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HomeMy WebLinkAbout07-0757JUSTIN TRESSLER, Plaintiff V. MICHELLE TRESSLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 0`157 CIVIL TERM CIVIL ACTION - LAW : 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 COUNTYBAR ASSOCIATION 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 JUSTIN TRESSLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO.0 'r. 7s I CIVIL TERM MICHELLE TRESSLER, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT 1. Plaintiff is Justin Tressler, who currently resides at 431 Pine Road, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. Defendant is Michelle Tressler, 130 Meals Drive, Carlisle, Pennsylvania 17015. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 6, 2001 at Upshore County, West Virginia. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since January 8, 2006, and continue to do so. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. The Plaintiff in this action is not a member of the Armed Forces. WWEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, ABOM & KUTULA"s, L.L.P. DATE 02 100 I'n Kara W. Haggerty 36 South Hanover Sti Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 VERIFICATION I, JUSTIN TRESSLER, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. 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 2-2 _ O JUSTIN T SLER CERTIFICATE OF SERVICE AND NOW, this tL'-day of February 2007, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Complaint, upon the Defendant's Counsel by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Jane Adams, Esquire 64 S. Pitt Street Carlisle, PA 17013 W? Kara W. Haggert y, te C -0 T i I. ?Jj JUSTIN TRESSLER, Plaintiff V. MICHELLE TRESSLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 07-757 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this JjAday of February, 2007, I, Jane Adams, Esquire, hereby certify that I did receive and accept service of the Complaint in Divorce in the above captioned matter on behalf of the Defendant, Michelle Tressler, and I further certify that I am authorized to do so. DATE _211362 Respectfully submitted, !T Adams, Esquire 64 . Pitt Street rl isle, Pennsylvania 17013 17) ) 245-85013 Attorney for Defendant C) r- P 4p q -v CV, rv"t- • to- t' JUSTIN TRESSLER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :No 07-757 Civil Term MICHELLE TRESSLER .1N DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on February 8, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. the decree. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: -711 q /,f, 0O -7 Jus . Tressler, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 43301(d) OF THE DIVORCE CODE 1. 1 consent to 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 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 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: J 1 ?(/ 2 00 -7 ",4, v Justi . Tressler, Defendant r- Z, _ AIJ r_n t. o "c MICHELLE K. TRESSLER, Tma-+ V. JUSTIN C. TRESSLER, AA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA a 1- IS? No. 0 Civil Term low V r IN Gb'-& HY AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on February 8, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unworn falsification to authorities. ?& d, & Date- ?? v 7 Michelle K. Tressler, aA? WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND 43301(d) OF THE DIVORCE CODE 1. I consent to 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 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. §4904 relating to unsworn falsification to authorities. Date: Michelle K. Tressler, oe-9 "asA ti C= c y ?• JUSTIN TRESSLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 07-757 CIVIL, TERM MICHELLE TRESSLER, CIVIL ACTION - LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground(s) for Divorce: a. Irretrievable Breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: a. Complaint was filed on February 8, 2007, and an Acceptance of Service signed by Jane Adams, Esquire, on February 13, 2007, on behalf of the Defendant was filed in the Prothonotary Office on February 14, 2007. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: a. by Plaintiff July 18, 2007; by Defendant: August 2, 2007. 4. Date of filing and service of the Plaintiff's affidavit upon the Respondent: a. July 19, 2007. 5. Related claims pending. a. None. 6. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: a. N/A. 7. Date Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: a. by Plaintiff: July 19, 2007; by Defendant: August 17, 2007. Respectfully submitted, DATE 0 12?o-7 "0M& K=LA"S, L.L.P Kara W. Haggerty, Esq e Supreme Court ID #86 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff JUSTIN TRESSLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 07-757 CIVIL TERM MICHELLE TRESSLER, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 22' day of August, 2007, I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Transmit the Record on the Defendant by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, addressed as follows: By First-Class Ma Jane Adams, Esquire 64 South Pitt Street Carlisle, Pennsylvania 17013 Attorney for the Defendant wc i S? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff NO. 2007-757 VERSUS Michelle K. Tressler, Defendant DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT Justin r_ TrP,B?lar PLAINTIFF, AND Michelle K. Tressler 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; BY THE COU ATTE PROTHONOTARY