HomeMy WebLinkAbout00-07184
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STPTE OF
PENNA.
C:nnn;p Wp;gpl
Plaintiff
No. 00 7184
VERSUS
Rodney L. Weiqel
Defendant
DECREE IN
DIVORCE
AND NOW,
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DECREED THAT
l'nnni j::>. lAlp; I)t:>l
, PLAINTIFF,
AND
Rn~npy To. Wpig~l
, 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
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By THE COURT: /
4'JL..
J.
P THONOTARY
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CONNIE WEIGEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00- 7184 CIVIL TERM
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 ~ 330l(d)(I) of the Divorce Code.
2. Date and manner of service of the Complaint: The Complaint was served on October
19th, 2000 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid.
3(b).
(1) Date of execution of the affidavit required by ~ 3301(d) of the Divorce Code:
September 2,2001.
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
Date of filing: September 12, 2001. Date of service: September 12, 2001.
4. Related claims pending: None.
5(a). Date and manner of service of the notice of intention to file praecipe a copy of which
is attached: May 16, 2003, first class mail.
J, ~AtrtJ&Ja.
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Attorney for Plaintiff
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ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243 2968
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CONNIE WEIGEL
PLAINTIFF
v.
RODNEY L. WEIGEL
DEFENDANT
IN TIIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-7184 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 20th day of October, 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberlaud Couuty Courthouse, Carlisle on the ~ day of December ,2000, at -.!Q.:30 a.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present.at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR TIIE COURT,
By: Isl
Hubert X. GilrQJI. Esqlf
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites 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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY 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, Permsylvania 17013
Telephone (717) 249-3166
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CONNIE WEIGEL,
Plaintiff
v,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
: NO, 00- 7/~1/ CIVIL TERM
RODNEY L. WEIGEL,
Defendant
ORDER OF COURT
AND NOW, . upon consideration of the
attached complaint, it is hereby directed that the parties and their respective counsel appear before
,the conciliator, at on the
day of 2000, at _ m., for a Pre-Hearing Custody Conference. At
such conference, an effort will be made to resolve the issues in dispute; or if this cannot be
accomplished, to defme and narrow the issues to be heard by the Court, and to enter a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the
conference may provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By:
Custody Conciliator
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 andreasonable
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.
YOU SHOULD TAKE TillS 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 17013
(717) 249-3166
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CONNIE WEIGEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CNIL ACTION - LAW
: IN DNORCE AND CUSTODY
v.
: NO. 00-
CNIL TERM
RODNEY L. WEIGEL,
Defendant
ORDER OF COURT
You, Rodney L. Weigel, defendant, have been suedin courtto obtain custody of the children:
Melinda Sue Weigel, born October 12, 1993; Jesse Lee Weigel, born December 2, 1994; and Melissa
Sue Weigel, born June 13, 1996,
You are ordered to appear in person at
. at . ~m" for
. on
a conciliation or mediation conference,
a pretrial conference,
a hearing before the court.
If you fail to appear as provided by this order, an order for custody, partial custody or
visitation may be entered against you or the court may issue a warrant for your arrest.
YOU SHOULD TAKE TillS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO NOT HAVE
ALA WYER 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 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
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 andreasonable
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.
BY THE COURT,
Date:
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CONNIE WEIGEL,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DNORCE AND CUSTODY
: NO. 00- 7J1" Y CNIL TERM
RODNEY L. WEIGEL,
Defendant
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.
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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 HA VB 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, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
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 hearmg.
CONNIE WEIGEL,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00-7 If''!
CIVIL TERM
COMPLAINT FOR DIVORCE AND CUSTODY
The plaintiff, Connie Weigel, by her attorneys, the Family Law Clinic, sets forth the
following cause of action:
Count I
DIVORCE UNDER 23 Pa.C.S. llll 330Hc) and 330Hd) OF THE DIVORCE CODE
1. Plaintiff is Connie Weigel, who currently resides at 104 Locust Lane,
Mechanicsburg, Pennsylvania, 17055.
