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Home My WebLink About99-04702 h h v li i I 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ; M PENNA. a lk7,, K GARY L. CASSELL, NO. 99-4702 Plaintiff VERSUS PATRICIA J. CASSELL, nofonAnnf DECREE I N DIVORCE AND NOW, ?, IT IS ORDERED AND DECREED THAT Gary L. Cassell PLAINTIFF, AND Patricia J. Cassell ,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; The parties' Property RPtt1Pm n Agreement, dated Octobee 14, 1999, is incorporated herein but not merged. Am& BY THE UR ATTEST: J. ROTHONOTARY •.3• op dell, 7u s1? ?''???7"` I GARY L. CASSELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICIA J. CASSELL, Defendant CIVIL ACTION - LAW NO. 99 - 4702 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: 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) -3301(d)(1)effi Dis,eree a (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Service was made on August 11, 1999, by certified mail, restricted delivery, return receipt requested to the Defendant, Patricia J. Cassell. 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 Plaintiff: January 13, 2000 by Defendant: January 3, 2000 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs 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: (b) Date of plaintiffs Waiver of Notice in §3301 (c) Divorce was signed: January 13, 2000 filed with the Prothonotary: January 18, 2000 Date defendant's Waiver of Notice in §3301 (c) Divorce was signed: January 3, 2000 filed with the Prothonotary: January 6, 2000 ? `7'?=CiC?Cyl ?5 r,n Kristen Goddard nse Esquire GRIFFIE & ASSOCIATES Attorney for Plaintiff U': } iu ... :? GARY L. CASSELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. CIVIL 1999- V?o,) PATRICIA J. CASSELL, 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 GARY L. CASSELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. CIVIL 1999 - '170Z PATRICIA J. CASSELL, Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT Plaintiff is Gary L. Cassell, an adult individual currently residing at 139 Pleasant Grove Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Patricia J. Cassell, an adult individual currently residing at 139 Pleasant Grove Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 26, 1973, in Franklin County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES Kristen Goddar Donsen, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. DATE: _P-3-9?_ GAR CASSELL, Plaintiff C,- t. 1 GARY L. CASSELL, IN THE COUPT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION -LAW PATRICIA J. CASSELL, NO. 99-4702 CIVIL TERM Defendant IN DIVORCE AND NOW, this /6 ?Jday of ?? ?,L 1999, comes Kristen Goddard Donsen, Esquire, attorney for Plaintiff, Gary L. Cassell, and states that the Defendant, Patricia J. Cassell, was served with a true and attested copy of the Complaint in Divorce by certified mail, restricted delivery on August 11, 1999. Respectfully submitted, GRIFFIE & ASSOCIATES AsAtcnHoddar ? btnonsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to??hts /?c;?!hdayof G!'i-_a 44, 1992 J . Notary P is Notarial Seal Robin J. Goshom, Notary Public Carlisle Boro, Cumberland County My Commission Expires Apr. 17, 2603 NEEN Z 013 271 373 US Postal service Receipt for Certified Mail Provided fi - No Insurance Coverage rse Do not use for Intamenonal Mail See reve (U'?5E I l SI IYn c n+ Gr rt Kuuy Sate, LP Code 17G; IGIr fll S11Y" i $ Postage Sao CeNMed Fee ? Spedal Delivery Fee C.'7 c::) •? C? f • (l FAe ' l _ - . p very Resloded De Relum ReceW ?•.? WhomaD PAP O TDTA Sea FBs to 5 _?? m aM posts or ate 3 U. LISPS :o N o. e I also wish to receive the 1 . •Canq•t•sima t rWW2fOr*dd1*XW•nvlaa• and b. •Canplele Mama 3 " of 00 form 00 dW wa an relurnlNa :' following services (for an ): extra fee , PrMm your n•ms ddreaa on tlr raver ; card to Xi-on w the front a thamaMPIM.oronmsback aepaadonnot :A , ft t ? nddreseee'sAddress dDelWer ( ? rrnNl ?? •Wme•R^mR WRKI Wd'onthe mdpaoebelow awaNdarx.Ibw. The Relian Raalpt we Wrowto whom ar make w delivered and aw dale Restrkte y 2.P consult ppetrnaetef for }9e. ddMnd aa. Article Number 11 '1 3. Addressed to: T CG1S5° II ? YiCIGt Alb. e ce 13`? I ???+Sqn ?? vOVC FGGtGI ? Reglslered artMed ress ? Ex ? Insured I p PIS n05b lcSbvt r ? , ? ? COD Q(?tn 7. Date o e ery y 5. Received By. (Pdnt Name) S. Addr 'a ( requested and d S. ignature• assessor of LISPS 8 pS Form 3811, December 102595.97.9-0179 Dome ;Uo etum eCe pt o LLA5 4 r• ? 1 L ? rcl 0 CrN , 0 V !~ ?^ GARY L. CASSELL, Plaintiff V. PATRICIA J. CASSELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 4702 CIVIL TERM IN DIVORCE AFFIDAVIT OE CONSENT A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on August 4, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 intention to request entry of the decree. I VERITY THAT THE STATEMENTS MADE IN THE FOREGOING 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: /- 13 oboa GARY-L. CASSELL, Plaintiff i SEa ZD =? o U GARY L. CASSELL, Plaintiff V. PATRICIA J. CASSELL, Defendant IN THE COURT OF COMMON PL CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 4702 CIVIL TERM IN DIVORCE WAIVER ON NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301 (e) OF THE DIVORCE CODE I consent to the entry of a final decree in 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 divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. 1 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: / i3 fax. L 1? GARY L ASSE L, Plaintiff } w ;•in n o U GARY L. CASSELL, V. Plaintiff PATRICIA J. CASSELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4702 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1999. 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 4, 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of 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 unswom falsification to authorities. Date: January 3. 2000 ??' , ` • &w-LL PATRICIA J. CASS L DEFENDANT \? ?,.. ? ? "J ? - !;` ? ?'? GARY L. CASSELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICIA J. CASSELL, Defendant NO. 99-4702 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301(g) OF THE DIVORCE DE 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. 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 unswom falsification to authorities. Date: January 3, 2000 SILL PATRICIA J. C SELL DEFENDANT ??•=