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Home My WebLink About01-04163w -` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. w>. m: GERALD L. MANHOLLAN, PLAINTIFF N O. OI - 4163 VERSUS GAIL A. MANHOLLAN. DEFENDANT DECREE IN DIVORCE AND MOW,., 1~V~'P~-~ 31 ~_, IT IS ORDERED AND DECREED THAT GERALD, L. MANHOLLAN ,PLAINTIFF, AND GAIL A. MANHOLLAN _, 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; NORC. ~- ~S i ". , , ~d GERALD L. MANHOLLAN, . Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01-4163 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Certified Mail, on July 9, 2001. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on October 12, 2001 and by Defendant on October 15, 2001. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 4. Related claims pending: None. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Not a~olicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary. October Ld 2001 Date Defendant's Waiver of Notice in Section 3301 (C) Divorce was filed with the Prothonotary. October2y 2001 J C~, Andrew C. Sheely, E quire Attorney for Plaint ff ll O n -L. Jl ~`[ l~..4J I-} ~~~ `J [7. v~ .....{ lm ~ ....p - .A--r 1~ ^i2 - ~i L -~ ~+ ~^~ I ~ G- `o ~ ,T C~ Tr0 ~ :. (.7 (J ~i ~` ~ °° ~~ .A7 ~~ Andrew C. Sheely. Esquire 127 s. Market Street P.O. Hox 95 Mechanicsburg~vPA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW O1 - ~~(a3 CIVIL TERM 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 proceed against you and a decree in 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 with your children. When the grounds 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 the 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 TARE 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 17013 (717) 249-3166 BY ~GY~/ Andrew C. Sheely, Es u re PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew 0. Sheely, Esquire 127 S. Market Street P.O. Bon 95 Mechanicsburg. SPA 17055 PA ID NO. 62169 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW O1 - ~l(,3 CIVIL TERM IN DIVORCE COMPLAYNT 1. Plaintiff is GERALD L. MANHOLLAN, an adult individual who currently resides at 35 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is GAIL A. MANHOLLAN, an adult individual who resides at 21 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 1, 1993 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. Plaintiff avers that he is the innocent and injured spouse, and that the Defendant has offered such indignities to Plaintiff so as to render his condition intolerable and life burdensome. 10. This action is not collusive. 11. The parties separated on December 24, 1998. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Date: July (~ 2001 Respectfully ubmitted, ~C Andrew C. Sheely, squire Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 2 VERIFICATYON I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: July, 2001 er~d~I~1~hF~i~~'l9G~~_ Andrew C. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. GAIL A. MANHOLLAN, Defendant CIVIL ACTION - LAW O1 - IN DIVORCE AFFIDAVIT CIVIL TERM Gerald L. Manhollan, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Ge old L. Manhollan --- ~' NOYARIAL SEAL ANN W. dFtAATIN, Notary Public ~aroksbuerggl8oro, Cumberland . ~ Conaniaslcn E:pir~ Sept. 29, 2~1D3 _ runt ~ntlWC.=•.hts '~*Hq" ~-`aF53Y:d~'tifiSifiY~ C) rn - ~ ( ; v.. '- ( _ ZJ _ ~ ~;__ ,~, _ ~ - ~ - - _ , - , ' ~ ; ~, - .. ~~.5 O ~~ 1 44`.~~ ~ IV e\ t yLC1 ~ ~ M ~ p H C l~ ~a'e Andrew C. Sheely, Esquire „ 127 S. Market Street P.o. Box-~95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01-4163 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that he caused a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon Gail A. Manhollan, by Certified Mail, Restricted Delivery, Return Receipt Requested, as indicated by the attached receipt cards, on July 9, 2001. ANDREW C. SHEELY SWORN to and subscribed before me this IIP'day of July, 2001. ~iL~~hf.I~/ Notary Public My Commission Expires:~e~~{~d9,aJoo,3 t 9,~, _. ^ ComplAte items 1,'2, and'3: Also cat•,phsfdl `- -A. item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. 