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Home My WebLink About97-05944 ~ ~~ ;' t .. ~~ ~ \, " "t ~ .------"..-- --' - .-..- ,.. -" ~ ~ ~ .. .., ~ ~ t, ~ ~ ~ ~ . 8 ~ ~ ~ 8 8 ~ ~ 8 8 8 . .---,-..--,.-..------......- ,. ~~-~~~~~**~*.~.~.~.~~. ~I 8 ~ ~ ~ 8, ~ ~ ~ ~ ~ w ~ I ~l ~ -~_.~--*-~.~~**.~,~.~..~ ,;+;. .:<<. .;+;. , .;<<. .:<<- ,~ ':<<- .;oc- .:.;. .:eo .... __ ., . .. ....... "..... -'--"'-, 8 8 8 8 8 8 . 8 8 8 8 8 8 8 8 8 I, 8 8 8 8 i~ I~ 8 1 8 8 i: (8 18 I :8 , I" ,., , l)i I' I~ i' " " ." ;:; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF *~ PENNA. STANLEY L. NYE, Plaintiff ;\; 11.97~5944 .......19 V"'I'....;II:.. KATHY D. NYE, Defendant DECREE IN DIVORCE AND NOW, . .~.In~ ~.,. .l.~......,., 19. ,9..." it is ordered and decreed that. . . .. . , , . . . . , .. . S'l'ANLEY . L., .NYEf. , , , . , . .. ". "', plaintiff. and. . . . . . . .. . . . . . . . . . . . . . . . . .K,l\rHY. D.NVE. . . . . , . . . . . , , , , . '. defendant. are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which hove been raised of record in this action for which 0 final order has not yet been entered; "... .NONE.., .... ....... ... ...... ................ 'f Uy Th.. WI' .\. C4 AII...t: U~ J. ~ I~ i" I,,=" Prot honotary M -:.:. -:+;. .:.;. -:.:. .:.:. :.:. :.:. .:.;. .:+;. .;.t;. .:.;. .:.;. .;.t:. STANLEY L. NYE, Plaintiff IN TilE COURT O~' COMMON PLEAS . CUMBERLAND COUNTY. PENNSYLVANIA : VS. . CIVIL DIVISION . KATHY D. NYE, : NO. 97-5944 CIVIL TERM Defendant . . 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(d)(l) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: December 19, Acceptance of Service 1997 by 3. Complete cither paragraph (a) or (bl. (a) Date of execution of the affidavit of consent required by S330l(c) of the Uivorce Code: by plaintiff by defendant (b)(l) Date of execution of the of the Divorce Code: December 19, 1997 service of the plaintiff's affidavit upon 1997 affidavit required by S3301(d) ; (2) Oate of filing and the raspondent: December 19,_ 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of inte~tion to file praecipe to transmit record, a copy of which is attached: December 19, 1997 by personal delivery ____' (b) Date plaintiff's Waiver of Notice in S3301(c) oivorce was filed with the Prothonotary: Date defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: _ ~././I'~/A Attorney for (Plaintiff)(~t) , ; ...... 0; ~'. l'l!;: <1i tt:' (2:- C,' u.." ~. ii::< , OJ. o - - ['::; " !..; "');~'; .-- ~.? , H:~ "... 'ol ~".~ .-, "ite. r.}.~L1. ::'.:'j U .c; co en r-.....\. \).' ... >- ",@':'la: ~I-~< r;m< ~ ~ 1- !~~ ~ ': ':~c. IJ~L: A s1 j ~ l"l - .II. 'Il) PJ-It) '\t-1t- ~1 ~ ,~ t , " ~~ : ~ ( ,. I' I~ , ~~ I, - ". ., , . , STANLBY L. NYB, I IN TRB COURT or COMMON PLa.,S rOR PLAINTIFr I CUMBBRLAND COUNTY, PBNNSYLVANIA I v. I NO. 97- 5"'1-"" CIVIL URN I UTHY D. NYB, I DBrBNDANT I IN DIVORCB 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 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 at the Cumberland County Courthouse, 1 Courthouse Square, First Floor, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S PBES OR EXPBNSES BBPORB A DIVORCB OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IF YOU DO NOT HAVE A LAWYER OR CANNOT APFORD ONE, GO TO OR TELEPHONJ THB OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administr.ator