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HomeMy WebLinkAbout99-06370 i sv; t.•. t t w JLr f? IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PENNA. Diane.. R....Ensminger, . Plaintiff Versus Rodney L..Sheller, ...Defendant PLEAS IN N t )..9976370 ... ................. 19 DECREE IN DIVORCE AND NOW, ..... a ...I......... 9??UUJ1 it is ordered and decreed that .... Fnsllmi.nger ........................ plaintiff, and .... Rodney..L.. Sheller ................................. 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; . n v.-? ......................................... ...... .............. By T k\ f? Attest: ,??`?? ??j W(/w J. j i Prothonotary 1• \ U I'e v DIANE R. ENSMINGERj Plaintiff VS. RODNEY L. SHELLER, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 99-6370 CIVILTERM PRAECIPE TO TRANSMIT RECORD 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) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: U. S. mail on October 25, 1999 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 1/24/00 ; by defendant 1/21/00 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: n/a 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 plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 1/27/00 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 1/27/00 oq F7 T ? cv _. r 11 ? ' DIANE R. ENSMINGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : NO. CIVILTERM 1999,] RODNEY L. SHELLER, Q 9 - le 3 70 l:l v c Defendant IN DIVOORCE NOTICE: TO UIJ'END AND CLAIM RIGI11' 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 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 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 Cumberland County Court I louse, Carlisle, Pennsylvania. IF YOU DO NOT PILE A CLAIM FOR ALIMONY. MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE 1*1IE FINAL DECREE 01' DIVORCE: OR ANNULMENT IS GRANTED. YOU MAY LOSE TI IE RIGI IT TO CLAIM ANY OF TIIEM. YOU SIIOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORY Olt CANNOT AI'FORD ONE. GO TO OR TELEPI ZONE THE OITICE SET FORTH BELOW TO FIND OUI' WI IERE YOU CAN GET LEGAL I IELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013 'T'elephone: (717) 249-3166 DIANE R. ENSMINGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. CIVIL TERM 1999- G39o"? ?""` RODNEY L. SHELLER, Defendant IN DIVORCE COMPLAINT UNDER SECTIONS 3301(C) AND 3301(D) OF THE DIVORCE CODE 1. Plaintiff Is Diane R. Ensminger, an adult individual who currently resides at 103 E. Pine Street, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Rodney L. Sheller, an adult individual who currently resides at 2 Stuart St., Apt. 2, Mt. Holly Springs, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents In the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 10, 1999, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff request the court to enter a decree of divorce in favor of the plaintiff and against the Defendant. Respectfully submitted, FISHMAN & MORGENTHAL Steven J. Flshman I.D. #18289 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 (717) 249-8333 Attorney for Plaintiff, Diane R. Ensminger t 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 to authorities. :a Date: ? ? ? ? ? ? -?? ? ?o ?, ?? ? ?. U ¢? ~ ? ? 4? ? ? '69. 2 l? Q ? ? ?? \ ? ?? . , ??;, `: is „ ?? . z ???? ?? C i?%? 1 ',r ,;? i 'i° r t: ?? ?'.?: , ?a r?.j, `ikf$¢. <?i7 X ) ?? .?? ..i.. '.?.?[ k_{? t :'v{ DIANE R. E.NSMINGER. IN'1'111i COURT OF COMMON PIXAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99- 6370 CIVIL. TERM RODNEY L. SHELLER, Dcfcndant IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE, AND WAIVER OF NOTICE. OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on October 19, 1999. 2. Dcfcndant acknowledged receipt and accepted service of the Complaint on October 26, 1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days hnve elapsed from the date of the filing of the Complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 1 understand that I may lose rights concerning alimony, division of property, Lawyer's fees or expenses if 1 do not claim them before a divorce is granted. 6. 1 understand thnt 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 inc immediately alter it is filed with the Prothonotary. 7. 1 hnve been advised of the availability of marriage counseling and understand thnt I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: o"'O DIANE R. c; ujr c? .-• w c Sy ?? 1 '-DIANE It. ENSMINGER. Plaintiff V. RODNEY L. SHELLER. Defendant IN TI IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6370 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE. OF SERVICE AND WAIVER OF NOTICE. OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 330I(C) OF THE DIVORCE CODE I. A complaint in divorce under Section 3301(C) ofthc Divorce Code was filed on October 19, 1999. 2. Defendant acknowledged receipt and accepted service of the Complaint on October 26, 1999. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 1 understand flint 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 do not claim them bcforc a divorce is granted. 6. 1 understand flint I will not be divorced until a Divorce Decree is entered by the Court and flint a copy of the Decree will be sent to me inunediatcly afer it is filed with the Prothonotary. 7. 1 have been advised of the availability of marriage counseling and understand that I may request flint the court require counseling. I do not request that the court require counseling. verify that the statements made in this aMdavil are true and correct. I understand flint false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unstsoru faibif .atlw11o uulhoritics. Date, - 00 s ?jp(ZI(' ? - RODNG L. Slll: R .. - - - ...... .. .. nib n 3 t? u f cry r- •tn N } ,, r7 U Fr?7'F _, Z 1 DIANE R. ENSMINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-6370 CIVIL TERM RODNEY L. SHELLER. Defendant IN DIVORCE AND NOW, this 20fix day of October, 1999, 1, RODNEY L. SHELLER, Defendant above, hereby accept service of the Complaint in Divorce filed in the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. RODNE L. SHELLER ?- - `s?- ??, r . ?? ?-1 T( . ? f:: :? ?;'x