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Home My WebLink About99-07252<e i THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF tf` {t PENNA. it N o ..997-7.2.52 ....... ................. l )99 i ?I DECREE IN 03' f DIVORCE *4A. •2QQQ, it is ordered and ......... AND NO DOUGLAS.L..METZGER............ Plaintiff, decreed that . . . . . . MICHELLE, L., METZGER, , • , • . • .. , defendant, and ............................... are divorced from the bonds of matrimony. NONE 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; ti •,:; 0 • i e ttes Prothonotary " i ;o • :?> :e: <e: cei W. ce::e:• t7-• t?:? :v, ^•:e:• :e:•. •:e:• :e> ;o> :e:• <e: te:? : ,e> IN t J ,aAl 11,429 F1FILMDATAFILC4md cuA91]]W P UWe fume. 00110'W 02.11 08 P\I Rni3e 03RZW 11.1001 AM DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7252 CIVIL 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: via certified mail, restricted delivery on December 8, 1999 as evidenced by the filed Affidavit of Service. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; March 14, 2000; by the Defendant; March 17, 2000. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 15, 2000. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 21, 2000. MARTSON DEARDORFF WILLIAMS & OTTO Date: March 22, 2000 By J? W ?QA Thomas J. Will' s, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 11.... - CERTIFICATE OF SERVICE I, Tricia D. Eckcnroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: John Anthony Lombardi, Esquire P.O. Box 130 Summit, NJ 07902 MARTSON DEARDORFF WILLIAMS & OTTO 'Q I Tncia D. Eckenroad ? Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: March 22, 2000 4 r? 4 It!? V N c J.r C?j u :" C LLU ?._ _ ? :IJ Cl C7 _ O 2) O C) j., `4m, __.• ,rte-.,. ?' ;_.._ 7FIFILPSDATAFII,1`d ?2f4C,b1 NJe Crt4d IIIlO.MMP 2VA%l µoiad 1113DW'WUx Ie AN ]12214 DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- rl d.I A 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 i fyou 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 bythe 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be home by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL ANNULMENT IS NTERED,YOU MAY LOSE THE RIGHT TO CLAIM ANY OFTHEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR OFFICE SET FORTH BELOW TO POND OUT WHERE YOU C O N GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone(717)249-3166 k?. DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant IN TI-IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 72 S1 IN DIVORCE COMPLAINT CIVIL ACTION - LAW Plaintiff is Douglas L. Metzger, who currently resides at 120 Emerson Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Michelle L. Metzger, who currently resides at 32 Aubrey Street, Summit, New Jersey. 3. Plaintiff has been a bona fide resident 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 September 30, 1996 in California. 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. 8. Plaintiff requests the Court to enter a decree of divorce. MARTSON DEARDORFF WILLIAMS & OTTO ':K?s?-?. W Thomas J. W' li< ns, Esquire By :: Ten East Hi trees Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff J Date: December L, 1999 VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Doug ?as. e i r 'f lij? 1 7 v CP CJ { fi i ]F IFILLTDATAFILUdslx1 ,71'21W ar I,& IN Q.,cd I Iaa4109 W 1] A11 ec,Asd 1'28%01 IiMI'M TI.: W DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-,72,5k CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Michelle L. Metzger at 32 Aubrey Street, Summit, NJ 07801 on December2, 1999 by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Michelle Metzger" and dated December 8, 1999. wA Thomas J. W' s, Esquire Sworn to and subscribed before me this 281h day of December, 1999. _ D tary Public Notarial Seal Tdcia D. Eckenroad. Notary Public Carlisle Boro. Cumberland County Ay Commi•,sion Expires Oct. 23.2000 t? 1 Z 013 338 149 US Postal service Receipt