2. Defendant is Rodney L. Weigel, who currently resides at 98 Regency South,
Carlisle, Pennsylvania 17013..
3. Plaintiff has been a bona fide resident of Cumberland County and the
Commonwealth for at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on July 9, 1988 in Carlisle, Pennsylvania.
5. Plaintiff and defendant have lived separate and apart since September 15, 1999.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and that plaintiff or defendant
may have the right to request that the court require the parties to participate in counseling.
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WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the
marnage.
COUNT II
CUSTODY
9. Plaintiff repeats and realleges paragraphs one through eight.
10. Plaintiff seeks custody of the following children:
Name Present Residence Date of Birth
Melinda Sue Weigel 104 Locust Lane 10/12/93
Mechanicsburg, 17055
Jesse Lee Weigel 104 Locust Lane 12/2/94
Mechanicsburg, 17055
Melissa Sue Weigel 104 Locust Lane 6/13/96
Mechanicsburg, 17055
11. Both the Plaintiff and the Defendant are the biological parents of the children.
12. The children are presently in the custody of the Plaintiff who resides at 104 Locust
Lane, Mechanicsburg, Pennsylvania, 17055.
13. During the past five years, the children have resided with the following persons
and at the following addresses:
Persons Address Dates
Mother, grandmother, 104 Locust Lane 3/00-present
grandfather, Jeremy(half-brother) Mechanicsburg, PA 17055
Mother 124 Willow Drive 9/15/99-3/00
Shippensburg, PA
MotheI, Father 124 Willow Drive 4/99-9/15/99
Shippensburg, PA
Mother, Father 124 Woods Drive 10/93-4/99
Mechanicsburg
The mother of the children is Connie Weigel, currently residing at 104 Locust
Lane, Mechanicsburg, Pennsylvania, 17055.
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Plaintiff is currently married to the Defendant.
The father of the children is Rodney L. Weigel, currently resides at 98 Regency
South, Carlisle, Pennsylvania, 17013.
Defendant is currently married to the Plaintiff.
14. The relationship of the plaintiff to the children is that of mother. The Plaintiff
resides with the following persons:
Name
Kenneth Calaman
Mildred Calaman
Melinda Sue Weigel
Jesse Lee Weigel
Melissa Sue Weigel
Jeremy Thomas Calaman Trayer
Relationship
Father
Mother
Daughter
Son
Daughter
Son
15. The relationship of the Defendant to the children is that of father. The Defendant
currently resides with the following persons:
Mary
Relationship
Girlfriend
Name
16. Plaintiff has not participated as a party or a witness, or in any other capacity, in
other litigation concerning the children in this or another court.
Plaintiff has no information of a custody proceeding concerning the pending in a
court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to the
children.
17. The best interest and permanent welfare of the children will be served by granting
the relief requested because:
a) Plaintiff has been the primary caretaker of the children since birth;
b) Plaintiff provides the children with a stable environment;
c) Plaintiff continues to exercise parental duties and enjoys the love and affection
of the children.
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18. Each parent whose parental rights to the children have not been terminated and the
person who has physical custody of the children have been named as parties to this action.
WHEREFORE, Plaintiff requests this Court to grant her primary physical custody of
the children, subject to partial custody as the parties may agree to in the future, and other such
relief as the deems just.
Date ID/J':J.fO[)
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THOMAS M. PLACE
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
VERIFICATION
Understanding that the making of any false statement would subject her to the penalties
of 18 Pa. C.S. ~4904, the undersigned verifies that the statements made in the foregoing
Complaint are true and correct, to the best of her knowledge, information and belief.
CCAA~ rvJ~~
Connie Weigel
Plaintiff
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CONNIE WEIGEL,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
RODNEY L. WEIGEL,
Defendant
NO. 00- '7/~'I CIVIL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
To the Prothonotary:
Kindly allow Connie Weigel, Plaintiff, to proceed in forma pauperis.
