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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
IRWIN C. CASSELL, SR.,
Plaintiff
NO. 00-6322 CIvlL
VERSUS
MARGARET A. CASSELL,
Defendant
DECREE IN
DIVORCE
AND NOW,
1~o;
atJO I ,IT IS ORDERED AND
.:2./ ~
DECREED THAT
IRWIN C. CASSELL. SR.
, PLAINTIFF,
AND
MARGARET A. CASSELL
, 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;
NONE
BY::; c U~T4 Ii
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~~'jtTHONOT^R'
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IRWIN C. CASSELL, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
00-6322
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please transmit the record, together with the following
information, to the Court for entry of a Divorce Decree.
1. Ground for Divorce: Irretrievable breakdown under Section
330l(c) of the Divorce Code.
2. Date and manner of service of the Complaint: On October 2,
2000 by U.S. Certified Mail. A Certificate of Service has
been filed with the Prothonotary's Office.
3. Date of execution of the Affidavit of Consent required by
Section 330l(c) of the Divorce Code:
by Plaintiff on
January 17, 2001; by Defendant on January 19, 2001.
4. Related claims pending: None. No economic claims have been
raised.5. Date Plaintiff's Waiver of Notice in Section
3301(c) Divorce
was filed with the Prothonotary: January 17, 2001.
Date Defendant's Waiver of Notice in Section 3301(c) Divorce
was filed with the Prothonotary: January 19, 2001.
~ t /-!ii?~
Kint H. Patterson
Attorney for the Plaintiff
221 Pine Street
Harrisburg, PA 17101
(717)238-4100
Dated:
]-116/0 /
,
II
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IRWIN C. CASSELL, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 01)- l. 3 ::L <l-
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
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 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 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, Dauphin County Courthouse, Front &
Market Streets, Harrisburg, Pennsylvania 17101.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE AR 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.
Lawyer Referral Service
Cumberland County Lawyer Referral Service
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
II
,
IRWIN C. CASSELL, SR.,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. t.n) - l., 3:L.z.
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
COMPLAINT
AND NOW comes Plaintiff, by his attorney, Kent H. Patterson,
and files this Complaint in Divorce, based upon the following:
1. Plaintiff Irwin C. Cassel, Sr. is an adult individual
residing at 176 Cedar Lane, Middlesex Township, Carlisle,
Cumberland County, Pennsylvania 17013.
2. Defendant Margaret A. Cassell is an adult individual
residing at RD #2, Box 88, Newport, Perry County, Pennsylvania
17074.
3. Plaintiff and Defendant have been bona fide residents in
the Commonwealth of Pennsylvania for at least six (6) months
previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on March 6, 1991 in
Winchester, Virginia.
5. There have been no prior actions for divorce or annulment
between the parties.
6. Plaintiff and Defendant are both citizens of the United
States of America.
7. Defendant is not a member of the Ar.med Services of the
United States or any of its allies.
II
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8. Plaintiff avers as the grounds on which this action is
based are that the marriage is irretrievably broken.
9. Plaintiff has been advised that counseling is available
and that Plaintiff may have the right to request that the Court
require the parties participate in counseling.
WHEREFORE, Plaintiff requests Your Honorable Court to
enter a Decree in Divorce dissolving the marriage between Plaintiff
and Defendant and such further relief as the Court may determine
equitable and just.
~7?c17~
/.:
Kent H. Patterson
Attorney for Plaintiff
221 Pine Street
Harrisburg, PA 17101
(717) 238-4100
II
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VERIFICATION
I, Irwin C. Cassell, Sr., verify that the statements in the
foregoing Complaint are true and correct to the best of my
knowledge, infor.mation and belief. I understand that false
statements herein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
~A'~J-f/~~.
Irwin C. Cassell, Sr.
~ /-~ '2 (7M:J
Date
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IRWIN C. CASSELL, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6322
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on September 15, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree in divorce after
service of Notice of Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouae and I participate in counseling. Being so advised,
I do not request that my spouse and I participate in counseling
prior to a Decree in Divorce being handed down by the Court.
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. 54904 relating to unsworn
falsification to authorities.
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IRWIN C. CASSELL, SR.
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IRWIN C. CASSELL, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6322
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on September 15, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree in divorce after
service of Notice of Intention to Request Entry of the Decree.
4. I have been advised of the availabili ty of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in counseling. Being so advised,
I do not request that my spouse and I participate in counseling
prior to a Decree in Divorce being handed down by the Court.
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. S4904 relating to unsworn
falsification to authorities.
1 ;/1/01
Date
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MARGAR T A. CASSELL
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IRWIN C. CASSELL, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6322
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. 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 4909 relating to
unsworn falsification to authorities.
~4 /?; ..2 (h') /
Date
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IRWIN C. CASSELL, SR.
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IRWIN C. CASSELL, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6322
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 330l(c) OF THE DIVORCE CODE
1. 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 co the penalties of 18 Pa. C.S. Section 4909 relating to
unsworn t:alsifi.cation to authorities.
/ P9/b/
Date
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MARGAR A. CASSELL
II
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IRWIN C. CASSELL, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00 - 6322
CIVIL
MARGARET A. CASSELL,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
I, Kent H. Patterson, attorney for Plaintiff, hereby
certify that I served Defendant with the Complaint in Divorce on
October 2, 2000 by mailing a copy of same by U.S. Certified Mail,
postage paid, addressed to Defendant as follows:
Margaret A. Cassell
RD # 2, Box 88
Newport, PA 17074
Attached hereto is the sender's receipt and the return
receipt card which is signed by Margaret A. Cassell and indicates
a date of delivery of October 3, 2000.
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Kent H. Patterson
Attorney for Plaintiff
221 Pine Street
Harrisburg, PA 17101
(717) 238-4100
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Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mail See fBVel5e
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Special Delivery Fee
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~ SENDER:
"0 . Complete items 1 and/or 2 for adc;litional services.
en . Complete Items 3, 4a, and 4p.
~ . Print your name and address on the reverse of this form so that we can return this
... card to you.
~ . Attach this. form to the front of the maUplece, or on the back if space does not
CD permit. --
... . Write "Retwn Receipt Requested" on the maUplece betow the article number.
1!_ . The Retum Receipt will show to whom the article was delivered and the date
delivered.
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1. 0 Addressee's Address
2. a Restricted Delivery
Consult postmaster for fee.
4a. Article Number
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