for Certified Mail No Insurance Coverage Provided. d m L u °o C C O C L -71 a, Gto • Complelo items l andfor 2 for additional eeMM5. At Complete hams 3. aa, and ab. O Pnnt your name and address on the reverse of INS form solhal we can return this card 1o You. or on the back it space does not O Anach this torn to Ina tront of die mailpiece, pemut. O Wnte 'Ratum R.eaip, Ragwsred'an the mailpioeo below the snide number. o Tha Relum Receipt will show to whom the ands was delivered and the data Do not use forlnleroa nal man oav.o.o,.,o ryt10 Ile 12 Sere BNuneeer'/ _L ptsoy , Stale, 8 ZIP - P A a / . 17o) $ •5' Fee Delivery Fee ' Fae d detive ry eceipi5twvdeylo 0at?DeWered 0 ce'ptDownbYAM ",:? desielfs Address Postagd3Fce s dtN Dalai 0??,Ie I also wish to receive the follow- Ing services (for an extra fee): i m i . 0 Addressee's Address i t 2.IXRestricted Delivery i V m f E 3 4 1e. I' Tl 1 iiclle,,Addr/essssed /tq:. .IIL1L I f? ( Vy, IIL ?1? 0 ServiceTy C J ? Registered L 0 Express Mi .SLIMR - .1 VX -Gal' urn Co f too 102595-n-BoM S. c t i X19 Er m. B'Cenlged c . O Insured C 0 COD requested and re i I` i I c Return Receiol V.-I. FMLWl1ATAF1Lrcm4,WCUF%7:]W.Al F W& Cswad ODIaw 03.1108 PM koisw OVIOW03I319P\I DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7252 CIVIL IN DIVORCE AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. Douglas L. Metzger, Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Do as L/Nie ger, Plaintiff Sworn to and subscribed before me th. I4/ day of March, 2000. In, 526 Notary Public NOTARIAL SEA DAWN M. SHUGHART, Notary Public Carlisle, Cumberland County My Commission Expires Nov. 28.2002 I It ti ? C>? .X n U p J U _ P.0L=ATAF1LGIOmdrc cw%7122 MF.IA& Cr"W 03116 02:11:08 PM Mild 03/1M 02:1):19 PM DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant : M THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7252 CIVIL n ° 9n o vn_ IN DIVORCE un AFFIDAVIT OF CONSENT ? COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) Douglas L. Metzger, Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. ®wom to and subscribed before me ly day of March, 2000. ? I _ All Notary Public NOTARIALSEAL DAWN M. SHOGHART, Notary Public Carlisle, Cumberland County My Commission Expires Nov. 28, 2002 Do as L. N etzger, Plaintiff DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7252 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(0 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 ofproperty, 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 unswom falsification to authorities. Date: 3/f y?Up cqc - DougfaA. er, Plaintiff u: ?r{r c c'z J c_ Lr7 ? 4 O Q U DOUGLAS L. METZGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7252 CIVIL MICHELLE L. METZGER, Defendant IN DIVORCE AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND Michelle L. Metzger, Defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Michelle L. Metzger, Def ant Swom topnd subscribed before me this/7?f March, 2 00. ry Public t",:1C.tEGkR! Itotar rvatioofC.oslcroY Carr1?'?^•Cx:• PI: C?? J . r--- cS p) L C1_ :J C" „ J CD G CJ DOUGLAS L. METZGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7252 CIVIL MICHELLE L. METZGER, DIVORCE Defendant AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND Michelle L. Metzger, Defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to thepenalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. V Q 44` Michelle L. Metzger, a ant Sworn?,pnd subscribed before me this/f?f March, 2 00. PuLYPI?aC.K }Intp7 piwllo of Ito?vJccsoy t:nlez eunrt=a, u:uc3 DOUGLAS L. METZGER, Plaintiff V. MICHELLE L. METZGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7252 CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(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 ofproperty, 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 unswom falsification to authorities. Date: March 17, 2000 Michelle L. Metzger, of n L . Q_ L? C,1 cJ ? U cJ C_7 - - 171 in