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HomeMy WebLinkAbout01-05369:~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~ ~ Jimmie B. Naugle ~r.: `~ 17558-5093 VERSUS Joan M. Naugle N o . tom _otissA 191-50-2211 DECREE IN DIVORCE AND NOW, 7~.,..e.. L.s' ZAaZ IT IS ORDERED AND DECREED THAT Jimmie B. Naugle AND Joan M. Naugle 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 F'OR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY TH COURT: ~~ ~l ATT T: J• PROTHONOTARY _. f'tibGt4iL'33 GNauz~;6'.?~ Ysee.1Ls4 Vren?`£i~sa.5~a~ffi4Nf ~ .. •. ~~ ~ ~~ ~o b~ i ~6~'~/ . ___ _ ~~ ____..~~ J.! Jimmie B. Naugle SS # 175-58-5093 Plaintiff VS. Joan M. Naugle SS # 191-50-2211 Defendant PRAECIPETOTRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: 2. Irretrievable breakdown under§3301 (c) 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). Date and manner of service of the complaint: becember 19, 2001 - Mutual Consent 3. of the Divorce Code: i (c) of the Divorce Code: 12!19/2001 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: q2l,~~ m~ _ ~rrifAd mail (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: j ~ ~ o -oZ Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 1 _ I ~ - bZ ~~°~~" Attorney for Plain{1ff / Defq danrt t Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §330 by plaintiff 12/19!2001 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION N0.2001-05369 CIVIL TERM by defendant (b) (1) Date of execution of the affidavit required by §3301 (d) "*'Y&3TY~B'Yi-H~ra-akunitu.r~eT~-a~aieteL. y.., a.a - . .. ~.-d~.Y~%Y~kAs~4SB5.K' -'-':~k%,ewa,k~~ ~~NII "`sx~F.>.. .,.:.vs,,. ~,.a.~,~,~za.~~_ _x_--,, r ,.v.r.> .,, a.~ v xr ., ~ .. .., a.., ~.. _...}I Ei,,. r~fp C3 ~ ~_} ...~ _ _ ~~ ~ ~ A y~ ~yy 4~ .e ~ ~ _ ,i l„J ~~CC ' G ~ F' t ~~ ~ ~ ~ `~. ~. ~ ~ C~ ~" ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle . 11A S. Frederick St. . Mechanicsburg/PA/17055 SS# 175-58-5093 . Plaintiff . VS. Joan M. Naugle 129 W. Portland St. Suite 39 Mechanicsburg/PA/17055 SS# 191-50-2211 Defendant No. ~I-.5309 Civi~ 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 praeeed 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 Plaintiff. You may lose money, property or other rights important to you, including the right to demand marriage counseling. IF YOU DO NOT FILE .A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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: Cumberland County Bar Association Lawyer Referral Service 100 South St. Harrisburg, PA 170108 (717) 238- 6715 "COUNSELING NOTICE UNDER Pa.R.C.P. RULE 1920.45(a)*(1 the Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a)(6} Section 3301 (c) Indignities Irretrievable Breakdown Mutual Consent Section 3301(d} Irretrievable Breakdown Two-Year Separation where the court determines that there is a reasonable prospect of reconciliation. A list of qualified professionals is available for inspection in the: FAMILY DIVISION Administrative Court 4th Floor, Cumberland County Courthouse Carlisle, Pennsylvania 17013 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 Plaintiff vs. Joan M. Naugle SS# 191-50-2211 Defendant DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE i. Plaintiff is Jimmie B. Naugle, who currently resides at 114 S. Frederick St., Mechanicsburg, Pennsylvania 17055, at least since 08101/00. 2. Defendant is Joan M. Naugle, who currently resides at 124 W. Portland St. Suite 39, Mechanicsburg, Pennsylvania 17055, at least since 08/01/01. 3. Jimmie B. Naugle has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant-were married on 09/27/91, at Mechanicsburg, PA, County of Cumberland. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is attached. 10. After ninety (90J days have elapsed from the date of filing of this Complaint, plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to X3301 (c) of the Divorce Code. x la~iff (~e) Date: 09/14/01 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 . Plaintiff vs. Joan M. Naugle SS# 191-50-2211 . Defendant VERIFICATION No. I verify that the statements made in this complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PA. C.S., Subsection 4094, relating to unsworn falsification to authorities. ~ ~ ~~~ laintiff DATE: 09/14/01 r. ~.