I, Jaime L. Jablonski, of the Family Law Clinic, Certified Legal Intern for the party
proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that
I am providing free legal service to the party. The party's affidavit showing inability to pay the
costs of litigation is attached hereto.
Date: In I n I ()()
I I
e L. Jab osnki
rtified Legal In rn
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ROBERT E. RAINS
THOMAS M. PLACE
TERI HENNING
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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CONNIE WEIGEL,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
RODNEY L. WEIGEL,
Defendant
: NO. 00- 71fl'/ CIVIL TERM
AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
I. I am the plaintiff in the above matter and because of my financial condition am
unable to pay the fees and costs of prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to
pay the costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and
costs is true and correct.
(a) Name: Connie Weigel
Address: 104 Locust Lane, Mechanicsburg, PA 17055
Social Security No.: 202580436
(b) Employment
If you are presently employed, state
Employer:
Address:
Salary or wages per month:
Type of work:
If you are presently unemployed, state
Date of last employment: September 1993
Salary or wages per month: $774.00/month ($4.50/hour 40 hrs/week)
Type of work: packer/laborer
(c) Other income within the past twelve months
Business or profession: None.
Other self-employment: None.
Interest: None.
Dividends: None.
Pension and annuities: None.
Social security benefits: None.
Support payments: $138.00/month($60.00 every two weeks) The last check that
the Plaintiff received was for $34.00 instead of $69.00.
Disability payments: None.
Unemployment compensation and supplemental benefits: None.
Workman's compensation: None.
Public Assistance:
Medical Assistance by Access
Food Stamps: $350.00/month
Other:
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(d) Other contributions to household support
(Wife)(Husband) Name:
If your (wife)(husband) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children: None.
Contributions from parents: Plaintiff's parents allow her to use their car, help pay
for the children's school pictures and activities, and allow her and the
children to live in their home.
Other contributions: None.
(e) Property owned
Cash: $5.00
Checking account: $6.00
Savings account: None.
Certificates of deposit: None.
Real estate (including home):None.
Motor vehicle: None.
Stocks; bonds: None.
Other: None.
(t) Debts and obligations
Mortgage: None.
Rent: None.
Loans: None.
Other:
Electric $400.00 (from previous residence)
Phone $240.00 (from previous residence)
Food: $30.00/month
Dental bill $20.00/month (total amount owed is $500.00)
Holy Spirit Hospital $5.00/month (total amount still owed is $50.00)
FingerHut $ 100. OO/month (has not been paying)
(g) Persons dependent upon you for support
(Wife)(Husband) Name:
Children, if any:
Name: Age:
Melinda Sue Weigel 6
Jesse Lee Weigel 5
Melissa Sue Weigel 4
Jeremy Thomas Calaman Trayer 6 weeks
Other persons: None.
Name:
Relationship:
4. I understand that I have a continuing obligation to inform the court of improvement
in my fmancial circumstances which would permit me to pay the costs incurIed herein.
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5. 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. ~4904, relating to
unsworn falsification to authorities.
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Connie Weigel
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CONNIE WEIGEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY 1. WEIGEL,
Defendant
: NO. 00-7184
CIVIL TERM
CERTIFICATE OF SERVICE
I, Jaime 1. Jablonski, Certified Legal Intern, Family Law Clinic, hereby certify that! servED
a true and correct copy of the Divorce Complaint with a Custody Count on Rodney 1. Weigel,
residing at 98 Regency South, Carlisle, P A 17013 by U.S. mail, certified, restricted delivery, return
receipt requested, postage prepaid. Service was complete upon receipt by Rodney 1. Weigel on the
1'1t:.Vl day of Gf':\-t:>t'lO))
, 2000, as evidenced by his signature on the attached
green card.
e 1. Jablonski
rtified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, P A 17013
717-243-2968
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CONNIE WEIGEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00- 7184 CIVIL TERM
NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE
TO: Rodney L. Weigel, by and through his counsel ofrecord, Jacqueline M. Verney, Esq.
