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HomeMy WebLinkAbout07-0990 JONATHAN R. SEELE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : No- 07- qqD Ci v MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION -LAW 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 fro 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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 (717)249-3166 JONATHAN R. SEELE, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. ? 7 - 4 90 Ccu?-? ??`' vi. MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION -LAW COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Jonathan R. Seele, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Jonathan R. Seele, an adult individual whose current address is 60 Byron Nelson Circle, Etters, Pennsylvania 17319. 2. . Defendant is Melissa O. McConchie, an adult individual whose current address is 4704 Courtland Street, Camp Hill, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 16, 2004 in Lewisberry, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed forces. 7. The Plaintiff and Defendant are both citizens of the United States. 8. The marriage is irretrievably broken. 9. Plaintiff and Defendant have been advised of the availability of counseling and that Plaintiff and Defendant may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff and Defendant do not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 10. Plaintiff requests the Court to enter a Decree in Divorce. Respectfully submitted, nathan R. Seele 60 Byron Nelson Circle Etters, PA 17319 (717)938-5536 r VERIFICATION 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. § 4904, relating to unsworn falsification to authorities. DATE (? N S Ob 7 onathan R. Seele N M d HI -qFq JONATHAN R. SEELE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . No. 07-990 Civil MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION -LAW AFFIDAVIT OF ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. Date: a)9f)(M-_ Melissa McConchie JONATHAN R. SEELE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . No. 07-990 Civil MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION -LAW AFFIDAVIT OF CONSENT I . A complaint in divorce under §3301(c) of the Divorce code was filed on February 21, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of 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 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date: ? D I ? q ? Melissa McConchie Defendant JONATHAN R. SEELE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07-990 Civil MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION -LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) AND 3301(D) OF THE DIVORCE CODE 1. I consent to the 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 if 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 unworn falsification to authorities. Dat : ?? Melissa McConchie Defendant JONATHAN R. SEELE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . No. 07-990 Civil MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION - LAW AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce code was filed on February 21, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of 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 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. r Date: ? -/-3 J than R. Seele Plaintiff JONATHAN R. SEELE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . No. 07-990 Civil MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION -LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(0) AND 3301(D) OF THE DIVORCE CODE 1. I consent to the 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 if 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: ? _ / _? - 0 7 J an R. Seele laintiff JONATHAN R. SEELE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-990 Civil Term MELISSA O. MCCONCHIE : IN DIVORCE Defendant : CIVIL ACTION -LAW 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 §3301(c) 2. Date and manner of service of the complaint: Acceptance of service by Defendant dated February 23, 2007. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff: June 14, 2007; by defendant: June 14, 2007. 4. Related claims pending: None 5. Date plaintiff s Waiver of Notice was filed with the prothonotary: June 15, 2007. Date defendant's Waiver of Notice was filed with the prothonotary: June 15, 2007. Respectfully submitted, Date: Melissa McConchie, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JONATHAN R. SEELE PLAINTIFF VERSUS MELISSA O. MCCONCHIE DEFENDANT No. Oq 990 nn m --ar .rr DECREE IN DIVORCE AND NOW,_ TtIJn c Za , _2 5 IT IS ORDERED AND JONATHAN R. SEELE DECREED THAT MELISSA O MCCONCHIE AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, ,DEFENDANT, 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 BY THE COURT: PROTHONOTARY ?' ?'P 'U k ??,