~ c; ~ __ ~ -• ~ , ~ ~ ~- }- ' ~ o <_: < - ~ ~ ~ ~ n y ~ -rs 3 ~ ~ A .i., A ~ xx ~`P . ~ IN FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 Plaintiff vs. Joan M. Naugle SS# 191-a~0-2211 Defendant No. 2001-0536 DIVORCE AFFIDAVIT QE' CCJNSENT 1. A complaint in Divorce under Section 3~01(c} of the Divorce Code was filed on 09/14<01. 2. The marriage of Plaintiff and Defendant is irretrievably broken and. ninety days have elapsed from the date O~ filing a~ tale GQmplai~zt:. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I da 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 made are subject to the penalties of 18 PA C.S. Sec 4904 relating to unsworn falsification to authorities. Plaintiff iz- i9-d~ Dated: ~~~/ ~ 0 SWORN TO AND SUBSCRIBED BEFORE ME THISI~AX OF,~~, w NOTARIAL SEAL ROBERT J. GOLD, NrJ~ary Public Hampden Twp. C+dmherand County firz}' Cci<,mis>;ia.~ ~ x "' ?±4, 20©3 1, _ ~.} s '~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle , SS# 175-58-5093 , Plaintiff vs. No. 2001-05369 Joan M. Naugle DIVORCE SS# 191-50-2211 , Defendant AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code wa.S filed on 09/14/01. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. 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 txue and correct. I understand that false statements herein made are subject to the penalties of l8 PA C,S. Sec 4904 relating tQ ~nsworn falSifiGa~ion to authpritiee, -. ..e.__ a _. A-I -t - u; ;. ,T. ,i ~ __? Dated: ~~i/ 5-~ / SWORN TO AND SI7BSGRIBED BEFORE I~IE THIS~DAY QF 2l _. 00 / ~; ~i'~° NOTARIAL SEAL HampdenTTwpGOC~r~~erl~aod County nsy Cammission Fxpirrs July 10, 2003 ~~ la/~q/o~ .. _ ~. ., r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 Plaintiff . vs. Joan M. Naugle SS# 191-50-2211 Defendant No. 2001-05369 DIVORCE WAIVER OF NOTI OF INTENTION 1. I consent to the entry of a Final Decree of Divorce. 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. Z verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA C.S. Sec 4904 relating to unsworn falsification to authorities. ^/7~ 8~ Date ~' ~ ~~ lalntiff ~~i:s:ra""sN!as#sn'~.v+b,~~t~.c::s:,.'. :sv.v-a,-n._,r.b fie. ,, zf'...~_: as ,~„rs <..:n, ~F'~ v°"`"~«.m~na ~FCS ~ ;.? lam, • V f_~ k ~n~~ ' ] ~ r ~~ r ~~' .~ ~ ^. W f~ %tJ .~Ci _._ y~'~ y .I.J~a ~'::? C J ~ v ~~~ y L ^~ IN THE COURT OF COMMON PLEAS OF CUM$ERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 Plaintiff vs. No. 2001-05369 Joan M. Naugle DIVORCE SS# 191-50-2211 Defendant WAIVER OF NOTICE OF INTENTION 1. I consent to the entry of a Final Decree of Divorce. 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 made are subject to the penalties of 18 PA C.S. Sec 4904 relating to unsworn falsification to authorities. D to efendant c T CJ S y ,~1 ~~,..' an r.A -y y . ~ „CY + ~ MM ~.y~ t_i i~T '~. e. . rr ~~] _ _ ~ 4} ~(."3 .~ ~ G y, K (jy- ~ . 1 • ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 Plaintiff vs. Joan M. Naugle SS# 191-50-2211 Defendant No. 2001-05369 DIVORCE CERTIFICATE OF SERVICE OF DIVORCE - .+~inp~ere Items 1, 2, and 3. Also c~ Pie .ttem 4 if Restricted Delivery Is desired. ' ^. Print your name and address on the reverse so that we can return the card to you. ^~.Attach this card to the back of the mailpiece, 'or on the front if space permits. 1. Article gtltlressed to: J c~>qw /~f ~ ~-C ~ '~~f W. ~2~ 5 ~ul~ `~~ ~L~'~ ~ ^ Agent B. ceivetl by (Printed Name ~ Atldtlsssee n ~ ~ ~~ 1 7 C. Date of Delivery D. Istlellve add - ~ 3 6Z ry ress different m item 17 ^ Yes r~_ ES, enter tlelivery atldress below: ^ No ~~CiS ~EG/7/*+/icS car/t[p- ~ ~Ce[tifietl Mail ~-,~,] Ex'~ress Mail ~ °~~~%teretl ~ ~ ^ Return Receipt for Merchandise ^ InsuredMail aC.O.D. 2, Article Number ~ 4. Restricted Delivery~(Fxrra Feel (Transfer from service / nee - ~ Yes , PsF 7001 2510 0003 5270 8597 omes4c Return Receipt ___.._____..__._--_'_._.~.~_.._.._..,..._.... ~._.._......