Plaintiff intends to file with the court a Praceipe to Transmit Record on or after June 6,
2003 requesting that a fmal decree in divorce be entered.
Date: May 16, 2003
~~
Certified Legal Inte
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LUCY JOHNSTON-WALSH
ROBERT E. RAINS
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
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CONNIE WEIGEL,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DNORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00-7184 CIVIL TERM
NOTICE TO DEFENDANT
If you wish to deny any of the allegations set forth in this affidavit, you must file a
counteraffidavit within twenty days after this affidavit has been served on you or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 330Hd) OF THE DIVORCE CODE
1. The parties to this action separated September of 1999, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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. ~4904, relating to
unsworn falsification to authorities.
Date t - ;) 11 -o"L
[i em v\,' '1Ju ft
(Connie Weig ) .
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CONNIE S. WEIGEL,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
DOMESTIC RELATIONS SECTION
RODNEY 1. WEIGEL,
Defendant
DOCKET No. 00983 S 1999
PACSES Case No. 256101697
No. 00- '] \ '2>'-\ L. v; \ Toe.." "'"
CERTIFICATE OF SERVICE
I, Nicholas Aloia, of the Family Law Clinic, hereby certify that I am serving on this date a
true and correct copy of Praecipe to Transmit Record and Vital Statistics on Jacqueline M.
Verney, Esquire, 44 South Hanover Street, Carlisle, PA 17013, by placing a copy in the U.S.
Mail, First Class, postage prepaid.
Date: J ~"'C 4 l d.-OO '\
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CONNIE WEIGEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00-7184 CIVIL TERM
CERTIFICATE OF SERVICE
I, Katherine B. Lovette, hereby certify that on this 13th day ofFeburary, 2002, I am
serving a true and correct copy of the Plaintiffs Affidavit Under Section 3301(d) of the Divorce
Code upon Defendant's attorney, Jacqueline M. Verney, Esq. at 44 South; Hanover Street
Carlisle, PA 17013 by fIrst class U.S. Mail.
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Katherine E. Lovette
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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CONNIE WEIGEL,
Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00- 7184 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 9330l(c) of the Divorce Code was filed on October
17,2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a [mal 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. 94904, relating to
unsworn falsification to authorities.
Date 0' Ill/a (
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Connie Weigel, Plaintiff (j
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CONNIE WEIGEL,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00- 7184 CIVIL TERM
CERTIFICATE OF SERVICE
I, Matthew 1. Goodrich, hereby certify that on this 12th day of September 2001, I am
serving a true and correct copy of the Plaintiff s Affidavit of Consent upon Ms. Jacqueline M.
Verney, Esquire by depositing the same in First Class Mail to the following address:
Jacqueline M. Verney, Esquire
44 South Hanover Street
Carlisle, P A 17103
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Date
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Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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CONNIE WEIGEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
v.
RODNEY L WEIGEL,
Defendant
: NO. 00-7184 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(c) AND 3301(d) OF THE DIVORCE CODE
1, I consent to the entry of a [mal 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.CS, 94904 relating to unsworn
falsification to authorities,
Date: 0'7 jlll 0-1
r~~ flAJu-gJ-
Connie Weigel, Plaintiff
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CONNIE WEIGEL,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00- 7184 CIVIL TERM
CERTIFICATE OF SERVICE
I, Matthew 1. Goodrich, hereby certify that on this 12th day of September 2001, I am
serving a true and correct copy of the Plaintifrs Waiver of Notice ofIntetltion to Request Entry
of a Divorce Decree upon Ms. Jacqueline M. Verney, Esquire by depositi;ng the same in First
Class Mail to the following address:
Jacqueline M. Verney, Esquire
44 South Hanover Street
Carlisle, P A 17103
01 1/2./0)
Date
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Matthew . Goodrich
Certified Legal Intern
FAMILY LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
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CONNIE WEIGEL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
RODNEY L. WEIGEL,
Defendant
NO. 2000 -7184 CIVIL
IN CUSTODY
COURT ORDER
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AND NOW, this { day of December, 2000, the Conciliator being advised that the parties have
reached an agreement, the Conciliator releases jurisdiction.
