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Home My WebLink About97-05790 ..,~ 'll. , ~ u . ~ ~ ..... '1 " ~ ~ l:'o. '<) . I:'-. c::t- ~ tL) d " il I! / '.\ " .~.~,~..~..~.~~.~.~,*~,~,~..~:~.~~'~.~~~~.~~~.~.~-~-'~.~ ~ ~ ~ ~ ~ ~ ~ ~! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. ~ CLARENCE E. FENICLE, .~ j' I~ !~ I~ 1~ ~ ~ ~ ~ 8 8 . a I~ r. ~. . ~! , i ~, 'I ~. ~\ ~ " ~( .,'i ~! ~! ~j "I ~i ~i : I M! " ~; , I ~~ . ! ~I Plaintiff ;\ll. 97-5790 CIYJ!..... Jq~ \'t'f..;II.'( DEBORAH S. Ff.N ICLE Defendant it is ordered and ~ 8 ~ ~ I. !~ i~ (~ I~ I~ I'~ ) : !~ 1~ \~ (~ I: :~ DECREE IN DIVORCE AND NOW. ,.)4"I~".,.",., 199.8,.", .'. ... " ~ ~ ~ ~ ~ ... " decreed that" ' " , ,CLARENCE, .E. . FENICL.E. , , . , ' , , , , ". ,., ,.. " plaintiff, and"."""",., ,DEBORAH, ,s~. ,FEN ICt,E ."",...,,,.",". 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; :a: '" ~ ~ ~ Ii! " None ...... ,.."..' ,.. ,-_.., ...",..". .,...., ;~ I' !~ /.;> I~ )'.' ',.,"",.,"'-;;j:/.,...,.,""",..,' \The. i~ / nrt,..V6r ~; ^tte'::C~dC4' +:!f /':-~/,C~ 'Ki~~JIC. j!, i~k ~ 1/ . V' Prothonotary v' i , ~ .~ ~ ~ ~ ~ ~'.-;."., .,. .... ~..' .z. ,~, .>>> ,>>;. .3t.- ..... .:.;- J. ~ ~ ~ "..i"~ ~ ~ .~..~.*.~,.~.~.~.~..~.~.,~-.~}-~..~'~-*..~.~.~-.~~.*, 'lIS: ~r d-l. dJP/ /la.dY?t d7f~/ ?/r.~r ~ d/ &~ /h~/ Z. .:ttf A..~ (~tA -? 4-~.~) CLARENCE E, FENICLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 97-5790 CIVIL VS, DEBORAH S, FENICLE, Defendant IN DIVORCE 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)) of the Divorce Code. 2. Date and manner of service of the complaint: Mailed to Defendant's attorney, Michael R. Rundle, Esquire on October 21, 1997. Acceptance of Service filed by Attorney Rundle on October 22, 1998 evidencing receipt of Complaint. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by plaintiff July 8, 1998; by defenda~t July 8, 1998. (b) (1) Date of eAecution of the affidavit required by ~ 3301(d) of the Divorce Code: ; (2) Date of filing and service of the plaintiff's affidavit upon the respondent 4. Related claims pending: None 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's waiver of Notice Divorce was filed with the prothonotary: Jul ~ I Date defendant's Waiver was filed with the prothonotary: ~ f '\ 'I (') v'1 (, W n . r._ ~ , "I'! i c~ r;r. i:!1 (" I .rrl , 1 ,,~) , C'j :tS - -n I ~ :!. , ;1. ) 'I II ..' " ! ~;'l '.l " , I,) ~< vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV'ANIA CIVIL ACTION - LAW 97 -S"19D CIVIL IN DIVORCE CLARENCE E. FENICLE, Plaintif f DEBORAH S. FENICLE, Defendant NOTIC. TO DBrBND 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available in the Office of the Prothonotary at 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 Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 CLARENCE E, FENICLE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW I 97-$'7<tQCIVIL IN DIVORCE vs, DEBORAH S. FENICLE, Defendant COMPLAINT UNDER SECTION 3301(0) or 3301(d) OP THB DIVORCB CODB 1. Plaintiff is Cla~ence E. Fenicle, who currently resides at 281 Potato Road, Carlisle, Upper Frankford Township, cumberland County, Pennsylvania 17013, since June, 1995. 2. Defendant is Deborah S. Fenicle, who currently resides at 207 Pine Road, Mt. Holly Springs, South Middleton Township, Cumberland County, Pennsylvania 17065, since August, 1979. 3, Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 30, 1977, in Carlisle, Cumberland County, Pennsylvania. 