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Home My WebLink About00-05924 " w.' , w. " " " " " " w. w. ~ _~"" ,"" .", r, , :Ii'" :Ii"''''''' <Ii"'''':';''' w." w. w. :Ii"'''' '" " w. " w. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY w. w. w. w. STATE OF w. JllIIIelll A. Melr8Dnell, Jv. w. w. w. " w. w. Plaintitr VERSUS w. w. w. aweade1.)1l K. Mel(e!lllell. Defendut w. w. w. w. w. w. w. w. w. AND NOW, w. w. w. w. " " , DECREED THAT James 1\. PENNA. NO. 00 - 5924 CiTil fem DECREE IN DIVORCE tit 1,: t.(t{PJI\; ~( , IT IS ORDERED AND ~ , PLAINTIFF, AND awendctlYl'l K. Megormell, , DEFENDANT, w. ARE DIVORCED FROM THE BONDS OF MATRIMONY. " w. 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; " " " " " " w. w. " " " )Ieillte. . J. ~~~~ROTHONOT^R' w. w. w. w. " " :Ii :Ii :Ii:li :Ii'" :Ii "':Ii "':Ii"" :Ii :Ii"''''''' :Ii :Ii ff. '" '" '" '" Of. Of. :+: " " ~" w. w. " w. " " " " " " " " " " " " " " " " " " " w. " " w. " " " " w. " w. w. " w. w. w. w. " " w. " " " " " " w. " " " w. w. " " " w. w. " " " " " " " " w. " w.. w.' w. " " " " " " " " " " " " " " "'''':Ii''' . /';;StY / :;is'a ., . '. . td L~ /u;A/ -tz;' <4 ~ 7t~ ft1a4/ .zj; df'. , ", .. ,~~_._- ...,." ,,~ '"'-~'''"1'~ , - -~..._~~. " -,._"'~~,.~"., ci - ~~-'>I'" "' ~......,... '-. " L ... JAMES A. MEGONNELL, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00 - 5924 Civil Term GWENDOLYN K. MEGONNELL, : ACTION IN DIVORCE , 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 93301 (c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery. return receipt requested. delivered on: September 1.2000. 3. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: By Plaintiff: By Defendant: January 2, 2001. January 3, 2001. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: January 4, 2001. Respectfully Submitted: Date: \ .- \ 0 - 0 \ J ne Adams, Esquire I . No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff , ~-- 0' ^" - -t:;:', .. JAMES A. MEGONNELL, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : No. 06-5qd~ C(;;J GWENDOLYN K. MEGONNELL, : ACTION IN DNORCE Defendant vs. 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 other rights important to you, including custody or visitation of your children. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THlS 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 FIN!) OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 )i:~' "" . t . .. . JAMES A. MEGONNELL, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. ()()- 5'1 ~ 'I d;zJ -r~ vs. GWENDOLYN K. MEGONNELL, : ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE I. Plaintiff is James A. Megonnell, Jr., an adult individual, who resides at 115 N. Sporting Hill Road, Mechanicsburg, Cumberland County, Pa., 17055. 2. Defendant is Gwendolyn K. Megonnell, an adult individual, who resides at 602 Cherrington Drive, Harrisburg, Dauphin County, Pa., 17111. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 23, 1994 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available aild that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. ,"^". .-"",',," .--. " .. ~ " ,.~...,-~~ -,,-'...... ~-- ~~ , "1 ..It _Jl .~ . 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. ~4904 relating to unsworn falsification to authorities. d M.~~J.P1&""ff ~ Respectfully submitted, Date: B Ida/ OV ~~ I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -"O'''~' ~~ -illlIliJ~lIF~j~~.<-"L"" -~.". -!lrlkW.,;sll;iili'~Ul'~!.hll~;lilljj;;,;;;~l..".IliIM:ill!lIl!IUi!i.fi: ~ - c:::- c;.. (A cO -...J ~ 4) ...0 ~ Iliiiiil!:iI.iliili!iEli!:!:~" ~, -- --- ~ (.. -.....j , YJ~ 218St PJ ~~ - ~ '- );! " . <'-A ..,,~d D .. C;~ --,' C 0 <:~ "'" -0[,6 ~ 92~il ;75 - zr--' l'0 :"8 ~::c; (:;0 /~ r' ~'" ~~Q ~C) -0 ~Q :::1:: ~~~ -0 r;-? L.