-," -- -<-, '. ,. . 't f/~.a:J tJc/- ~ ~ ~'4 ~ tj'./cr.CJ,?l w~~ ~~ ~ '" <--'- --f.'- , il'I IF!~._ .'., Pi- .,~ ~" < _ i~" ~~ ~ ~'W'W-"'*=r, ". IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, Plaintiff Civil Action - Law vs. #2000 - 3843 Civil Term Ronald G. Gettel, Defendant In Divorce a v.m. PRAECIPE TO TRANSMIT RECORD To: Curt Long, 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 3301(d) of the Divorce Code. 2. Date certified mail June 26, 2000. and manner of service of the complaint: by sent June 22, 2000, and received by Defendant on 3. Date of execution of the affidavit required by S 3301(d) of the Divorce Code: June 27, 2000. Date of filing and service of the plaintiff's affidavit upon the respondent: filed July 5, 2000; served on July 10, 2000. 4. Related claims pending: None. 5. to file attached: 2000. Date and manner of service of the notice of intention praecipe to transmit record, a copy of which is by certified mail received by respondent on July 10, Date: September 6, 2000. ~~- Michael B. Finucane Attorney for Plaintiff ~ ,_ __,'___ - "_' _', " _, - - ",I ~-"lfmJjlJlI_.ii!i~'W;lmi~JliB~~~II~~_;m~'80~f";;;;!i':*~,g&!51l'W~~- T_ litnnl1_~=,j~~.~""", 1- iJ~' T'~ "UU ~~~[..-." lillL ',; 'I I , , ..... C) '._<H' e ~:.:.t -0 r!_ ' r'l" ~ :- -> /,_. i_: ~;T- f~~ ( ::'-> --;.- :0:::: C,,' r-<l- )> ...--' """" -~ ---, :.<} ._u -" \ CJ -~ ~--- ~ .'.....f-. - ... IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, Civil Action - Law Plaintiff vs. #2000 - 3843 Civil Term Ronald G. Gettel, Defendant In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Ronald G. Gettel, Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraffidavit to the plaintiff's affidavit. Therefore, on or after July 28, 2000, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counteraffidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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, Pa. Bar Association Lawyer Referral Service Telephone 1-800-692-7375 (PA only) or 717-249-3166 ldJj- r 'u~oii;i;- h "~""'=l1I!uai'I!i..M.U'!j~;';5J",_j\It"")i;;;;:':;,"'~~' ~ ~, '"' "'~. ~ I " ~ ~",~;i ......."".~~~- ~ _~-"'.;..iwllilliit- ~~ ~ .. "~~'''" -, " 0 '-,.I C \:.,:'] <' ::.1) -eJ (C ,-:-j ITl r-: ",) Z L e:: U) >~ -< '< C: -'0 )> ('""'. _.- ;:; , , ,- )> ~.. j'~ '~ C s:; ;.; -:..) -~ :x; \'" -< . ..---'>~ '~;, IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, plaintiff Civil Action - Law vs. #2000 - '3('43 (!,"U~( f€A..P1 Ronald G. Gettel, Defendant In Divorce a v,m. 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 di vorce irretrievable breakdown of the marriage, you ,counseling. A list of marriage counselors Office of the Prothonotary at Cumberland Carlisle, Pennsylvania. is indignities or may request marriage is available in the County Courthouse, 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 Telephone #717-249-3166 - .~.~ ~ "'l ~ ,~.."... 'R_~- ~. -. ~--* .*~}" IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, No. 0-0 - 3 ~ '+3 civil Plaintiff vs, Ronald G. Gettel, Defendant In Divorce a v.m. COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Janie Sue Gettel, who lives and resides at 940 Sterling Court, Enola, Cumberland County, Pennsylvania, and has resided there since June, 1999. 2. Defendant Independence Pennsylvania, is Ronald G. Gettel, who lives and resides at 91 Drive, Shippensburg, Cumberland County, and has resided there since April, 1999. 