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Home My WebLink About01-05308IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY y. STATE OF ~ PENNA. ~ . ~;~ ,- DAVID C. APPLEMAN. Plaintiff VERSUS VIRGINIA M. APPLEMAN, Defendant N o. oI-s3oa DEGREE IN DIVORCE CIVIL TERM JJ~~ zoo Z. AND NOW, (J ~~~~ f j ~~_ , 7. , IT IS ORDERED AND DECREED THAT DAVID C. APPLEMAN AND VIRGINIA .M. APPLEMAN ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, 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 THE COURT / ~~ ATTEST/: ~ n , /1 J. PROTHONOTARY c .i.,µ, A.i ^"t&ia?a~,~e->Ae;._~~c343,'Ya f. J .. , ~, "°s ~~ ,ell DAVID C. APPLEMAN, Plaintiff vs. VIRGINIA M. APPLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 01-5308 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce ree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 Icl• 2. Date and manner of service of the Complaint: Acceatance of Service filed by Plaintiff's 3. Complete either Paragraph la) or Ib): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 18 October 2002 By Defendant: 23 September 2002 Ib) (11 Date of execution of the Affidavit required by Section 3301 Id- of the Divorce Code: 12) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None. 5. Complete either (al or Ibl: la) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (bl Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 18 October 2002, filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 23 September 2002 and filed on 17 October 2002. Date: 2f ~c~'O~/ ?~7Z B S muel L. ndes ttorney for Plaintiff CJ :'_`. ^' l- .. -' - _~ __~ y -4; (\j ~ 5" ,~~e r 1 DAVID C. APPLEMAN, Plaintiff vs. VIRGINIA M. APPLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0. dl-S~oB c.;,~l 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 foregoing 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 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 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 at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 1 DAVID C. APPLEMAN, Plaintiff vs. VIRGINIA M. APPLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. Q~-~3~tj IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. w DAVID C. APPLEMAN, Plaintiff vs. VIRGINIA M. APPLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaihtiff, DAVID C. APPLEMAN, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is DAVID C. APPLEMAN, an adult individual who currently resides at 126 Wagner Street in Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is VIRGINIA M. APPLEMAN, an adult individual who currently resides at 760 South Rose Street, Escondido, California, 92027. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. ~. The Plaintiff and Defendant were married on 26 June 1999 in Mooresburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I -IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. Samu .Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12`h Street Lemoyne, Pa 17043 (7171 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: 9/p.S~O/ ~.~L~ ~a------ _T DAVID C. APPL AN - I :... ~ P~u,rrrx~,~, ,.~s._-~~~ ,..:: :_ :. ._: _ W :. ; _ ~3~Am ~IM'iA'°.~°m.,'° :~ ...:. ,_ ...,.....~ , _ J/~ C G ~~ /~ m'`, -- ;c. C ~ U _l ~ 1 _l^ DAVID C. APPLEMAN, PLAINTIFF vs. VIRGINIA M. APPLEMAN, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 01-5308 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 11 September 2001 and served upon the Defendant on or about 14 September 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date DAVID C. APPLE N __ & I • ~-• I~R,kluam ••.•,",.:•••.a ~d'WBCe%ntr:V~~ri:-'y d~ercn*2E& ^4) 1: ~}~' ~i ' ~r~ _~ .~- ~ En'Nf~,J / r DAVID C. APPLEMAN, PLAINTIFF vs. VIRGINIA M. APPLEMAN, DEFENDANT - IN THE COURT OF COMMON 1 PLEAS OF CUMBERLAND 1 COUNTY, PENNSYLVANIA 1 1 CIVIL ACTION -LAW 1 1 N0. 01-5308 1 - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that 1 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 Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1 g (4C- acra ~. ~ ~ ~~ Date DAVID C. APPLEM <~ ~-:, ~,.