-rn J>c 0 Z c-< =< l':) 5:5 r,-> -< .. ,,; ~.~ ~ -^ >"- -;--:1 - .... JAMES A. MEGONNELL, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00 - 5924 Civil Term GWENDOLYN K. MEGONNELL, : ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on August 28, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or expenses, if I do not claim them before a divorce is granted. I understand that the statements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: I - d. -Of ~ ORIGINAL James WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Ci33011cl OF THE DIVORCE CODE 1. I consent to 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. 94904 relating to unsworn falsification to authorities. Date: 1 - ;;( -0cI James ~...-~lJ!latM~iiihlf.'~i1hfli~~ ... ! . I fI"" I !J'-" r , \ (,-. ~. "';,-",,: ..J i , Ii ! """,;1 t , , \. " . ."- -.' - - J.il !llil~~'S*"5,i!~,..~, __'__~;li~j~.~".&ti""'lJ!il"",~~Illii..>>!;I'HII1~~"..~'~-"-'" L.dl ,,",b.. ,""',","'~_ ".," M'_~-, ,~. "' ~--~ , ~ ~, Li1ll_i~1lIIIP~""'~ ~ ~ - 0 0 ,~ C ,--" s: 'f -rJ(G rnn, ~~~. ;-[ ~ .r: L ~C,' -'tJ ~8 ---.--,- ,--, "-J . ~'+t Z ~ ::> ).> =< :D --J -< - ~" ~ ,~-'-" -< ~ , - ~'~~ ., ~'';'n < -. '--j"'-~1 ;,. '\ JAMES A. MEGONNELL, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00 - 5924 Civil Term GWENDOLYN K. MEGONNELL, : ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on August 28, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or expenses, if I do not claim them before a divorce is granted. I understand that the stCltements made in this affidavit are true and correct. I also understand that false statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 1- 3 -- 0 \ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301 leI OF THE DIVORCE CODE 1. I consent to 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. !j4904 relating to unsworn falsification to authorities. Date: 1-3-01 ~rI!.ll'!!!&~lcli.,ii;"~'LI"l'J1t rJ ~'"_"'.....' e- '<L'r~~~ti~i~>M..ra-~~~!!ClJi:~_~!iilliiiB!!llilr_r' J&<I-;""'~<i~M!~_U!L t ~ ~~. ~~,~ UII!-&rrlr'" o C LJ~ rn ,~, j~~;; (::C ~~ ...1>..-._ ~~:) ~! <,~ ~ ~lt ~" ~ , o (,-" ' j -'--j c_ .~':;"" -.:.. .~~ ;:, -- r::;; ;:) =0 -< --_1 j!!'; -~ " ~ - , JAMES A. MEGONNELL, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 00 - 5924 Civil Term GWENDOLYN K. MEGONNELL, : ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this September 5, 2000, I, Jane Adams, Esquire, hereby certify that on September 1, 2000, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Gwendolyn Megonnell 602 Cherrington Drive Hanisburg,Pa.17111 DEFENDANT Respectfully Submitted: ane Adams, Esquire I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~_~~~<.ili"_'>'~'~t:<1~'P"jlh~.!i{~~;(I{liffi~ji@[;\1~~tfliI!I~illlilIli8iQ!I\IliIi..l:!all>>l ~ -" ~ .', - ~ ~~ .. [l 2~ l:J,s. CI"') O~jn-. C"1 ==S :;':-,' v ..,.:'_1. ~..::: (~. 55C:. 2G ~O c: =::) 2: ::;2 (). -,~. ,:;:~ , .J ~-~ ~,'?, .< ,~~ " ii , Ii JI I. ii I' i !1 :"-" ',~ (-'::1 . Cb~pi-eie items-'1'~'2~ anti 3. Also -com'pf~te item 4 if Restrlct@;d Delivery is desired. . Print your name and address on the reverse '. s_d that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Ar1icle Addressed to: o Agent Addressee Dyes o No G~~~nd2f ,eoa ~~[)y; ~n.[)'/ " .- - --0 {/A / 7 /I J ,)J6+ +~ I 3. Service Type .~ 0 Express Mail ...- ~ 0 Return ReceIpt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Dellve ? es 2. Article ~u~~er iCOP: ,7~ ~e~i~ Ja~~lji .~.. , ~.. . .tttJ/---L/, .J ,- - ~. ~, 4" I" , I'..... IT,Q/J_ll~rrT'!I_~ .",l.. I... ('" ,_" .,' ;:-, '_' - _"" It. PS Form 3811, July 1999'" , , Do~!icRetum eceipt ,"., 102595.gg.M.'789 . .~ i' ,,- \ )"