3. Plaintiff and Defendant have been bona fide residents of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and Defendant were married on April 20, 1991, in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties, except for an action filed to No. F.R. 1996- 243 for divorce in Chambersburg, Franklin County, Pennsylvania, which action was dismissed on by Order of Court on September 2B, 199B. 6. The marriage is irretrievably broken. 7. The Plaintiff requests the Court to enter a decree of divorce. - - '_L . , 8. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. ~~ Gettel, Plaintiff Q 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. Date: June \ ~ , 2000. Sue Gettel, Plaintiff -,,,.~ ~ ~ , .~ I,; ~"'~-; " IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, Plaintiff #2000 - 3843 Civil Term vs. Ronald G. Gettel, Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ( ) SS: COUNTY OF FRANKLIN Michael B. Finucane, being duly sworn according to law, deposes and says that he is attorney for the plaintiff in the above entitled action, that on June 22, 2000, he mailed a Divorce Complaint to the defendant at 91 Independence Drive, Shippensburg, PA 17257, by certified mail Article #Z225134180, return receipt requested, restricted delivery to addressee only, and said address being the last known post office address of the defendant, and the said return receipt card shows the date of delivery as June 26, 2000. ~ j. Michael B. Finucane, Attorney for Plaintiff Sworn ans.Fubscribed to before me this ,,2.'{7'"""day of ~ ' 2000. ~Il.%(!.~ Notalial Seal Elizabeth A. McConnack. Notal)' Public Chambersburg Boro, Franklin County My Commission Expires June 15. 2002 Member, Pennsylvania Association of Notaries " .;,.~,',~ , , - " '~--ll~lit ~^-~, '';''Mw.."1l~~-'l<~ti~~",,!@ii1f.~__I'~~ll-J :j I '~:IiIll , ...W, o__~ '" J.luwu jd~ o <;::: <~ ~jfr ~~- ~~ ~~~-~ ~~~; -< Wdil1lli" U'l ""1 "0 ,,' ;'0 :.,) t;c- . -I I '" " ~ ,- '-"', ,: j",H'" . 1::, [] GomJjlete items 1 anator.,2 for additional services. II Complete itelJlS:.3, 4a, and 4b. 1: [] Print your nama and address on the reverse of this form $0 th~ we ca.tJ..retum this I: qardtoyou. ...." .;p. e [J Attach this form to the front oftha mailpiece, or on the back ifspaee-dees not permit. - .!! [J Write "RetumRaoeiptBequB8d' on the mailpiece below the article number. ;; D The Retum"Receipt will sllow 10 whom the article was delivered and the date o delivered. 11 3. Article Addressed to: i RONALD G GETTEL II 91 INDEP.iNDENCE DRIVE SHIPPENSJIURG PA 17257 I also wish to receive the folLow- ing services (for an extra fee): 1. 0 Addressee's Address 2. IKI Restricted Delivery 4a. Article Number Z 225 134 180 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise KI Certified o Insured DeOo By: (Print Name) III Co. <- !Ii 6. Signature (Addressee or Agent) ~ .l!! PS Form 3811, December 1994 /7)57 102595-99-8-0223 Domestic Return Receipt Ii "i: ~ 1l. I c ~ " 1ii IE f " " .2 " " ... i .c .... ,\'h ~ , ~&,; .. IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, Plaintiff Civil Action - Law vs. #2000 - 3843 Civil Term Ronald G. Gettel, Defendant In Divorce a v.m. NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 23, 1994, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 falsification to authorities. Plaintiff Date: ,-~e~ ~--r-, 2000. ."",,-,:Ii>~ "-"- :..'