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Home My WebLink About98-05932 - u ! ~; I '" ::.. I 1,- \ ", !~i , ( ~. - .. .:::1 ... ~ ~ "). ~ '<) ~ ~. ~ 1f -0 4- ~- .,. () 9 (,. , t?) lil rJ '. ~ do @ '" :::> r , -- :.. -..; ~ f.;,'.. ~ , ' :;l eJr. It} ,\9- j Iii' e:;( , C". >-- " , . I L' ,. ... n , C; u' U .0: Z III .0: .0: > ril H H >< <( P. lJl ..... +J U Z ..... l:: E-I Z Z '.-l III Z :J ... 0 ril +J 'tl H ...J g ~ P< l:: l:: .0: w ::t;; - 'M Q) ...:l 0 :Sll'~0': 0 ~~ III ..... P. U >< .0: .... Q) :>;; ~... . E-I H P< ~ 0 0 ...J >~g~ r.. !3 ~ . ...:l U w z ~ 0 I H lJl ril >- Z 0 .a: 0 ril > 0 ril a:a::Oa. E-I U Z 0 Z U Z Ou..o;U) p: 0 Z p: 0 ~ '" " D Cl H . 0 - z 0 Z E-I . .0: > I <.... :J U .0: U ...:l H I- g ...:l .0: lJl 0 Z ril p: .0: ril :J:l ril H lJl ...:l <( E-I !i! ~ ril ~ . l>: Z D H 0 ril :J:l H U U Z E-I U TERESA L. NOEL, Plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW CHARLES A. NOEL, Defendant NO. ('I){("')) 'I ,"hI!') I ') (. ) 'f I., '.' c,> 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 cIaim 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 counseling. 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. Cumberland County Bar Association 2 Liberty Avenue CarliSle, Pennsylvania (717) 249-3166 <<~Zt~,:"/,,.~Y;(4,~,~ Anthony L. eLuca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, PA 17007 TERESA L. NOEL, Plaintiff IN TilE COURT OF' COMMON PLEAS OF' CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. CHARLES A. NOEL, Defendant NO. ((: . ...... '. ~..' \ \ '\ i ' , l " . 1 "' .) , .1" DIVORCE COMPLAINT AND NOW, comes the Plaintiff, TERESA L. NOEL, by her Attorney, Anthony L. DeLuca, Esquire, and seeks to obtain a Decree in Divorce, from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is TERESA L. NOEL, who currently resides at 25 Sheaffer Drive, Carlisle, Cumberland county, Pennsylvania since February 21, 1998. 2. Defendant is CHARLES A. NOEL, who currently resides at 25 Sheaffer Drive, carlisle, Cumberland County, Pennsylvania since February 21, 1998. 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 January 30, 1998 at WinChester, Virginia. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United states or its allies within the provisions of the Soldiers' and Sailors' civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no pr ior actions of divorcc or for annuIment betwecn the parties in this or any other jurisdiction. 7. PIaintiff 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. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, the Plaintiff respectfully requests the Court to enter a decree in divorce pursuant to section 3301 (c) of the Divorce Code. COUNT II REQUEST FOR A FAULT DIVORCE UNDER SECTION 3301 (a) (6) OF THE DIVORCE CODE TERESA L. NOEL, Plaintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. CHARLES A. NOEL, Defendant NO. 98-5932 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under section 3301 (c) of the Divorce Code was filed on October 15, 1998. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of 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. Sec. 4904 relating to unsworn falsification to authorities. Date: ( ~.'?'/)? .z:' Teresa L. L/// // /4t! o 1