~ ~„ r, < _ ~;: ~: ._~ _ _, _ ~,-, ~ =• , _,_ ~~ ~- :: ~: -:~, `? _ ~~ ~= ~S ,~?,~'"~ 09/24/2002 TUE 12:51 FA$ 711 540 1490 SkI17i-YOUNG COPY CENTER I~j002/004 F DAVIb C, APPLEMAN, PLAINTIFF vs. VIRGINIA M. APPLEMAN, DEFENDANT ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ) ) CIVIL ACTION -LAW ) i NO. 01-5308 ) ! iN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 fcl of the Divorce Cade was filed on 11 September 2001 and served upon the Defendant on or about 14 September 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety f9O) days have elapsed from the date Of filing of the Complaint and the date of service of the complaint on the Defendant. 3. 1 consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiuer of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that t may request the Court to require my spouse and 1 to participate in counseling and, being so advised, do nat request that the Court require that my spouse and 1 participate in counseling prior to the divorce becoming final. 1 verify that the statements made in this Affidavit are true and correct and I (' ,! ~,: 11 understand that fa{se statements herein are made subject to the penalties of 18 Pa. C.5. Sectien 4904 relating to unsworn falsification to authorities. Date VIRGI M. APPLEMA~J' 9§~4H{2d11a#,aRVe~tq.saw~~.t~ Bey x=.., h=. a- _ ~,aeexA.rma~&t~l .•• -`~.. r~ .. ~ i ~} ('' .~ (_- tV :7 .{ '~j :'7 ~ .. - „`{ _ - - f. ~' n- i.1' i~ - - tia fSi ~-; ~~h 09/24/2002 TL~E 12:31 FAR 717 590 1430 SNITR-YODNG COPY CENTER (i iI ~, DAVID C. APPLEMAN, PLAINTIFF vs. VIRGINIA M. APPLEMAN, DEFENDANT r~oo3/oa4 IN THE COUfiT OF COMMON PLEAS OF CUM3ERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0. 01.5303 1N DIVORCE WAIVER OF NOTICE OF (NTE1~1 TION TO REQUEST ENTRY OF ~,,D{YOij,CE 6ECR~~UNDER S CT10N 33Q7 ICI OF,IHE DIVORCE COQF 1. I consent to the entry of a final decree in divorce without notice. 2. !understand that i may lose rights concerning alimony, division of properky, lawyer's fees, or expanses if 1 do not claim them before a divorce is granted. 3. l understand that f will not lac 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. verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. U-L ~ ~ ~t ,~~~ pie VIRGI M. APPLEMA 1' i 1~ .; ~`2M-a.sua3ie«sra.Av,.a~s;.;•antam~...s~s ~;.,iwlq~Y t~.rca~..m .<.. ...a a~9~. _., ..•~•.~.:.• ••.. ,. ~ °:`~ `+S ~ 9?F! " ~ _.,g f5 i ~ l _ _ ~.:.: E' L. ti ~ G~~ =; l,_ J _ ~f, ~tJ - _. ~ ~- __ r"G G "~ C}4 r~~ DAVID C. APPLEMAN, PLAINTIFF vs. VIRGINIA M. APPLEMAN, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 01-5308 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I hereby enter my appearance on behalf of the Defendant, Virginia M. Appleman, accept service of the Complaint and acknowledge receipt of a copy of the same. Date: 14 September 2001 Catkin" for Defendant / w .vim...'- ... ~pai`~411~~`:~# x~'»LYib3"533u~'ikE ~.'94+?Wt$12`YNZI. YA".±Y12#1f6'~l^` _... I `_~ .\i +~.~:. 11~~ i~ t~r;. ~ "i K- 5 ;~ .~ "^; `,:~ ti, i ;' =~~C? yr_ f~~ Li~/ ~U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA David C. Appleman Plaintiff v. No. 01-5308 CIVIL ACTION -LAW IN DIVORCE CIVIL TERM Virginia Appleman Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above captioned Divorce Action, hereby elects to retake and hereafter use her previous name of~~ ~ S . This election is made pursuant to the provisions of 54 P.S. 704. - ~ ~ ~ ~~'' `~/ v gna a (m ed am ) 9 I~~~~IiZ~^~~ Si a e (form n e) ~~r ~- Cammomvea',th of County of~,~ ~(y. ss: 2~3 On the ~`L~' day of ~(1~`'~ ,-~eoZ, before a Notary Public. Personally appeared G~NN ~~5~ known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have ~Y OFFICIAL SEAL EDUARDO RU4ALCABA NOTARY PUBLIGCALIFORNIA~ ~ COMM. N0.1369925 SAN DIEGO COUNTY MY COMM. EXP. AUG.13, 2006 my ~ayld and3Votarial Seal. PUbhC ` r- _., v. -; ~ ~ ~~~F ~ } . ~ ~~ g ~, ~,?_. ~ . . _ _ s `~ 0 =C W .~~Tl ~ri ~ ti -. CA b~1