__.. _ 702595-01- M-2509 ~ Q `a ~ -, , ~ cz ~, z~ <i= 'fT to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 , Plaintiff vs. No.2 Joan M. Naugle DIVORCE SS# 191-50-2211 Defendant -05369 NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT THE RECORD T0: Joan M. Naugle(Opposing Party) Pursuant to Local Rules of Cumberland County please be advised that I plan to file with the Office of the Prothonotary a Praecipe to Transmit the Record with attended documents on /-/l-O,~ Exact copies of the Praecipe and the proposed Final Decree are enclosed herewith. After the Praecipe and proposed Final Decree are filed, you will have a period of ten (10) days during which you may file objections to the entry of the Final Decree based upon this Praecipe. If you dispute any of the information on the Praecipe or the Final Decree, you must act within that ten- day period. Any objections must be filed in writing with the Office of the Prothonotary. If no objections are filed before the expiration of the ten-day period, this case will be submitted to the Court for entry of the Final Decree. ~2-3 t -O f Date of Mailing -- ~J- Plaintiff ;+`e~` - _ ~aixr.~i~'~~~»,'€sb5tsar~ .m~~.ro~ F.~-,.. s ~ a. ~,-s`+ ~.us~+~iidhrPq ~;..a,.,,k '1TIw~h -.. ~: i ~ _ . ~:: ,~ ~ IIl CY: r' _- - _- ~ •l_. , .-.~ ; n _ f ~' ~,~ ` r~ ~( ~.. N ` ' a ~, 1' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle . SS# 175-58-5093 . Plaintiff , vs. No. 2001-05369 Joan M. Naugle SS# 191-50-2211 . Defendant . AFFIDAVIT OF NOTICE Jimmie B. Naugle, Plaintiff, being duly sworn according to law, deposes and says that Jimmie B. Naugle is the Plaintiff in the above captioned matter, that the Plaintiff has sent copies of the Complaint, properly endorsed, in Divorce to Joan M. Naugle of Mechanicsburg, Pennsylvania 17055 (by registered mail, postage prepaid, return receipt requested to 114 S. Frederick St., Mechanicsburg, Pennsylvania 17055, the Defendant's last known address. Plaintiff 191 ~~ SWORN and SUBSCRIBED to before me thisa~~day IIAyCp ' °''ND.e-B,2U02 _. .. _. of//~ea~P~~a-~-c, Hof. Notary Publi k~ , Jimmie B. Naugle SS# 175-58-5093 Plaintiff vs. No. 2001-05369 Joan M. Naugle SS# 191-50-2211 Defendant AFFIDAVIT AS TO SIGNATURE Jimmie B. Naugle, being duly sworn according to law, deposes and says that he is the Plaintiff in the above- captioned divorce; that he is familiar with the signature of the Defendant; and that the signature on the return receipt attached hereto as Exhibit "A" is the signature of the Defendant. Plaintiff iN WITNESS THEREOF, Dated: ~1oO l Sed Fugb ~~ _ I have hereunto set my hand and seal. NOTARY PUBL C :"'~:&S~~P41~F~WS~,?i~kS%atHa~tYddz~s'~M ~:a+t+ rhdr,.~..n x .e,~~3=.ti_?ri~:,°-;e ~ '. ~~xE ~~~~ c~ <_. ~,,, 'u ~- n'+r~"- cx `~, ~~ ~ r -~: ~. =; , 'i Ct ''~: `ti C`s ~C~ b ~7 ;1---- .. -__.--_ . ~~ , , , r~. r ~?r -x--~-~ ~ ~ fi~,s„m. i, 6P~nplet~items 1 2, and 3. Also complete - ~A. eceived by (e/ease Pnnt .. ,..Diem 4 if Restrigted Deliv_e_ry,s desired,, _.,, _ . ~~ ^ Print your name and address on the reverse C. ign tune so that we can return the card to you. - ^ Attach this card to the back of the mailpiece, X or on the front if space permits. D. Is d ivory adtl 1. Article Atldressed to: If S, en ery o lay-v~. ~o~l a v>G{ S-I . 9~i B. D of elive ~-' DI ^ Agem ^ Adtlresst i17 ^Yes ^ No W' ~ / ~ ~ S ~ 3~ ~4~'A ~ ~ q /'~ 1 ~(t //~ Y' {/~ yy~f ` {{ • 1 ert~etl press Mail ~ - ^ Registered ^ Return Receipt~J'or~rchandise ,~l vl ) r/v ^ Insured Mail ^ C.O.D. "v~ J ~ ~ 0 ~~ 4 R td t d D li ? F f F . es c e e very ( x m ee) ^ y~ I z. ArticieNumber . 70p1 114 0004 - (fmnsfer frpmseii~. 7301 7071 . PS Porrn 3811, Mamh 2001 Domestic Return Receipt 102595A7-Ft-1424 ._ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Jimmie B. Naugle SS# 175-58-5093 . Plaintiff Joan M. Naugle DIVORCE SS# 191-50-2211 Defendant AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a Notary Public in and for said County and State, Jimmie B. Naugle, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of his own knowledge that the Defendant Joan M. Naugle herein is not in the military service as defined in the Solders' and Sailors' Relief Act of 1940 and its Amendments thereto, for the following reasons: she lives in Mechanicsburg, and works full time at EDS. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondarily, for a party in the military service. 6 Y~~~ Signature of Plaintif C3 C ' ~~ :~ ~T ~ ~r {'Tf:Y: F°7 ' ~ '. Z U . ~ ~T ~ ~~ ^- -, ~L `~y!} ?. -_{ '~ ~ ~'C ~ C?"~ ~ ~ / C:r C