Loading...
HomeMy WebLinkAbout99-02966 1 1 1 I J f r' F L G v! i Q• i Q? LAURA F. HANDLEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, ENNSVLVANIA VS. : CIVIL ACTION - LAW : NO. 99- CIVIL TERM KEVIN P. HANDLEY, , 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 will proceed without you and a decree in divorce or annulment may 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 or 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, Pennsylvania 17013 (717) 249-3166 LAURA F. HANDLEY, Plaintiff V. KEVIN P. HANDLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99- LouCIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW comes Laura F. Handley, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the fallowing: 1. Plaintiff is Laura F. Handley, an adult individual, currently residing at 1242 Timber View Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Kevin P. Handley, an adult individual, currently residing at 2802 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on November 14, 1987 in Ridgway, Elk County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The 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. Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfidly submitted, 'hl J que a M. Verney, Esquire Supreme Ct. ID. 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff VERIFICATION I verify that the statements made in the within Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsification to authorities. Dated: S// 7M :&aa r. Uo r"J U24c? Laura F. Handley J .lucyueline 11. Vel'fleN' n.1' Ilneis rl lr ',1 • i i.lrl I'.I I I':. I .1 ? • I '.1. .I .. IN RE: TAX SALE OF 1998 UNDER THE REAL ESTATE TAX SALE LAW; PROPERTY OF WILLIAM P. STANTON TAX PARCEL NO.: 05-20-1798-299 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999 - 2962 CERTIFICATE OF SERVICE The undersigned hereby certifies that notice by publication in the above captioned matter, pursuant to Confirmation Nisi dated January 19, 2000, was made by publication once in The Sentinel of Carlisle, Pennsylvania on January 26, 2000, once in The Patriot News of Harrisburg, Pennsylvania on January 25, 2000, and once in the Cumberland Law Journal, of Cumberland County, Pennsylvania, on January 28, 2000, all as evidenced by copies of proofs of publication which together are attached hereto as Exhibit "A." DATED: October 13 , 2000 Ja ob L. Heisey, Director Cumberland County Tax Claim Bureau One South Hanover Street Carlisle, PA 17013 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued In said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Coov of Notice. of. Publication IN RE: NOTICE JUDICIAL SALE IN THE COURT OF COMMON OF1999 UNDER THE. PLEAS, CUMBERLAND -HEAL ESTATE COUNTY, PENNSYLVANIA 'PROPERTYOF DANIEL A. GARONZIK NO.1998.4546 CIVIL TERM TAX PARCEL NO. "23.32.2336.123 PROPERTYOF NO.1998-4547 CIVIL TERM DANIEL A. GARONZIK ; TAX PARCEL NO. 23.32-2338.0128 PROPERTYOF ALFREDSUMMONS NO. 1999.2956 CIVIL TERM AND/OR EMMA BELL SUMMONS TAX PARCEL CO. 06.20-1796.209 PROPERTYOF N0.1999.2962 CIVIL TERM WILLIAM P. STANTON ; TAX PARCEL NO. 06.20.1769.299 NOTICE IS HEREBY GIVEN that the Tex Claim Bureau of Cumberland County; Pennsylvania, has presented its Petition for Confirmation to the Court with respect to Judicial Sales of Real Estate help September 24, 1999 and December 7. 1999, and the some was confirmed Nlsl on January 19, 2000. Said Properties are as followw, 2-2336-123, M1.rHolly Springs Borough, tormnarly owned 23.3Daniel A. Garon,lk; 78 R Mountain Street. land 10.33 acres, parcel no. 23.32-2338. 0128; Mt. Holly Springs Borough, formerly owned by Daniel A. Garonzlk; 414 N. West Street, house a Idl parcel no. 06-20.1796.209, Carlisle Borough, formerly owned by Alfred Summons and/or Emma Belle Summons; 161 W. Locust Avenue, house 1101, parcel no. 05-20-1798-299, Carlisle Borough, formerly owned by William P. Stanton. lsa objections or exceptions are fr6d hereto by any owner, creditor or other interested party by February 18, 2000 with court a decree of absolute confirmation shall be entered as lurse by the Cumberland County Office of the Prothonotary . Jacob I. Holsey, Cumberland County Tax Claim Bureau January 26, 2000 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. i January 26, 2000 Sworn to and subscribed before me this 26th day of January 2000 Notary Public My commission expires: NOTARIAL SEAL SHIRLEY 0. DURNIN, M " iislIt BOrO., Cant rland l n:: ; CDm issiart Erpjrcr, Av THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication ![nder8ct Wo 587 nooro d 11 i Commonwealth of Pennsylvania, County of Dauphin} as Michael Morrow being duly sworn according to law, deposes and says: That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 181h, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday and Metro editions/issues which appeared on the 25th day(s) of January 2000. That neither he nor said Company Is Interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds In and for said County of pauphin?ln Miscellaneous Book "M", Volume 14, Page 317. 