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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;
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By
Attest:
Prothonotary
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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
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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
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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
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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.
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,
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
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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
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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)
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PS Form 3811, December 1994
/7)57
102595-99-8-0223 Domestic Return Receipt
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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.
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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.
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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~'~~"';'
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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)
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102595.99.8.0223 Domestic Return Receipt
PS Form 3811 , December 1994