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HomeMy WebLinkAbout00-06322 :t\"';F.;F. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,I,' ~J . .. . . ff.Of. Of.:f. :f. ff.:f. Of. Of. . .. . if. Of. if. Of. Of. if. if.ff. :f. :f.:f.if.if.if. ff.:f. if. if. if. if.:f. 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 J. ~~'jtTHONOT^R' ,.,"''''''' . . . '" "'''':f.iF. iF. "''''ff.iF.'''iF.:f.:f. ,., if. if. if.iF. ;F. I ~, . ~, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . if.if.;!i'" d ',;J~ ,,tV or ~ -tJl L . .".." .~ 1-'["'"'~ t..,.l; "', <,. " M~~~4"~ 'Jf~ ~~ ~. ,_ I . ~1l~_1"'"~'~~~"""1"~""""'"~'~1~~~'~1~"I!1l'I . ~=,. ; ,..~~ .. ,~'''''". .1 ' , -,~ , 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 I~.;"" . 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 'C' ~ '", 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 ~ ", 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 II ~"'~ ,~.-.......:talIW~~~i\li~,rfJH,~>t."i--jr...,-';'...ii<t.k.itci~i<-~fik<,;;'">lW~~- ,,,-,,,",,-, "'-~"" f~ .c ""- ~ 6 ~ "'.I ''''',,~~.". ,. ~<~~w,,><" .~ , ". ,~~~ , ". ~ .-,~~ - ~'- ~.' , I . -~ 0 ,Q 410" .., en --,< ~. 1""1 :r: "T< -u 'f'"'~- .l-F 01 'i,5? ~Cl -0 ~~ ~2 ::g ~: . ca: 0 ~. ~ ~ 50 R .....5' ~ 01 ....... '-I '-J e "\ ~ t' ~ ~ " ," ~. ,. 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. ~:,~n~T ;7, .!lbCI J;.a;V/:V~4 O~fr, IRWIN C. CASSELL, SR. II ..... ~,"'~~IIliIittA;JSI ~" ~~I!iI!iWI;*__''''"~~'!l>fIk~;;oi:~ruolAli.-;H'''',,~~I.w~fllij~C ' ~ ~~~ ""-=",,,,"--, ~.; '.;.....~"k.' ~. =_ i-'~ C) c: U~ 9J[:"; 2t-. ~~:.-- ~8 ~ iIiitii -,- c:} ~~ ." ;"'''1 ,.::.:; u'; ._y' l :0 ~.~) i=-{l ~=-,I 2~ -.<.., -c;: l=- (4\ - . -" .~-,j -.' <'-" 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 r7A~jf~. MARGAR T A. CASSELL II r~ ,~~ - ~~tll!\II!m~-n;~~_~l@i"'.;t"'~~~~~'ll"'~'~'~JlilW~il#~lift~~l!~r- ]u ~~ ...."J,__,~~ .-, _'0' C",,~,~ () c: <~ -uEG 111[!:J, Z__, ~i~ -< ~~~- S!; S~ -:5 -, ~~" C~ 11.\>, (:=: -" r-.] :0'1 :'!..! G"> " \_,~, '::':-i -J:> :IJ -~ c:- O.., " ., ~"~ O'LL 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 ~~/~~~ IRWIN C. CASSELL, SR. II !ilI~ };tilliiil -'~'''-~'''''''''''Jl~.~'<lfl,~~''''~~iilh1.'i. ...J :.;' -'"~ - "" ~,~ "~<" n c' (::-) C "' 1 <:::- ..,., ...,..., ;.-;-~ nlr>: rf'1 Z7} ~T:J . Z ::; ,-,-, S2 Vi , J r::: r::''--, ~) , ~'J :s. ~ ,..; .Y f~; , z -".. c::- )> C :....) . . iT; ~~ ,. >~ -~ \0 :0 -< ,-:,',i , 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 ~~A,~ MARGAR A. CASSELL II ~ ''^'- illiiiUiIIIIiWil/IJM!tT"""'~"""""'~~InW.MIIW'',!l;~",,"~''~"; ,~. O. "".J.l,,,,,o'i ','. ~'.~ (") ~~~ -01',-',' r1"1:-';'; ~_u 01 c: ~s=: j=;C Z :;! Ji1 " C:::J ..." ,""'1 LJ...' "\ c' ;::1 -;.j (-" e:? (:7 \".0 ';;J -< / . . ~,~ .. .. . . 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. ?f/~ Kent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 -~ ~~~- '"""". . t . T p 149 . 800 548 us Postal SeNice Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See fBVel5e t. Certified Fee sy ;Lt6 Special Delivery Fee . ~ 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. c o ~ i 7Y7arfft'JJlLt- Ii. Cass4/ 8 ~DiI c2. Box ff tU-twf~(1t ?A /747'1 3. Article Addressed to: I also wish to receive the following services (for an extra fee): 1. 0 Addressee's Address 2. a Restricted Delivery Consult postmaster for fee. 4a. Article Number / '-I q 00 5 P 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise 7. Date of Delive~ )\ D-J-D(./ 8. Addressee's Address (Only If requ and fee is paid) a) " .;: Iii rn a 'ijj " " a: c ~ " 1Ii 1!J"".m....r 1994 '"-.-.-- ." . ..... ., ." ...,02595-"'.....9 .t>............ .....,.... RMe'\nl' , ' W" 'M (1.,,1 {:-+..t-:;::::'H::".:. .-, J1l1lJtllllffWl'.IWffrt'dnnrHf,HnTn rrdllH ,I ~ >'^,:",""-,, ~~ ~~~ilIiIi'~" - ~ - -<--~- . ~ ~,. ~~~-~ .' " .H r -" . -~, ~, ,~ ~ ~~ ~- o ~ '"1Jt:.J rncp- ~~~, l~C) :}:~C:: L-r', .~-- \-' )~,..- Z --I -<. "~ . c:::" .." ,",-; ~J . ~ 'I i , II :1 II " I 0" '=-,.:' (1"'