1 i PUBLICATION COPY Sworn Noladal Seal Terry L. Russell, IVOtal day A. D. r..euinnasunu pues June 6, 2002 NOTA" PUBLIC N mber,PennsyivanlaASSOCiationct a,?, mission expires June'6, 2002 CUMBERLAND COUNTY TAX CLAIM oUREAU ONE COURTHOUSE SQUARE CARLISLE, PA. 17013 Statement of Adverticiny, r+? To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same $ 178.50 Total Notary Fee(s) $ 1,50 norly owned by Daniel j $ 178,00 root, land 10.33 cc ?lisher's Receipt for Advertising cost 28. Mt. Holy piisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general ao 0 on; rotme y is receipt of the aforesaid notice and mans 0 Scr ono/or Emma publication costs and certifies that the same have ue, house, a lob cartel THE PATRIOT NEWS CO. Ye borough, formerly onhm. By .................. C tr roe calm lame EXMW OAO Miscellaneous Notices '??U li I(?f CCI PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND ?y? 1. X11 (/,?1'!'l(CCf'Yd)l( c Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law. Journal on the following dates, JANUARY 28, 2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 28 day of JANUARY. 2000 tObU E. SWYGEI:, Pbtory %Wc Corlida aom, Cumberland County, PA Mt Coramit%i + Ezpimc W.amh S, 2001 mmlw ow NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania No. 1999-2958 Civil Term IN RE: TAX SALE OF 2998 UNDER THE REAL ESTATE TAX SALE LAW; PROPERTY OF JOHN P. LEISEY AND CAROL A. LEISEY TAX PARCEL NO.: 42-24-0792-085 TO: JOHN P. LEISEY CAROL A. LEISEY FGB REALTYADVISORS, INC. NOTICE: INTENTION TO SELL REAL ESTATE AT JUDICIAL SALE FOR UNPAID REAL ESTATE TAMS TAX PARCEL NUMBER: 42-24-0792-085 497 Lexington Avenue Upper Allen Township Cumberland County, Pennsylvania RULE TO SHOW CAUSE AND NOW, tills 19th day of Janu- ary 2000, upon consideration of the Motion for Second Revised Rule to Show Cause and Motion for Service Pursuant to Special Order of Court by Publication and Regular Mall pur- suant to Pa. R.C.P. 430, a Rule to Show Cause is Issued upon all interested parties to appear and show cause why a decree should not be made that the property (as described in the Petition which began this action) be sold freed and cleared of all tax and municipal claims, hens, mortgages, charges and estates, except sepa- rably taxed ground rents. Rule returnable March 1, 2000 at 1:30 P.M. in Courtroom Number 2, Cumberland County Courthouse, One South Hanover Street, Carlisle. Pennsylvania 17013. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the court. You are warned that if you fall to do so the case may proceed without you and a judgment maybe entered against you without further notice for the relief requested by the Petitioner, Cumberland County Tax Claim Bureau. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IFYOU DO NOT HAVER 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 800.990-9108 NOTICE In the Court of Common Pleas Cumberland County, Pennsylvania IN RE: JUDICIAL SALE OF 1999 UNDER THE REAL ESTATE No. 1998-4546 Civil Term PROPERTY OF DANIELA. GARONZIK TAX PARCEL NO. 23-32-2336-123 No. 1996-4547 Civil Term PROPERTY OF DANIELA. GARONZIK TAX PARCEL NO. 2332-2338-012B No. 1999-2956 Civil Tenn Cumberland Notices 1 FMIW W PROPERTY OF ALFRED SUMMONS AND/OR EMMA BELL SUMMONS TAX PARCEL NO. 06-20.1798.209 No. 1999-2962 Civil Term PROPERTY OF WILLIAM P. STANTON TAX PARCEL NO. 05.20.1798.299 NOTICE IS HEREBY GIVEN that the Tax Claim Bureau of Cumber- land County, Pennsylvania, has pre- sented its Petition for Confirmation to the Court with respect to Judicial Sales of Real Estate held September 24, 1999 and December 7, 1999, and the same was confirmed Nisi on January 19, 2000. Said properties are as follows: 000 E. Orange Street, land ap- prox. 35.5 acres, parcel no. 23-32- 2336-123, Mt. Holly Springs Bor- ough, formerly owned by Daniel A. Garonzik; 79 R Mountain Street, land 10.33 acres, parcel no. 23.32-2338-0128, Mt. Holly Springs Borough, formerly owned by Daniel A. Garonzlk; 414 N. West Street, house & lot, parcel no. 06-20-1798.209, Carlisle Borough, formerly owned by Alfred Summons and/or Emma Belle Sum- mons; 161 W. Locust Avenue, house & lot, parcel no. 05.20-1798-299, Car- lisle Borough. formerly owned by William P. Stanton. Unless objections or exceptions are filed hereto by any owner, ben creditor or other interested party by February 18, 2000 with this court a decree of absolute confirmation shall be entered as of course by the Cum- berland County office of the pro- thonotary. Jacob L. Helsey, Cumberland County Tax Claim Bureau Jan. 28 2 Cumberland Notices EXKW WW \_ .`) ?_ 1 _ f: •". ? ..? J 1 ??_ 1 J