HomeMy WebLinkAbout99-041755
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COMMON PLEAS
COUNTY
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200.0 , it is ordered and
BRADLEY,E.,MYERS,,,,,,,,,,,,,,,,,,,,,,,,••.••, plaintiff,
VICKIE L. MYERS ......., 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
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................................................
By T rt:
Attest J.
7 Prothonotary
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BRADLEY E. MYERS,
Plaintiff
V.
VICKIE L. MYERS,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4175
CIVIL ACTION - LAW
IN DIVORCE
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: United States Mail, Certified Mail,
Restricted Delivery on duly 14, 1999.
3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce
Code: by Plaintiff: February 25, 2000; by Defendant: February 25, 2000.
4. Related claims pending: No claims pending.
5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with Prothonotary:
February 28, 2000. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with
Prothonotary: February 28, 2000.
Dated: February 25, 2000
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
1
BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-4175
VICKIE L. MYERS, CIVIL ACTION -LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
1, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true
and correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above-
captioned matter upon the following individual by first class mail, postage prepaid, addressed as
follows:
Ms. Vickie L. Myers
662 Salem Road
Etters, PA 17319.
DATED: February 25, 2000
Barbara Sumple-Sullivan, Es
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Plaintiff
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BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 9f- ?fl>5
VICKIE L. MYERS, : CIVIL ACTION - LAW
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RI HT
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 judgement 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 and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Oflicc at the County Courthouse.
II' 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 RAVE 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
BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
VICKIE L. MYERS, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT REGARDING COUNSELING
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.
0 Being so advised, I do not require 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.
Dated: 7-a- 9 9 B&h& ( r
BRA LEY E. MYE S
BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
VICKIE L. MYERS, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Bradley E. Myers, an adult individual residing at 901 16" Street, New
Cumberland, PA 17070.
2. Defendant is Vickie L. Myers, an adult individual residing at 662 Salem Road, Etters,
PA 17319.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on July 17, 1993 in York County,
Pennsylvania.
5. There are no minor children born of this marriage.
6. The parties separated on May 31, 1999.
7. There have been no prior actions for divorce or annulment between the parties.
8. 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.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
COUNT I - DIVORCE
NO FAULT
10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with
§ 3301 of the Pennsylvania Divorce Code.
Dated: July 7, 1999 /
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
2
BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
VICKM L. MYERS, CIVIL ACTION -LAW
Defendant IN DIVORCE
VERIFICATION
I, Bradley E. Myers, hereby certify that the facts set forth in the foregoing COMPLAINT
IN DIVORCE are true and correct to the best of my knowledge, information and belief. I
understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section
4904 relating to unsworn falsification to authorities.
Dated:` ?-J 9 9 ?Anjpen
BRAD EY E. MYE S
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BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-4175
VICKIE L. MYERS, CIVIL ACTION -LAW
Defendant IN DIVORCE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the
Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery,
Certified No. Z 143 612 066, Return Receipt Requested, on the above-named Defendant, Vickie
L. Myers, on July 14, 1999, at Defendant's last known address: 662 Salem Road, Etters, PA
17319. The original receipt and return receipt card are attached hereto as Exhibit "A".
I hereby certify that the facts set forth above are true and correct to the best of my
knowledge, information and belief. I understand that any false statements made herein are subject
to penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities.
Dated: Xlfl?l
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
Z 143 612 066
US Postal Service
Receipt for Certified Mail
No insurance coverate Provided.
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BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-4175
VICKIE L. MYERS, CIVIL ACTION -LAW
Defendant IN DIVORCE
July 8, l 1999. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the filing and service of 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.
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.
5. I verify that the statements made in this affidavit are true and correct. I understand
that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unworn falsification to authorities.
DATE: La5--0n QA,/ (" a/74
BRADLEY E. MERS
BRADLEY E. MYERS,
Plaintiff
V.
VICKIE L. MYERS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 99-4175
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TORO ES
ENTRY OF A DIVOR( E. DECREE uNpEo
§3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of 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.
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. 1 understand that false
statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
DATE: S OO0 S/(,GAb i e. PAl
BRADLEY E. YERS
?_/
BRADLEY E. MYERS, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA
V. NO. 99-41 75
VICKIE L. MYERS, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF C QN ENT
July 8, 1 1 999. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the filing and service of 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.
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.
5. I verify that the statements made in this affidavit are true and correct. 1 understand
that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
DATE: 11
VICKIE L. MYERS
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
) SS.
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared VICKIE L. MYERS, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing AFFIDAVIT OF
CONSENT are true and correct to the best of her knowledge, information and belief
117
subscribed to before me this4o:_ day of February, 2000.
Y
(SEAL)
,,
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BRADLEY E. MYERS,
Plaintiff
V.
VICKIE L. MYERS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 99-4175
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
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 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
statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
DATE: l.P? ?:1a-0 ?7 • I ?
VICKIE L. MYERS t
COMMONWEALTH OF PENNSYLVANIA )
) SS.
COUNTY OF CUMBERLAND )
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared VICKIE L. MYERS, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing WAIVER OF
NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER
§3301(d) OF THE DIVORCE CODE are true and correct to the best of her knowledge.
informati and belief.
/ ; tSff-tu?d?and subscribed to before me this _ day of February, 2000
Mmoww sew....
Y PUBLIC
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amlle,e' arty (SEAL)
16.
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BRADLEY E. MYERS,
PLAINTIFF
V.
VICKIE L. MYERS,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4175 CIVIL TERM
NOTICE OF ELECTION TO RETAKE FORMER NAME
NOTICE IS HEREBY GIVEN that the Defendant in the above matter, having been granted
a Final Decree in Divorce from the bonds of matrimony on March 7, 2000, hereby elects to retake
and hereafter use her previous name of VICKIE LYNNE ALT.
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
VICKIE L. MYERS
t/Azt1 ,?,Fv1'iM O, lJ[t
VICKIE LYNNE LT
SS
On the 3 , r( day of ?Zt t vc P , 2002, before me, the undersigned
officer, a Notary Public, personally appeared Vickie L. Myers, known to me or satisfactorily proven
to be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto s d and notarial seal.
NOTARY PUBLIC
NOTARIAL SEAL
ROBERT PETER KLINE, Nolary Public
New Cumberland Boro., Cumberland Co.
My Commission Expires June 21, 2004
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