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Home My WebLink About03-0992COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NANETTE WAGNER Vo JONATHAN WAGNER COMPL T DIVORCE COMPLAINT UNDER 3301 c OF THE DIVORCE CODE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOU 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NANETTE WAGNER V. JONATHAN WAGNER COMPLAINT IN DIVORCE COMPLAINT UNDER 3301 c OF THE DIVORCE CODE 1. Plaintiff is Nanette Wagner, who currently resides at 329 Fail'view Street, Carlisle, Cumberland County Pennsylvania. 2. Defendant is Jonathan Wagner, who currently resides at 21 Enck Drive, Boiling Springs, Cumberland County Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months previous to filing this Complaint. 4. Plaintiff and Defendant were married on September 29, 2001, Cumberland County Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties excepting the present action. 6. The marriage is irretrievably broken. 7. Plaintiffhas 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. 8. Plaintiff requests the court to enter a decree of divorce. Sup.Ct. # 87702 (717) 880-8243 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. §4904, relating to unswom falsification to authorities. COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERIAND COUNTY NANETTE WAGNER : : v. : 03-992 ; JONATHAN WAGNER : : CERTIFICATE OF SERVICE I, Jeffrey Forrest Boyles, hereby certify that I sent a true and correct copy of the Complaint in Divorce to the Defendant, Jonathan Wagner at 21 Enck Drive, Boiling Springs, via First Class Mail, postage paid. Date: 7__ ..} ~ O-~ ~p.~t_ II)g87702 2114 Plank Road New Freedom, PA 17349 (717) 880-8243 86/88/1992 1~;~ 71723~949§ J 80YL~$ ~ KOL09~ P~ 81 COMMONWEALTH OF PENNSYLV,kN3A COURT OF COMMON PLEAS CUMBERL~qD COUNTY NANETTE WAGNER V. JONATHAN WAGNER COMPLAINT IN DIVORCE 03-99'2 Civil Term ~AVlT OF CON~gNT 1. A Complaint in div~ film ~ ~ys ~ ~ ~om ~e ~c offi~ ~e c~l~. 3. I co~ to ~ ~ ~a fln~ d~ ofd~ ~ ~ of~ of ~on to ~u~ ~ ~&e d~_ I v~ that the srateme~s made in this af~da~ are true ~ correct. ! understand that false statements here~n are made sub, jcct to thc penalties of 18 Pa.C.S. §4904 rehti~ to muwom M~tcatio~t to COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NANETTE WAGNER V. JONATHAN WAGNER 03-992 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of 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 the 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 inthis affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unswom falsification to authorities. Date: Plaintiff 86/88/1~92 1~:4~ 7172~§949~ ~ BOYL~ J KOLOD~ ~A~ 82 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NANE3~rE WAGNER V, $ONATHAN WAGNER COMPLAINT 1N DIVORCE 03-992 Civil Te~m AFIq~AvIT orr CONS~.NT 1. A Complaint in divorce under Section 3301(g) of tl~ Db,~'ee Codm ~1~ fii~ on March 5, 2003. 2. Thc nmrri~e of Plaintiff and D~f~ndm is Lrrmrievably broken and 90 days have elapsed from the date of filing the complaint. 4. I ~on~'nt to the ~nnry of a final decree of divorce at~r ~vvie. e of ~oflc~ of intention to request entry of the deo'ee. I verify that the statmnmits made in this ~mdavit are tm** and correct, I understand that false statements herein are made mbj~ to the penalties of IS P,q..CS. ~4904 relating to ua~wom Falsitication to authoritim. COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NANETTE WAGNER V. JONATHAN WAGNER 03-992 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c} OF THE DIVORCE CODE 1. I consent to the entry of 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 the 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 inthis affidavit are mae and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unswom falsification to authorities. D~l'endant VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. C:~ '1, - ~[~,'Z. CIVIL TERM 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) 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: 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 I Z./O ; by defendant (b) (1) Date of execution 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: 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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: ¢,o / Z/~ Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: ~ / Z /O~ IN THE COURT OF COMMON OFCUMBERLAND COUNTY STATE OF Nanette wagner VERSUS PENNA. NO. 03-992 PLEAS AND NOW, DECREED THAT AND DECREE IN DIVORCE Nanette Wagner Jonathan Wagner ARE DIVORCED FROM THE BONDS OF MATRIMONY. IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A F}NAL ORDER HAS NOT Yet BEEN ENTERED; BY T/,rl~ Co ~,/" ROTH O N OTA R¥