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Home My WebLink About99-04228s .Y R'I e ? I Ici- a CV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. x• _KAREN.._5..._CASSATT ........ No . ....99-4228 c ...... ....................... -__..... Piai.n.tif.f............... ii Versus i ALAN J. CASSATT i Defendant ._. .. ,I c i i i DECREE IN I VOR CE AND NOW, ...? 7'Lr........ 14.?o9o, it is ordered and decreed that ..............Karen. S...Cassatt................. plaintiff, and . . . . . . . . . . . . . .. . . . . . . . . Alan. J... Cass.att , • „ • 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; .............None ..................... ?•wu? ,• ..................... B y Attest: J. Prothonotary i i R s i i 4W _ 7.13-[n 6W 7 /3 •DO ?d?ee ??r,?-/ ? ?? KAREN S. CASSATT, Plaintiff V. ALAN J. CASSATT, SR., Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 99-4228 CIVIL TERM : IN DIVORCE Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under § (3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: On July 16, 1999, by Certified Mail, deliver to addressee only, return receipt requested. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code; by Plaintiff: July 1, 2000; by the Defendant: July 1, 2000. 4. Related claims pending: None. 5. Date plaintiff's Waiver of Notice was filed with the Prothonotary: July 5, 2000. Date defendant's Waiver of Notice was filed with the Prothonotary: July 5, 2000. LAW OFFICE OF EDWARD L. SCHORPP Date: Gt/<Y S`o2CE'2? By?? Edward L. Schorpp, Esquire Attorney for Plaintiff > tf) l-' Lij ?? ° U o KAREN S. CASSATT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ALAN J. CASSATT, SR., NO. 99- 4)25' CIVIL TERM Defendant IN DIVORCE NOTICE TO nEF ND Arun Ayxx --- You have been sued ir. 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 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 ground for 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, First Floor, Cumberland County Court House, Carlisle, Pennsylvania 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 NO 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 KAREN S. CASSATT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ALAN J. CASSATT, SR., NO. 99- ?aa CIVIL TERM Defendant IN DIVORCE Plaintiff is Karen S. Cassatt, who currently resides at 328 Whiskey Springs Road, Dillsburg, Cumberland County, Pennsylvania 17019, since July, 1997. 2. Defendant is Alan J. Cassatt, Sr., who currently resides at 20 Pheasant Court, Mechanicsburg, Cumberland County, Pennsylvania 17055, since 1998. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 25, 1989, in The Cumberland Valley Brethren in Christ Church, 1071 York Road, Cumberland County (Dillsburg mailing address), Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. i , , ., CO 1[ VT N ALDM IVY 14. The allegations in Paragraphs 1 through 13 are incorporated herein and made a part hereof. I i. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to support herself through appropriate employment. 16. Plaintiff requires reasonable supporv alimony to adequately maintain herself in accordance with the standard of living established during the marriage. WHF,RF,F()RF„ Plaintiff requests your Honorable Court to enter an award of reasonable temporary alimony until final hearing and permanently thereafter. I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification 10 authorities. Date: 7191917 Karen S. Cassatt I,aw Office of Edward L. Schorpp ante: ?-_C?? -- 9-L--- Edward L. Schorpp Attorney for Plaintiff 3 -4 _ C o e6 P9 0 (7a 00 12 KAREN S. CASSATT, Plaintiff V. ALAN J. CASSATT, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 99-4228 CIVIL TERM IN DIVORCE 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was tiled on July 13,1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. 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, lawyers 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 and waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Dat Karen S. Cassatt, Plaintiff } lit ,r? cv _ _ ?._; ' cV ? _c _)_% .i; r. ., ,. -, i ?. - < ?'. ll) 7 i:','. J ri?u -'=: '? ' L c U , KAREN S. CASSATT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ALAN J. CASSATT, SR., : NO: 99-4228 CIVIL TERM Defendant IN DIVORCE 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 13, 1999. 1 acknowledge receiving a true and correct copy of the Divorce Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on July 16, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 13301 (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, lawyers fees or expenses if I do not claim them before a divorce is granted. 3. 1 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 and waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Dater I AelmfJ. Cassatt, Sr., Defendant v) C?l > _r J :? W d ? ?-? C U KAREN S. CASSATT, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ALAN J. CASSATT, SR., NO. 99-4228 CIVIL TERM Defendant IN DIVORCE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) AND NOW, this ay of ?y?% 1999, I, Edward L. Schorpp, Esquire, attorney for Karen S. Cassatt, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce in the above-captioned matter, with Notice to Defend and Claim Rights, upon Alan J. Cassatt, Sr., the Defendant, at his residence at 20 Pheasant Court, Mechanicsburg, Pennsylvania 17055, by depositing same in the U. S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on July 16, 1999, indicating service was effected, is marked Exhibit "A," attached hereto and made a part hereof. Bycs?// Edward L. Schorpp Attorney for Plaintiff Sworn and subscribed to before me this ??Ih day of t?JT 1999 ?? ,r sly (? nil a" Notary Public Notarial Seal tr?NlM D. Gordon, Notay Pubk Cer9ele Boro, CumbeAarid County M!' Canr"sion expire" June 12.2000 d Exhibit "A ii Q) p ? U KAREN S. CASSATT, Plaintiff V. ALAN J. CASSATT, SR., Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 99-4228 CIVIL TERM IN DIVORCE Please withdraw Counts 11, III, & IV of the Complaint filed in the within action. To CURTIS R. LONG, Prothonotary Date: Sv?Y -5--'-20520 Edward L. Schorpp, Esq. Attorney for Plaintiff 127 West High Street Carlisle, Pennsylvania 17013 (717) 243-9258 r_ .n :! <` < ? ?i ?? . -. ?? i- ?- ? G.. '] J . [ 1 -. T ' } 3. in ..' (n , , u , ' ? .._. , ! _ .?iw -._ - = ?i;? . ? u_ ? `-? Q o U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW KAREN S. CASSATT Plaintiff VS. ALAN J. CASSATT, SR. Defendant File No. 99-4228 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff /Defendant in the above matter, having been granted a Final Decree in Divorce on the 12th day of JULY , k%2000 , hereby elects to resume the prior surname of (KAREN SUE WILEY) Wr..Y , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: JULY 21, 2000 Signature lt, CtI ?.?? ec, Signature of name being r sumed COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND y? On the A_ day of before me, a Notary Public, personally appe red the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal., NOTARIAL SEAL TRICIA MARIE DUNKLE, Notary p?pp? Qar??Oo?. C3unbarluW Counry f0 YOM r Notary Public _.. ... __ ,:? ,-. - ???: _;