BY THE COURT,
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CONNIE WEIGEL,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CNIL ACTION - LAW
: IN DNORCE AND CUSTODY
RODNEY L. WEIGEL,
Defendant
: NO. 00-7184 CNIL TERM
AGREEMENT AND ORDER AS TO CUSTODY
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THIS AGREEMENT, made this "2-0 day of \,./~~?-'
, 2000, between
Connie Weigel, hereinafter "Mother," and Rodney L. Weigel, hereinafter "Father," concerns the
custody of the children Melinda Sue Weigel, born October 12, 1993; Jesse Lee Weigel, born
December 2, 1994; and Melissa Sue Weigel, born June 13, 1996.
Mother and father desire to enter into an agreement as to the custody of the children. Mother
and father agree to the following:
1. Mother and Father shall have shared legal custody of the children.
2. Mother shall have primary physical custody of the minor children.
3. Father shall have periods of physical custody with the minor children as follows:
A. On alternating weekends from Friday at 6:00p.m. until Sunday at 6:00 p.m.
B. At such other times as agreed upon by the parties.
4. Father shall also have custody of the minor children for two weeks of summer vacation.
Father shall give Mother at least thirty (30) days notipe as to when he intends to exercise these
custodial periods.
5. The following Holiday Schedule shall supersede the regular holiday schedule:
A. Thanksgiving:
On Thanksgiving, Mother shall enjoy the first portion of the day until 3:00 p.m.
and Father shall have physical custody of the children from 3: 00 p.m.
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Thanksgiving Day until 3:00 p.m. the following day.
B. Christmas
In even numbered years, Mother shall have custody of the children
from 1: 00 p.m. Christmas Eve until 1 : 00 p.rn. Christmas Day and Father shall
have custody ofthe children from 1:00 p.m. Christmas Day until 1:00 p.m. the
following day. In odd numbered years, Father shall have custody of the children
from 1:00 p.rn. Christmas Eve until 1:00 p.m. Christmas Day and Mother shall
have custody of the children from 1: 00 p.rn. Christmas Day until 1 :00 p.rn. the
following day.
e. Mother shall have custody of the children on Mother's Day and Father shall have
custody of the children on Father's Day.
D. On other holidays, the parties shall make arrangements for the custody of the
children by agreement.
8. Up to and including December 31,2000, Father shall provide all transportation relating
to his periods of custody. Beginning on January 1, 2001, the parent that is beginning their period
of custody of the minor children shall provide the transportation.
9. Both parties shall keep the other parent informed of their address and telephone numbers
so that the other parent can be reached in times of emergency.
10. Neither party shall do or say anything which may estrange the children from the other
parent, injure the opinion of the children as to the other parent, or hamper the free and natural
development of the children's natural love and respect for the other parent. Both parties shall take
reasonable steps to ensure that third parties having contact with the children comply with this
proVlslOn.
11. The father and the mother will notify the other immediately of medical emergencies
which arise while the children are in that parent's care.
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12, The parties intend to be bound by the terms of this agreement and have this agreement
made an Order of Court
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Connie Weigel, Plaintiff
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cq e1ine M, Vemey
Attorney for Defendant
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L. Jablonski
C, .fied LegaIInt
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T" . M, Place 'J/
Robert E. Rains
Ten L. Henning
SUPERVISING ATTORNEYS
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
ORDER
AND NOW, this -z..?-' dayof 7:>~
. 2000, the foregoing Agreement is
approved and entered as an Order of Court
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