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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF PENNA.
SHM
PlaintifYNNE Mt±R[Q I WITZ N t t..9.9-.557.7 ...... .................. 19
............... _.. . ....
__...
Versus
MITCHELL LEE MARKELWITZ
Defendant... ;II
DECREE IN
DIVORCE
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AND ?O ?? .. , it is ordered and
decreed that . SHARr LxNtvE M.ARt?r1TZ ........................... plaintiff,
and .. 9 LEE MM0a1RITZ ................................ 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
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.........................................................
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Attest: ? J.
Prothonotary
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SHARI LYNNE MARKELWITZ,
Plaintiff
V.
MITCHELL LEE MARKELWITZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-5577 CIVIL TERM
CIVIL ACTION - LAW
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) of the Divorce
Code.
2. Date and manner of service of the complaint: Certified mail on xxx, 1998.
3. Date of execution of the Affidavit of Consent required by §3301(c) of the
Divorce Code.
By Plaintiff: December 20, 1999 By Defendant: December 20, 1999
4. Related claims pending: None.
5. Date the Waiver of Notice in §3301(c) divorce was filed with the
Prothonotary:
By Plaintiff: December 20,
Defendant: Dumber 20, 1999
for Plaintiff
01
G ? U
SHARI LYNNE MARKELWITZ,
Plaintiff
V,
MITCHELL LEE MARKELWITZ,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- Ss'7 CIVIL TERM
CIVIL ACTION - LAW
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 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 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, PA 17013
(717) 249-3166
SHARI LYNNE MARKELWITZ,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 99- SS'77 CIVIL TERM
MITCHELL LEE MARKELWITZ, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Shari Lynne Markelwitz, an adult individual, currently residing at
312 4U' Street, West Fairview, Cumberland County, Pennsylvania.
2. Defendant is Mitchell Lee Markelwitz, an adult individual, currently residing
at 312 4t' Street, West Fairview, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are bonafide 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 December 31, 1983 in Dauphin
County, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the
parties.
6. The Defendant is not a member of the Armed Forces of the United States
of America, or its Allies.
7. The 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, the 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 Defendant will, after
ninety days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce.
G 14e??-
Date
Respectfully Submitted
TURO LAW OFFICES
Ro uro, Esquire
32 South Bedford Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and
correct. I understand that false statements herein made are subject to the penalties of
Pa.C.S. §4904 relating to unswom falsification to authorities.
Date / Shari Markelwitz
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SHARI LYNNE MARKELWITZ,
Plaintiff
V.
MITCHELL LEE MARKELWITZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5577 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
September 10, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FC'REGOING 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.
V-;O?
Date
ari Lyn a Markelwitz
SHARI LYNNE MARKELWITZ,
Plaintiff
V.
MITCHELL LEE MARKELWITZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5577 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
4. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
September, 1999.
5. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
6. 1 consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
I VERIFY 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.
Z-z
Date Mitchell Lee Markelwi
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SHARI LYNNE MARKELWITZ,
Plaintiff
V.
MITCHELL LEE MARKELWITZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5577 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final Decree of Divorce without notice.
2. 1 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 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.
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Date
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Shari Ly a Mar el itz
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SHARI LYNNE MARKELWITZ,
Plaintiff
V.
MITCHELL LEE MARKELWITZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5577 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§ 3301(c) OF THE DIVORCE CODE
4. 1 consent to the entry of a final Decree of Divorce without notice.
5. 1 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.
6. 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 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.
/a a o -er r
Date
Mitchell Lee Markelwi
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SHARI LYNNE MARKELWITZ,
Plaintiff
V.
MITCHELL LEE MARKELWITZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5577 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
HEREBY CERTIFY THAT I served a true and correct copy of the Divorce
Complaint filed in the above captioned case upon Mitchell Lee Markelwitz, by certified
mail, return receipt requested on September 13, 1999 addressed to:
Mitchell Lee Markelwitz
312 4t' Street
West Fairview, PA 17025
and did thereafter receive same as evidenced by the attached Post Office receipt card
dated September 28, 1999.
1 VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,
INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN
MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
LAW OFFICES
Date
32 South Bedford Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
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Divorce Complaint
Z 452 476 373
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
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Do not use for Intemational Mail See reverse
Smt to
Mitchell Lee Markelwi
Slmei a Number
Pop Orm, e,8
West Fairview PA
17025
Postage $ .55
Carded Fee 1.40
Spedp Deihwry Fm
Reebkted Worry Fm 1.25
Ratans Receipt Stowing to
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BMeepeelpddan 3.20
TOTAL Po mge 6 Fens $
Pmamnx or Date
September 13,
1999
SENDER: ' Ialec wish to receive the follow
a Campteu pens t an,*i for emww wmm•. Ing services (for an extra tee):
Cam lw1dhW3.4h:ridxb.
Op"A . "ndaddnm on" r"erm of data lam m" we can M="r?w
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OTMRatans flaplpl wa poor to winos meipkcabei wm deWand and the date
t. pAddressee's Address
2. O Restricted Delivery
Mitchell Lee Markelwitz
312 9th Street
WestSFairview, PA 17025
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SHARI LYNNE MARKELWITZ,
Plaintiff
V.
MITCHELL LEE MARKELWITZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5577 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
NOTICE IS HEREBY GIVEN that the Plaintiff in the above matter, having been
granted a Final Decree in Divorce, hereby elects to resume the prior surname of Shari
Lynne Eagle, and gives this written notice pursuant to the provisions of 54 P.S. §704.
C? a Awc
Date
I
S ari Lynn Markelwitztz
22.
Shari Lynne Eagle
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS
On the day of 13i'r,day 1999, before me, a Notary Public,
personally appeared Shari Lynne Markelwitz, known to me or satisfactorily proven to
be the person whose name is subscribed to the within instrument, and acknowledge
that she executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notary Public
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