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Home My WebLink About07-14030 IN THE COURT OF COMMON PIERS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA WINGERT, Plaintiff V. KEITH WINGERT, Defendant No. Q -? ` y d 3 c v: I ?t-?rw IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED VV 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 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, One Courthouse Square, 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-8oo-99o-91o8 AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar acci6n con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decisi6n tambi6n ser emitida en su contra por cualquier otra queja o compensaci6n reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania. SI USTF.D NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTE SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A IA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3x66 1-8oo-990-9108 AMERICANS WITH DISABILITIES ACT OF 1490 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 Maryann Murphy, Esquire PMB 246 4902 Carlisle Pike Mechanicsburg, PA 17050 (717) 730-0422 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA WINGERT, Plaintiff V. KEITH WINGERT, Defendant 61,'11 +c.ra? No. 0`7- 1q63 IN DIVORCE COMPLAINT UNDER SECTION 3301k) and 33ol(d) OF THE DIVORCE CODE AND NOW comes MELISSA WINGERT, by and through her attorney, Maryann Murphy, Esquire, who respectfiilly avers as follows: 1. Plaintiff is MELISSA WINGERT who resides at 5003 Inverness Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is KEITH WINGERT who resides at 40o Airy View Road, Sherman Dale, Perry County, Pennsylvania 17090. 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. Plaintiff and Defendant were married on October 31, 2005 in Perry County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between Plaintiff and Defendant. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree dissolving the marriage between the Plaintiff and the Defendant. Respectfully submitted, Maryann urphy, Esquire PMB 246 4902 Carlisle Pike Mechanicsburg, PA 17050 (717) 730-0422 I.D. # 61goo Attorney for Plaintiff AFFIDAVIT I, MELISSA WINGERT, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. 7 Date ME SSA WINGERT 44 3 ti Q b R- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA WINGERT, Plaintiff : NO. 07-1403 Civil Term V IN DIVORCE KEITH WINGERT, Defendant AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on March 14, 2007, I sent the Complaint in Divorce to Defendant, Keith Wingert, by U.S. first class mail, postage prepaid, to the following address: 40o Airy View Road Shermans Dale, PA 17090 3. That on March 17, 2007, Defendant signed an Acceptance of Service which is attached hereto. o? Date A rifli 0 Maryann Murphy Esqui PMB 246 4902 Carlisle Pike Mechanicsburg, PA 17050 (717) 730-0422 I.D. # 61goo Attorney for Plaintiff f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA WINGERT, Plaintiff V. No. 07-1403 Civil Term : IN DIVORCE KEITH WINGERT, Defendant ACCEPTANCE OF SERVICE I, Keith Wingert, Defendant in the above-captioned case, do hereby depose and say that I personally received and accepted service of a true and correct copy of the Complaint in Divorce on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 49o4, relating to unworn falsification to authorities. -? VI [0-7 Date Keith Wingert rr;;!.. a C; t5m N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA. WINGERT, Plaintiff V. No. 07-1403 Civil Term IN DIVORCE KEITH WINGERT, Defendant AFFIDAVIT OF CONSF?NT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 13, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (9o) 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. Section 4904 relating to unworn falsification to authorities. Date MELISSA WINGERT C= Q :. -T7M c-n "? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA WINGERT, Plaintiff V. :No. 07-1403 Civil Term : IN DIVORCE KEITH WINGERT, Defendant AFFIDAVIT (IF CONSENT i. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 13, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (9o) 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.GS. Section 4904 relating to unworn falsification to authorities. ?? 0 7G f Date KEITH WINGERT? C) ? 0 'a -n CT. -' cn - -qrc ' ro Zs CY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELIS SA WINGERT, Plaintiff V. :No. 07-1403 Civil Term : IN DIVORCE KEITH WINGERT, Defendant WAIVER OF NOTICE OF INTENTION TO REOI ENTRY OF A DIVORCE DECREE Y TD SECTION ?g,QAO OF THE DIVORCE CODE i. 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 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 in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of i$ Pa.C.S. Section 4904 relating to unworn falsification to authorities. n Date' ME WINGERT C- G m ZS _? I CD rri GIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW MELISSA WINGERT, Plaintiff : No. 07-1403 Civil Term v • • : IN DIVORCE KEITH WINGERT, Defendant WAIVER QF NOTICE Of MEE NTION TO M.F ENTRY OF A DIVORCE DECREE UNDER SEC'T'ION ?oikl OF THE DIVORCE CODE i. 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 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 in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date KEITH WINGER C ' F r °k C MI cn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MELISSA WINGERT, Plaintiff V. : No. 07-403 Civil Term : IN DIVORCE KEITH WINGERT, Defendant To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: x. Ground for divorce: Irretrievable breakdown under Section .1301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Sent to Defendant on March IA. ?,oQZ by first class U.S. mail a re 'd. The of Service was signed by Defendant on March 17, tom and was filed on March 23„ 2007. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, June 21, 2007: by Defendant, June 22, 200 . (b)(x) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N A. (2) Date of filing and service of the Plaintiffs Affidavit upon Defendant: N A. 4. Related claims pending: There are no outstanding claims. 5. Complete either paragraph (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: N A. (b) Date Plaintiffs Waiver of Notice in Section 33o1(c) Divorce was filed with the Prothonotary: June 26, 2007. Date Defendant's Waiver of Notice in Section 33o1(c) Divorce was filed with the Prothonotary: June 2.6. 2007. %All I J'& Ii, i"U.? . Maryann Murphy, Esquire PMB 246 4902 Carlisle Pike Mechanicsburg, PA 17050 (717) 730-0422 I.D. #619oo Attorney for Plaintiff ? ? S ? _ ? ri : , ?" ? ? --. ..?-. Cf"? :: ? ;_ - "C7 ..{ „r ? ,:.? ' ?,? ? ..,( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Zak STATE OF PENNA. NO. 07_140' Civil To= VERSUS KEITH WINGERTF Defendant DECREE IN DIVORCE AND NOW, '44 /0" 2007 , IT IS ORDERED AND DECREED THAT 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; There are no outstanding claims. PROTHONOTARY /_QIL.f -e Lc= L/ ? r l a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MELISSA WINGERT, I? Plaintiff VERSUS No. 07-1403 Civil Term KEITH WINGERT, Defendant DECREE IN DIVORCE AND NOW, 2007 , IT IS ORDERED AND DECREED THAT MELISSA WINGERT , PLAINTIFF, AND KEITH WINGERT 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; There are no outstanding claims. BY TH /COURT: ATT ?? ° - 4?v -