Cumberland County Courthouse 1 Courthouse Square Carlisle, pennsylvania 17013 Phone (717) 240-6200 STANBLY L. NYB, I IN TIB COURT OF COMMON PLBAS FOR PLAINTIFF I CUMBBRLAND COUNTY, PBNNSYLVANIA I NO. 97- S" q "If v. I CIVIL TBRM I ItATRY D, NYB, I DBrBNDJlNT I IN DIVORCB COMPLAINT IN DIVORCE GROUNDS FOR NO-FAULT DIVORCB UNDBR SBCTION 3301(c) or 3301(dl OF DIVORCB CODB 1. Plaintiff is Kathy D. Nye, who currently resides at 14 Fairfield Street, Newville, Cumberland County, Pennsylvania, since December 1, 1995. 2. Defendant is Stanley L. Nye, who currently resides at 113 Spring Farm Circle, Cumberland County, Pennsylvania, since August 1996. C.,<,.,I, 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (61 months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant are citizens of the United States of America. 5. The Plaintiff and Defendant were married on February 18, 1984 in Newville Borough, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 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 counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 9. Neither Plaintiff nor Defendant is in the military or naval service of the United States or ita allieD within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 10. Plaintiff requests the court to enter a decree of divorce. WHERBrORE, Plaintiff respectfully requests that your Honorable Court grant a Decree in Divorce to him, also any other appropriate relief. "71;;/ .' '~I/ v.1 Richard L. Webber, ;fr. Attorney for Plaintiff 366 Green Spring Road P.O. Box 40 Newville, PA 17241-0040 (717) 176-6566 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.A. Section 4904, relating to unsworn falsification to authOrit~~)tA '(/, /~L Date: !o)2o/9J /~ Y.r tI't ~ . STANLEY r/. NYE, -, Plaintiff ;; '. I r> '. ~ ~ . '-~ . ~ '.1 L " , ,. r- t'.'.' ~) u .,,- - ..,. ..... .- ~ 8TANLIY L. NYI, , IN THB COURT or COMMON PLBA8 OF PLAINTIFF , CUMBBRLAND COUNTY, PINN8YLVANIA , V. , NO. 97-5944 CIVIL TBRM , KATHY D. NYB, , DBFINDANT , IN DIVORCB PRABCIPB TO RBIN8TATB COMPLAINT TO THB PROTHONOTARY, Please reinstate the Complaint filed in the above matter. Dated: /)",< " '" r 10 ,'''''' 7 .. 71/// ' . h/IL... Richard L. Webber, r. Attorney for Plaintiff 366 Green Spring Road P.O. Box 40 Newville, PA l724l-0040 (717) 776-6566 " n '.. J-' .. (' , L , L II , ( .J ., , , . L J: l.. , . , ,. C L. ,J ,\ . ,. .. STANLBY L. NYB, I IN THB COURT or COMMON PLBAS FOR PLAINTIFF I CUMBBRLAND COUNTY, PENNSYLVANIA I v. I NO. 97-5944 CIVIL TBRM I ItATHY D. NYB, I DBFENDANT I IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGIITS 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 visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A 1 ist of marriage counselors is avallable in the Office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, First Floor, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMEUT IS GRJ\NTED, 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 Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 phone (717) 240-6200 STANLBY L. NYB, , IN THB COURT OP COMMON PLEAS POR PLAINTIPF , CUMBBRLAND COUNTY, PBNNSYLVANIA , v. I NO. 97-5944 CIVIL TBRM , ItATRY 0, NYB, , DEFBNDANT , IN DIVORCE AMENDED COMPLAINT IN DIVORCE GROUNDS FOR No-rAULT DIVORCE UNDBR SBCTION 3301(c) or 3301(d) OF DIVORCB COOS 1. Plaintiff is Stanley L. Nye, who currently resides Torway Road, Gardners, Cumberland County, Pennsylvania since October 29, 1997. at 740 17324, Z. Defendant is Kathy D. Nye, who currently resides at 14 Fairfield Street, Newville, Cumberland County, Pennsylvania 17241, since December 1, 1995. 3. plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant are citizens of the United States of America. 5. The Plaintiff and Defendant were married on February 18, 1984 in Newville Borough, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 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 par.ticipate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 9. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the 1 verify that the statements made in this Amended Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904. :::::in~ ~ r~O')~}'7i"ti02\i:t;:r1Jy- I ' STANLEY L. NYE, Plaintiff I I r-1 , I , .,j ~~ . '. . . . . tfl l. . I \ , I .- ~ ., :-: ) STANLBY L. NYB I IN THB COURT OF COMMON PLEAS or PLAINTIFF I CUMBBRLAND COUNTY, PBNNSYLVANIA I V. I CIVIL ACTION - LAW I NO. 97-5944 CIVIL TBRM I KATHY D. NYB I DEFENDANT : IN DIVORCE ACCEPTANCE OF SERVICE I, KATHY D. NYE, the Defendant in the above action does hereby accept service of the Complaint in Divorce and Amended Complaint in Divorce. Dated: )?- ~ 19 ~CCI KA~~D, ~p Defend . -; >- C:) (.: 0; ~ .. ~' i .' IJIC' ". ( ,- -;: f~~;_ . .. I#.i el, c.J .! ~:; r,' "j' ~ ., '.Jiu Ll_ ' ..-; ,'-~ , :5 '-'. C~ (j 0' u STANLBY L. NYB, I IN THB COURT OF COMMON PLBAS OF PLAINTIFF I CUMBBRLAND COUNTY, PENNSYLVANIA I V. I NO. 97- 5944 CIVIL TERM I ltATIIY D. NYB, I DBFBNDANT I IN DIVORCB NOTICE or INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECRBE TO: KATHY D. NYE, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the section 3301 (d) affidavit. Therefore, on or after January 9, 1998, 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 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 LAWYBR AT ONCE. IP YOU DO NOT HAVB A LAWYER OR CANNOT APFORD ONE, GO TO OR TELBPHONB THB OFFICB SET FORTH BELOW TO PIND OUT WHERE YOU CAN GET LBGAL HBLP. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA l70l3 phone (717) 240-6200 , .,.. c:> E c::; ~ .'. , ~1..1" 1I1~ f"}~': ()/. ~r: ,'),,:, C;.: ~.. '" :.1. ll.f -' 'J~ ell' ;,: <'-, w.J. [i. ~ ':i~l . ~ : ~:~(l_ j." -, OJ, <:) .:J 0 <.i\ U , STANLEY L. NYE, PLAINTIrr IN THB COURT or COMMON PLEAS or CUMBERLAND COUNTY, PBNNSYLVANIA V. NO. 97-5944 CIVIL TBRM KATHY D. NYB, DEFBNDANT IN DIVORCB DBFBNDANT'S COUNTBR-ArFIDAVIT UNDBR SECTION 3301(d) OF THB DIVORCB CODE I. Check either (a) or (b): -1. (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): -L (a) I do not wish to make any claims for economic relief. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses, if 1 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 underotand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understsnd that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: / 2 - / ']-9 7 :~~. ~Q Defen NOTICI. Ir YOU DO NOT WISH TO OPPOSI THI BHTRY or A DIVORCE DICRII AND YOU DO NOT WIS! TO MAltS ANY CLAIM rOR ICONOIIIC RILl." YOU MIlD NOT FILl THIS COUNTIR ArrIDAVIT. .. .' J ~ 0 >- ii (1--: t.,; "- , ., " ,. , , , . .. C" - Ie, - ....I , I , u.. ll. , ,~ 1 '" II. C":J 'j U C' U