0., ^ AL'tach this card tP the back of the mailpiece, X oY on the front if Space permits. 1. Article Addressed to: D. GAIL A. MANHOLT,Aiv RESTRICTED DELIVERY FOR ADDRESSEE ONLY ~CSB(,9 21 Lois Lane ~ ~' Mechanicsburg, P 17050 i ,N1.' 9~ ~1~e~~/~~ ^ Addle Is delivery add fferent from item 1? ^ Yes If YES, enter delivery address below: ^ No 'P9Elail ^ Express Mail ® ^ Return Receipt for Merchandise mil ^ C.O.D. Delivery? (Extra Fee) ~] Yes 2. Article Number (Copy /rom service label)' 7099 32200011 0108.2s~m~ PS Form 3811, July 1999 ~ Domestic Return Receipt 702595-00-M-0,9,52 R~ .y Y ~ -.- m PIELB811~G Pp^1>~gdlollan ru ~ ra Poste9e $ 10.57 o ~ ... 0055 0 Certified Fee 1~ • Postmark ~ Retum Receipt Fee Here ~ (Endorsement Required) . ~ fles(dcted Delivery Fee O (EndorsementRequlred) §. 07IOb121)ftl G Total Postage aFees to IU Name (Please Print CleellY) (fo be completed by meller) rn Gail A. Manhollan ~- 8freet, Apt. No.; or PO Box No. it 21 Lois Lane-_.-------------------------------------------------- ~ C(ry, Stets, ZIPt 4_-.--- t` Me Pa 17055 .r trxf . Mechanicsburg Main Post Office MECHANICSBURG, Pennsylvania w/uoi2001 (717~6974g641 03:45:30 PM Product Sales Receipt ---~____ Descri tion Qile Unit Final p y Price Price MECHANICSBURG PA 17050 $0.57 First-Class Return Receipt $1.50 Certified $2.10 Label Serial #: 7D993220001101082342 Issue PVI: $4,17 Total; $4 17 Paid by: Check $4.17 1 liil~ o 'e~•k A i r r-. fl:~' ' i. ~ ;rr !i ~ r_ L; ~. ~ W w vJ N l ~,,~5 e 0 Y 1 ~ ~`~ V~ Andrew C. Sheely, Esquire 127 S. Market Btr2et P.O. Bqx 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697_7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01-4163 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 6, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE • ~O~ 2 / 200 ~ ,/,~! J~C~rfc~i G'~y`~~lG'~ ~-~2y Gerald L. Manhollan Andrew C. Sheely, Esquire 127 5. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01-4163 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER X3303 {C1 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 decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : /`®/i 2/2GE~J ~ ~t~"e."' ~~~ Gerald L. Manhollan -..°a~48SffiiF1°.YR~TkA~ m5X5.~.ak'A vt3 .+~-.E tY 3~. M,€:..wevaY ~ _ _ , s__ ~-e'1~h"8e~"-'a31~1~ 1~ %: ^y -~7.. G ~ N ? .. J /,~ T ., ,, _, ~ ~ ~ ` _ .1 ~ LO :. `j t't~ ° ,~ ~~ f V Andrew C. Sheely, Esquire 127 S. Mar3:et Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01-4163 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 6, 2001. I acknowledge that I received a copy of the divorce complaint on July 9, 2001. 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 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : /~~ ~~ ~ ~ ~ ~~ ail A. Manholl n v ~CSffi9~fi"@YJf~1*.~zat+y&~ a~~F~>.,.. ., vL,u. -..tea ~. _ ~ dif'f'5i f7 0 ~~ O T ._ E _ _ Z~ -I „r? Cam: ~ -;U r rn ;~ j ~ :II 4 ~ s 0 Andrew C. Sheely, Esquire 127 5. Ma.t 7Cet Street P.o. Hox 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-705D (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff vs. GAIL A. MANHOLLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 01-4163 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER X3301 (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 decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : U ` ~.5~- O ~ ~~ ~ ~cLiL.---~_ Gail A. Manhol n ...„~ti~~^abta~.,~ a.~~ez,,.F~., .r ,-.; esa _ .i .., y.~:. s.eu«mxrsi•""-'--- - :, -. •.x~i5k'xdAw3?e~SE ' .'°'w,~"°=` ~ . - .. ~~ C~ ~ ~V7 ~ ~ n7: ri ~ _` za, ~~ °i fV t_, ~ , < I77 l I C: ) r ~ . _C ~ ~~ ' ~ r-l O