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HomeMy WebLinkAbout99-04531i X ':W':4+. AWN :X. ..:N .W. . ...:, M.. •'F.•..{4• G. W. <*• M. .V} •:1:• :4• iii":•'::SCI{A•:T;?X;:?i:•:?•;:;{?•._:?i -.4w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. STATE OF ?'? wnr r • AMYL. DIEHL _ ...... ....... _ 453'1 c 99 .......... No ......................... ................. 1) versus CHARLES B. DEE" H ?l ?l DECREE IN ?}. VX E 19 it is ordered and AND NOW, ....................... .... , AMY L. DIEHL decreed that .................................................. plaintiff, CHARLES B. DEEL, II .. • . , defendant, and . . . . . . . . . . . . . . . . . . . . . . . . . .... 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 ........................................................................... I Y. Am ............................................................... y 'e 'C A 4tt st: 0 J. othonotary te• +s• :?• ce• •a. •:e• ev> W. t*.:?:• a:• :r,• te• .y: <?: <s• :e• :e• •?:• :?: <c is i i i P i i AMY L. DIEHL, V. IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CHARLES B. DEEL,11, Defendant TO THE PROTHONOTARY: CIVIL DIVISION - LAW NO. 99-453' CIVIL TERM 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) 9-901(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on August 5, 1999 by Acceptance Of Service by Defendant's attorney, Daniel L. Cam, Esquire. 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by the Plaintiff: December 11, 1999; by the Defendant: December 8, 1999. (b) (1) Date of execution of the Plaintiffs Affidavit required by § 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 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, and a copy of which is attached:a < (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by § 3301(c) of the Divorce Code: b laintiff: December 11, 1999; by the Defendant: December 8, 1999. 1 3' i Date: December 21, 1999 omas S. Diehl, Esquire Attorney for Plaintiff . , ?" ?-... .. . r- ! -- (?: ' \ ? ? V c . L?.. ?- C ?' .. . i AMY L DIEHL, Plaintiff V. CHARLES B. DEEL, II, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW :NO. 99 -4531 CIVIL TERM 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 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 or visitation of 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 Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 (717) 249-3166 AMY L. DIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW CHARLES B. DEEL, II, : NO. 99.431 CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, Amy L. Diehl, is an adult individual currently residing at 132 East High Street, Apartment 2, Carlisle, Cumberland County, Pennsylvania, since June 1999. 2. Defendant, Charles B. Deel, 11, is an adult individual currently residing at 265 Denton Drive, Dallastown, York County, Pennsylvania, since December 1998. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The parties were marred on May 16, 1998 in York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage between the parties is irretrievably broken. 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, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant pursuant to 23 P.S. O 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, : - Dated: 07 - / , Zr?l Lam! 1. -Thomas S. Diehl' Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 FaC.S. § 4904, relating to unswom falsifications to authorities AMY L DIEHL -? v- ?J ? _ ? ? ? _ ? ? ? ? J AMY L. DIEIIL. IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW CHARLES B. DEEL, II, NO. 99 -yia/ CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. 1 certify that 1 am authorized to accept service on behalf of the Defendant. Date: Daniel L, am Attorney for the Defendant 96 South George Street Suite 210 York, PA 17401 1 irr?51 CI l ( - l ? _ 1.) AMY L. DIEHL, Plaintiff V. CHARLES B. DEEL, 11, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99-45-N d/93/ CIVILTERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint In Divorce under § 3301(c) of the Divorce Code was filed on July 27, 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. I consent to the entry of a Final Decree of Divorce after service of notice of the intention to request entry of the Decree. I verify that the statements made in this Affidavit 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. Date: A? (.1 1 11 AMY L. DIEHL, : IN THE COURT OF COMMON PLEAS OF Plaintift' : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION - LAW CHARLES B. DEEL, II, :NO. 99 - 4532 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TINDER SEC 3301(c) OF THE DIVORCE COD 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, lawyer's 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 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 to authorities. Date: Z I, 199 AMY , DIEHL L1 CL I ti!' Ci i. yl t L U v. U I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMY L. DIEHL N6.4531 V. CIVIL ACTION - LAW CHARLES B. DEEL, II DIVORCE AFFIDAVIT OF CONSENT LO n r? 1. A complaint in divorce under §3301(c) of the Divorce Code was i o July 27, 1999. 2. The marriage of the plaintiff and defendant is irretrievably broke and:9 ninety (90) days have elapsed from the date of filing and service of the Compla' t. ?- N 3. I consent to the entry of a final decree of divorce after service f notice of intention to request entry of the decree. I verify that the statements made in this affidavit 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 to authorities. ?%& ?6 && -- arles B. Dee], II, Defendant Date: /ala/ 99 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 statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. D ate: JWZ6?& ?oz / $ 9 9 Charles B. Dee], II, Defendant _. [i; ._ ?- ,. ?. -'; ?.: - - ?;_s, - _ ?.- ?. , . , ,_? - - ,. = r? [-? U