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Home My WebLink About99-07290Y .m V A 0 a.: X IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNSYLVANIA SHARON LOUISE WAGNER, ...................................................... laintiff.......... li Versus MARC DOUGLAS WAGNER Defendant N o. 99-7290 C.I.Y.I. X)K TERM DECREE IN DI VORCE AND NOW, .........<!? !....?.9....., („29oA it is ordered and decreed that .... SHARON LOUISE 69AGNER plaintiff, MARC DOUGLAS WAGNER 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 ........................................................................... ........... .................................................................. JJ By T Court ......... . ...?........... ......... ........ ....................... ........... ...................G?C?... • . P....._............... rothonotary A*.)OK1A*i 'N6:%C16:•Wi /.W.!J' -W. ;A••. •A:•. •7&.:A?:•'A:!:•i?• iA •: i'A:•: X?N .{t:•. ??•: 1.t• 3 SHARON LOUISE WAGNER, Plaintiff VS. MARC DOUGLAS WAGNER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 99 - 7290 CIVIL TERM 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 53301(c) 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: December 6, 1999, by certified U.S. mail. 3. Complete either paragraph (a) o- (b). (a) Date of execution of the affidavit of consent required by 53301(c) of the Divorce Code: by plaintiff March 13, 2000 by defendant March 13, 2000 (b)(1) Date of execution of the affidavit required by 53301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's 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 plaintiff's Waiver of Notice in 53301(c) Divorce was filed with the Prothonotary: _ ;.larch 22. 2000 Date defendant's Waiver of Notice in 53301(c) Divorce was filed with the Prothonotary: March 22, 2000 Date: March 22, 2000 Attorney for (Plaintiff)(}f} JB W Marlin R. McCaleb, Esquire >- LO C> ?. y C?i U1 0 O o ? SHARON LOUISE WAGNER, Plaintiff VS. . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 7a(1U CIVIL TERM MARC DOUGLAS WAGNER, Defendant CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS LAW Of 1'ICL% MARLIN R. MCCALER 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. If the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the office of the Prothonotary at Cumberland County Court House, Carlisle. 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 borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylv/ann?a 17013 (717) 249-3166 Marlin R. McCaleb Attorney for Plaintiff SHARON LOUISE WAGNER, Plaintiff VS. MARC DOUGLAS WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 7? 9v CIVIL TERM CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(5j) OF THE DIVORCE CODE 1. Plaintiff is SHARON LOUISE WAGNER, who currently resides at 6367 Stephen's Crossing, Mechanicsburg (Hampden Township), Cumberland County, Pennsylvania 17055, since January 6, 1995. 2. Defendant is MARC DOUGLAS WAGNER, who currently resides at 132 Victoria Drive, Mechanicsburg (Lower Allen Township), Cumberland County, Pennsylvania 17055, since October 23, 1999. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 28, 1985, in the Borough of Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or I.AW (I, I,CO: MARLIN N. MCCALCO annulment between the parties except for an action in divorce commenced by Plaintiff against Defendant in the Court of Common Pleas of Cumberland County, Penrsyl,;ania, to No. 95-2035 Civil Term, which action was dismissed pursuant to Pa. R.C.P. 1901(c) by order of Court dated October 27, 1998. 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 your Honorable Court to enter a decree of divorce. 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., Section 4904, relating to unsworn falsification to authorities. Sharon Louise Wagner, Plaintiff Date: \a \a , 1999 Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Plaintiff LAW 1111 ICI:!; MARLIN R. MCCALER -2- SHARON LOUISE WAGNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 4l7- `r15?'0 CIVIL TERM MARC DOUGLAS WAGNER, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Sharon Louise Wagner, 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 office of the Prothonotary, 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 counselling 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., Section 4904, relating to unsworn falsification to authorities. Date: \a 1999 1yt?o ??o i,o ?.7<< c? Sharon Louise Wagner, Plaintiff 1 !rv+ .?A LAW OI„lf3 MAFLIN 14. MCCALG) LL: }l ^ r a L) t.l i:i^ O ii U O M ? O a E W tom !] U o y H a H W 9 ro o N o W > ua ++ w?+ xN r>i ? a 5rmo; 0 3 z (0 ww a u , w=NZ a O Q a ¢ SO w ` z 3 N a f m w ik. O I I ? C. 3 a Y° o w N H z a' H V z z N D M z PD HH '.7 F7 ?j aN u Z H ? a z a w w w u a s o v P D L) z N U U U x t p SHARON LOUISE WAGNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 7290 CIVIL TERM MARC DOUGLAS WAGNER, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF SERVICE MARLIN R. McCALEB, Esquire, certifies and says: that he is LAW m r'ICU. MARLIN It. MCCAL[B the attorney for Sharon Louise Wagner, the Plaintiff in the above-captioned action; that on behalf of said Plaintiff, he did file Plaintiff's Complaint in Divorce in the Office of the Prothonotary of Cumberland County, Pennsylvania, on December 3, 1999; that pursuant to Rule No. 1930.4(c) of the Pennsylvania Rules of Civil Procedure, he did serve said Complaint upon Marc Douglas Wagner, the Defendant herein, by depositing a true and attested copy of said Complaint, properly endorsed with Notice to Defend and Claim Rights, in the mail in the post of f ice at Mechanicsburg, Cumberland County, Pennsylvania, on December 6, 1999, properly addressed to the said Defendant at his place of residence at 132 Victoria Drive, Mechanicsburg, PA 17055, with proper postage attached, certified United states mail (Receipt No. P 977 270 307, return receipt requested, restricted delivery) ; that thereafter he did receive said return receipt card bearing the signature of Marc Douglas Wagner, Defendant herein, and indicating receipt of said copy of the Complaint on December 9, 1999; that the said certified mail receipt and return receipt card are attached hereto and made a part hereof, marked Exhibit "All. I verify that the statements made in this Affidavit are LAW or r¢cs MARLIN R. MCCALEB 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. Date: December 10, 1999 ?aZ??Clll Marlin R. McCaleb -2- I To: P 977 270 307 Marc Douglas Wagner 132 Victoria Drive Mechanicsburg, PA 17055 SENDER: REFERENCE: d. dFee RETURN Rawyt Fw rRw.m RECEIPT SERVICE rciea Dewerv LAW OFML _?SLIN R. MCCALEe TM l NNpe eM F.. US Postal Service Receipt for Certified Mail No Insurance Coverage Provide< Do not use for International Mail RE: SENDER: Marlin R. McCaleb. Esquire 219 East Main Street P.O. Box 230 I, Article Addressed to: Marc Douglas Wagner 132 Victoria Drive Mechanicsburg. PA 17055 M i?RC RESTRICTED I DELIVERY y Consult postmast P97727 EXHIBIT "All rJ4 F PL4 Z L) , w 4J H li a. q rO x N mi W'? 2 rt a w w Wz= L W N O ° w°d 4124 ' 0 m 5 O ° I ., E x zw uzmz w N N rc u H a 0 z 0 O r7 Z EA U a 0 ? Z Ga a P4 > U N 1 i_i? rt 'v7 JL? l? - SHARON LOUISE WAGNER, