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Home My WebLink About97-05728 " \. u ~ 't .., ~ If 0... ~ " " t' 'It ." ...... u 3' ~ 1,\ (' \. ~ ... . . .~ .. ~ I , 0- j ri ,! to- "" , f' Q'- ~ . ~ oJ/'~~ aq/ ~~~~~<<1~ 9',;)I,?~ '77..r~ A4-ud'/ z' ..../~. I' Ii ,i II 'I !I II ,. IIGERALD A. FOGELSANGER, I Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. I LEIGH R. FOGELSANGER, I Defendant I NO. 97-5728 IN DIVORCE PRAECIPE TO TRANBHIT 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: JJOl(d) of the Divorce Code. Irretrievable breakdown under S 2. Date and manner of service of the Complaint: June 9, 1999, by United States First Class Mail. J. Date of execution of the Affidavit of Having Lived Separate and Apart required by S JJOl(d) of the Divorce Code: June 9, 1999; (2) Date of filing and service of the Plaintiff's Affidavit upon the Defendant: June 9, 1999. 4. Related claims pending: None 5. Date and manner of service of the Notice of Intention to Praecipe to Transmit Record, a copy of which is attached: 22, 1999 by United States First Class Mail. File (UlY Respectfully sUbmitted, DISSINGER , DISSINGER Date: re cs/;;. y Iye{ cc: Gerald A. Fogelsanger Leigh R. Fogelsanger ,~) '.. ~- r- C f- , r-i..,.- l_h)~ :':( , . "_\ ~~. ( ~ . ..~ >1 i') I :14 r:._ .leu l,.,..' .'1'.... v' C"\ .'.j '.1' LJ II , . GERALD A. FOGELSANGER, plaintiff IN THE COURT OF COMMON PLEAS I OF CUMBERLAND COUNTY PENNSYLVANIA vs. LEIGH R. FOGELSANGER, Defendant NO. 97-5728 IN DIVORCE NOTICB or INTENTION TO REQUEST ENTRY or S 3301(4) DIVORCB DECREE TO: LEIGH R. FOGELSANGER, DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the S 3301 Cd) affidavit. Therefore, on or after August 21, 1999, the other party 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 counter- affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. 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. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKB THIS PAPER TO YOUR LAWYER AT ONCB. Ir YOU DO HOT HAVE A LAWYER OR CANNOT AFFORD ONB, GO TO OR TELEPHONB THB OrrICB SET rORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR 1 COURTHOUSE SQUARE CARLISLE, PA 17013-3387 717-240-6200 [r ('1") ~ c: ~ ; :~~~ "'s .' . .' -~;-] ,O,J .J I ! / " ,:;; L' lrl- U, , (.'"\ :j , en U " , ~ l:'. I" 'I C' '..) p .~ - ~ r\'\ ~ --::::r 'i""'> c...:. ~ '... r- ~~ ~~ t-; \-r>- ~8d~ -,!( (".;.... cHil~ -'!-;Z' _.-:;1 -;~~ ...: c: -8i ~<8 Q. ~~ I d~j i . tj : I i i = ,j ~..) \'~ "'- .J ............. v.--:-, -.... ~ ~ ~i i~ ~ ~ ~ ~ ~ ~ fi UJ ~ .- ~ II I ~" ~ <( ~ ' ~ . o "'0( g,? o(..~Q. ~ I )0 ~ w d z > f a: ..: 5 0'" "' ::l 1: z l) m i ..: ~ ~ I- II: ! Ul o " z (5 Z ~ ~ '" ~ o(o(~~ 9 ~ ~ g ;" i on i !l! III ;z: I<-< ..... 0 .. '. ." .. ' , . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ()L:V-~ L 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 rights 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 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. Court Administrator 4th Floor Cumberland county Courthouse Carlisle, PA 17013 (717)-240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Gerald A. Fogelsanger, Plaintiff I NO. fj1. ru j' (~~..J' '"&.- CIVIL ACTION - LAW VS. IN DIVORCE Leigh R. Fogelsanger, DEFENDANT COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Gerald A. Fogelsanger, who currently resides at 125 Fogelsanger Road, Shippensburg, Cumberland County, Pennsylvania, since August, 1997. 2. Defendant is Leigh R. Fogelsanger, who currently resides at Box 84, Cowan, Tennessee 37318, since August, 1997 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on September 17, 1993, in Kissimmee, Oscola County, Florida. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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 counseling. fi: ,... Lr. 1'- , I 9 )~.-' LJ ".-, ( ,. .., . . rt ..,. -, ((~ . F:: r- '/1 '4', .~l: :', C.o-j , . >~ U,;' I ,1 'J: ld :: .~l. I u_ -.' It. to ::5 u cro u Ul 0< lol ,..l Po .... .., ~ - Z .... s:: E- 00< ... III Z ~Po .., '0 ... .s:: s:: 0< o . p;", .QI ,..l '8~I~ia U>< lollll P;.... Po E- t!)... . lolQl :I: ~~~2:~ It<Z ZPO > t!)!::l 0 00 0< Z U 0 Ul 0< j ~ ~ i~ E-U ,..l Ul Q 2~ lol ,..l lol lol t!) lol Q U 0 t!) Z UO< p: It< 0 lol ,..l 0 It< :I: 1olP; > !::l 0< :>:lol ... ,..l :>: ~~ Q 0< t!) P; ... 0 Z lol lol ...U Z ... t!) ,..l " ,. . ---. ll(.\'II/1 tT ,Vrf!iftl/I .. .i.. , v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA NO, q7. 57:1.~ ell'" L IN DIVORCE GERALD FOGELSANGER, Plaintiff LEIGH FOGELSANGER, Defendant NOTICE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claim 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 judgement 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, 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, LAWRENCE E, WELKER, PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE I COURTHOUSE SQUARE CARLISLE. PENNSYLVANIA 17013 (717) 240-6195 3301(c) and 3301(d). in that: a) The marriage is irretrievably broken and ninety (90) days has elapsed since the date of filing and service of the Divorce Complaint on the Defendant, b) Plaintiff and Defendant have lived separate and apart since December 1996 and continue to do so, At the appropriate time the Plaintiff will file the appropriate Affidavit attesting to the two-year separation, 8, The 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 counseling, 9, Defendant is not a member of the armed services; WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree of Divorce. Respectfully submitted, Date ~,If} ~J Austin F, Groga , Esq Ire 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 Attorney for Plaintiff 1.0, NO. 59020 ~ ,.-'.- i ,.. cr; , ... / (y.., '. ') , .. ~ , .' , 1 :.'i' < .. \ ,::.j , :-... V:t , 1 .:~,; , i t.~ " .. , ,.il - ) ) d... , I , C". ::3 t..) "', U III U r;'j II: 0 o--'l > - Po. CXl H N C 0 ~ i~ z .... - 0 1tI II: - Z . ~~ , t-l II: H- Z ~ I .... CI t-l gj~o~j OZ 0\ Z CI ~ UO ...: :il z - ~ ~ 0 . III H O~ ~t: f&<U 0 o--'l III ~ t/l E~ z ~ i 0 Z t-l o--'l ~~...:z CI.... t-l.j.J ~ ~~~~~ I 0.... ClI:: II:~HO f&<..-i Onl 0 '. .\:. o ~H~ .j.J f&<'O U Z~j!::f o ~U . I:: . I:: Vi .:[ I U~>UII: ...:'... > . Q) 0 II'l Z ~o--'l"':O nl 11:.... ~ i5 ~~ ~ >< > 0.... Q) 0 ::COlllo--'lH o--'lPo. ::co Z ~UZHO ~ CI ~ Z> H Zf&<~HZ ~ ~ HOPo.UH CI o--'l . . .. I I GERALD A. FOGELSANGER, I Plaintiff I I I I I I I !I II IN THE COURT OF COMMON OF CUMBERLAND COUNTY PENNSYLVANIA PLEAS vs. LEIGH R. FOGELSANGER, Defend~nt NO. 97-5728 IN DIVORCE T 0 D . r . N D NOT Ie. 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 divorce is irretrievable breakdown of the marriage, you may counseling. A list of marriage counselors is Office of the Prothonotary at: Office of the prothonotary Cumberland county Court House 1 Courthouse Square Carlisle, PA 17013-3387 indignities or request marriage available in the I IF YOU 00 NOT FILE A CLAIM FOR ALIMONY, DIVISION OF I PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT I IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF TH~M. I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 , 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. Court Administrator Cumberland County Court House Fourth Floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 il I' GERALD A. FOGELSANGER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. LEIGH R. FOGELSANGER, Dsfendant CIVIL ACTION NO. 97-5728 IN DIVORCE NOTICB OF RIGHT TO COUNSBLING You are one of the parties in the above captioned action in divorce. By virtue of section 202 of the pennsylvania Divorce Code, it is a duty of the Court to adviso both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse square Carlisle, PA 17013-3387 Prothonotary GERALD A. FOGELSANGER, Plaintiff II vs. LEIGH R. FOGELSANGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION NO. 97-5728 IN DIVORCE AMBNDBD COMPLAINT IN DIVORCB 1. plaintiff Pennsylvania, Pennsylvania. is Gerald residing in A. Fogelsanger, a citizen of Mechanicsburg, Cumberland count~', 2. Defendant is Leigh R. Fogelsanger, a citizen of Pennsylvania. Her current address is 11 Poplar Lane, Newburg, Cumberland county, Pennsylvania. 3. Plaintiff and Defendant are ~ iuris and Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married in Osceola county, Florida in 1991. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant is in the military or naval service of the united States or its allies within the provisions of the Soldiers' & Sailors' civil Relief Act of the congress of 1940 and its amendments. 7. A period of two (2) years has elapsed from the date of separation and Plaintiff's Affidavit of Having Lived Separate and Apart is attached. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. Respectfully submitted, DISSINGBR , DISSINGBR //~~ o2!~ <'~- ... ... Mary 1. Etter Dissinger, Esquire Attorney for plaintiff 28 North 32nd street Camp Hill, PA 17011 717-975-2840 GERALD A. FOGELSANGER, Plaintiff IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. LEIGH R. FOGELSANGER, Defendant NO. 97-5728 I IN DIVORCE CERTIrICATI or SERVICE I, Mary A. Etter Dissinger, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the Defendant, by First Class United states mail addressed as follows: Leigh R. Fogelsanger 11 poplar Lane Newburg, PA 17240 Datel t, It 7/7 ~ /J!u... {'~ a Mary,X. Etter 0 s inger, Esquire SHERIFF'S RETURN - REGULAR CASE NO. 1997-0~728 P CO""ONWEALTH OF PENNSYLVANIA. COUNTY OF CU"BERLAND FOGELSANGER GERALD A VS. FOGELSANGER LEIGH R TREVOR KENT . Sheriff or Deputy Sheriff of CU"BERLAND County, Penn.ylvania, who being duly .worn according to law. .ay., the within NOTICE AND CO"PLAINT IN wa. .erved the upon FOGELSANGER LEIGH R defendant,.t 16.37 HOURS, on the l11h day of Auaust 192a at 11 POPLAR LANE NEWBERG. PA 17240 County, Pennsylvania, by handing a true and atte.ted copy of the together with DIVORCE and .t the .... time directing ~ .ttention to the content. . . CU"BERLAND to LEIGH R. FOGELSANGER NOTICE AND CO"PLAINT IN . . . thereof. Sheriff'. Costs. Docketing Service Affidavit Surcharge So an"?~~1 R. Tho.a. K~lne, ~herl%% 18.00 13.02 .00 6.00 .~7.~~ DISSINGER & 08/12/1998 by DISSI.G~ , ~ /I~ t?L '/ Depu~ 5her Sworn and .ub.cribed to before me IS-- ().. this /;J- day of ~J".r 19 'IV A. D. ".' (-- . ./' Y.. (~~ {iul/;t, .t.Tf(, , TO ono wry' GERALD A. FOGELSANGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. LEIGH R. FOGELSANGER, Defendant NO. 97-5728 IN DIVORCE PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Plaintiff, Gerald A. Fogelsanger, and reinstate the complaint in divorce and the amended complaint. Respectfully Submitted, DISSINGER & DISSINGER Date: 7/~/9JY tJatIA: , Mary . Etter DissInger, Supreme Court 1.0. 277 28 North J2nd Street Camp Hill, PA 17011 717-975-2840 Attorney for Plaintiff ':'~I 1;. .)< )'-" )".'0 .. e ~~ \~ '-rn -/ !'2 dw ~ (1. "j (J .0:":1 , , ,,,,' . ' ,_. "--- S '. - ,,' ,_-'" I . '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Gerald A. Fogelsanger, . NO. 97-5728 . plaintiff CIVIL ACTION - LAW VS. . . IN DIVORCE Leigh R. Fogelsanger, I DEFENDANT I l'~ECIPE TO THE PROTHONOTARY: Please Re-issue the complaint filed in the above captioned matter. Respectfully submitted, ~C~,' .~ H. Anthony Adam~, , u re Attorney for 128 E. King street Shippensburg,PA 17257 (717)-532-3270 '" (") "". . \ ~: 't,: .. :<1 '.. i.- f'"" 1: . ~, :- ) \_)