5. The parties separated in June, 1995. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretriev'ably broken. 8. Plaintiff has been advised of the availability of marriage counselling and that the Plaintiff may have the right to request that the court require the parties to participate in counselling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made . I , , ' , . , ' . . " ,; I .~ , subject to the penalties of 18 Pa, C,S. 54904, relating to unsworn falsification to authorities. l1k,,-u. e. ;rhl'~ Cra~ence g, Fenicle DATE: October 20, 1997 -,..,-~-" By: 203 jl iI I' n ~O n -. "'/1 "' ! , I ':r] ,-, .~1 ~ "'9 .....-<J. .- ,J ,.:J GJ ; , 'P ~ '.() r- ~ ' 1 ,-..c. \.1 ft. f::. .f ,) 3 n ilt ~ .. I ~ ..... ".., ::J -.J 0 "" .'. -...J ""tJ ~ P- - 1- "b ~ ---<. ~ -",. CLARENCE E. FENICLE, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW 97- 5790 CIVIL IN DIVORCE DEBORAH S. FENICLE, Defendant ACCBPTANCB or SBRVICB AND BNTRY or APPBARANCB Dear Sir: Please enter my appearance as attorney for the Defendant, Deborah S. Fenicle. I hereby accept service of a true and correct copy of the Complaint on behalf of my client. I certify that I am authorized to accept service on behalf of the Defendant. TO: LAWRENCE E. WELKER, PROTHONOTARY October LL , 1997 " - ~.~Q'l~ Michael R. Rundle, Esquire FOWLER, ADDAMS & RUNDLE 28 South pitt Street P. O. Box 208 Carlisle, PA 17013 (717) 249-8300 -"It. , " " .~-: n .'., \ ~1 " -';J ,,'" i ." ,'.J I,ll , ,. ....., ('l ,_' ,p _I ...-., J ..\ .,0 1,:'\ r,) ~<' \:: 0.."' \!) i I 1" ;' iit ) , I f-' I i i i vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 97-5790 CIVIL IN DIVORCE I . ! CLARENCE E. FENICLE, Plaintiff DEBORAH S, FENICLE, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 21, 1997. 2. The marriage of plaintiff. and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint, 3. I consent to the entry of a final decree of divorce. 4. 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. DATE: 7-0' , 1998 ~AJAK.I f ~ Clarence E. Fenicle -., Sworn to and subscribed before me this g'f:!:J. day 0 '.1 . 1998. NOTARIAL SEAL 80HNIE L, COVLE, NOTAIlY PUBlIC 10110 OF lIT HOllV SPAl~GS CtJI/Ol:RlAHD co IIV COIII/ISSlGN EXPlIlES oCTOBER 17, 11m ' : () \.() " ~:' ~,) ',I rr:. ".,- ! :'J I, ; ~ . ", - , I >,:'J ,;J .tl~ , .,', ~" " .' ;}J . (~) - -((I ~, ,. " '--j =~ .....) :'J ,-> -, " vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 97-5790 CIVIL IN DIVORCE CLARENCE E. FENICLE, Plaintiff DEBORAH S, FENICLE, Defendant AFFIDAVIT OF CONSENT AND WAIVER OF MARRIAGE COUNSELLING 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 21, 1997. 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final decree of divorce. 4, 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. 5. I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. 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: ::r~~ 8 , 1998 \::\o~ ~,r\~ ~ ~ A (' jQ De orah S. Fenicle Sworn to and subscribed before me this &-' day of .JlAl] , 1998. Iln"'^'-,- X~'-- IIO'lMUAL SfAL BO~NIE L, COYlE, ~OIAnY PUBliC BORO Of t~r HilUY SP~NGS, CUMIlfRWlO CO, MY COMMISSION EXPIRES O(;lOBER 17, 11m () ,'" ('" I' lA' ." ""':"~ I t~ I r, , ..- , , 'oj . ( , ," " ,;:.,J ".,J ~ ,J.') .";::1 '" , ~' I ,I , - , il',l , .1 :.1 :...) ~ 'r; .r, (,.) ...; " r h I i6:1 C) ,() (') ( :':.J 'n - ~.~ ..I ~ : I ,,' ,- 11:-'1 '-.- I, I :!i!J " f;) , '1; - .'C' ;. ~ \1 '\:'j ",C(} ,rn " :~) .,1 ~q .- e ,,' .', .,