. ll'i'~ - ~ ""~ . . IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, Plaintiff Civil Action - Law vs. #2000 - 3843 Civil Term Ronald G. Gettel, Defendant In Divorce a v.m. COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ~ (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both) : (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): \( (a) Ido not wish to make any claims for economic relief. I un~rstand 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-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 falsification to authorities. Date: t:'J7//S'/bO ,2000. J WJi710--( ~...6Ltz/ Ronald G. Gettel, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. 4i..T'r .-.,.., r'<"-=" 'illUllliu nlJiJl' ,~, , liS"" '''- f1j". jmtnl~1!i!liC 1 " hdi!1'~!ll;fti~,_. O.ij'~I~ . .'-"~ ,., <_.1, c' ~~ '"' 1Il!lM::I . -0:"___ ~;!~."-; . .c:::::.. r~ u~!___, : ---<, .~~. r--'";,"_ , ~E >c-;: :2':; -<: C) ~: ~-~. (( ~lil!l.Hl~ -~ :/) ;~;..~ f."J .....0 .~ -"'-h""",,"- '- :-;,~ >'_,,] l;~l!&;IIIisIl t &~ ~". lIi'ii!~ii ... IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Janie Sue Gettel, Plaintiff #2000 - 3843 Civil Term vs. Ronald G. Gettel, Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ( ) SS: COUNTY OF FRANKLIN Michael B. Finucane, being duly sworn according to law, deposes and says that he is attorney for the plaintiff in the above entitled action, that on July 6, 2000, he mailed an Affidavit Under Section 3301 (d) of the Divorce Code, Notice of Intention to Request Entry of Divorce Decree, and Counter- Affidavit Under Section 3301 (d) of the Divorce Code, to the defendant at 91 Independence Drive, Shippensburg, PA 17257, by certified mail Article #Z225134182, return receipt requested, restricted delivery to addressee only, and said address being the last known post office address of the defendant, and the said return receipt card shows the date of delivery as Jul 10, 2000. Michael B. ~nucane, Attorney for plaintiff Sworn and subscribed to before me this 11th day of July, 2000. ~!i-.911~ Notarial Seal Elizabeth A. McConnack, Notary Publ~ Chambersburg Boro, Franklin C,ounty My Commission Expires June 15.2002 Member, PennsylVania AssociallOn of Notaries ~&ilIIJJll(ll:fdlt~i!l.'Hi~~Hill~:ijF!11~i&,;i~1i~'~~"';' ,C" ,~~ _to, ""d~~'" _""""_,,,,,,,,~_.,__,=__"',,,," , '" .'~ ,~ ,"~'~ ." _ ,_ '";:, .el.C:~ 'maaiJ:li1. ~~"'*#.&.: ~ "1' _~';'lrr""""""-~ wfI-tlL ~ ~~f;:;; :?~ ..- L ~j,-. ~t~~-1 '-~ ,'~ -;..-,. .' J~>=':: ~ ~::: =2 ~.J') ,-,"'~ 'J ~''-J :....) cO \_-,< ~:-:~ ~r] -< -.-~'~ """"'-'''~l ... \ t :('0. .. " OJ 51 !i :I! .. z: , - c o " i ... E o .. S~DER: a CQm'plete it~ms 1 and/or 2 for additional services. Complete items 3, 4a, and 4b. a PfitI!:,;your name and address on the reverse of this form so that we can return this card!to you. a-Attach this form to the front of the mailpiecB, or on the back if space does not ~rn;)it. . d_ .c"'- o Write' "Return Receipt Requested" on the mailpiece below 1~~er. o The Return Receipt will show to-whom the article was deli~rEld aridlliil" date ._cteJ.!vered. ....,;;,\~- ,",- 3. Mble Addressed to: 4a. Article Nurpber I also wish to receive the follow- ing services (for an extra fee): 1. 0 Addressee's Address 2. Iijj -Restricted DellvelY ' l'tGNALD G GETTEL 91 INDEPENDENCE DRIVE SHIPPENSBURG PA 17257 Z 225 134 182 4b. Service Type o Registered D Express Mail o Return Receipt for Merchandise 7. Date of DelivelY '7-10-00 Xl Certified o Insured DCCD 8. Addressee's Address (Only if requested and fee is paid) f l'i 1: .. Ul 15. J c ~ " I .. c OJ " ~ 2 il >- ~ .. t= jl' d~ I ,( f\Ji)i e piA,o Ji.<<CL a..... e - 102595.99.8.0223 Domestic Return Receipt PS Form 3811 , December 1994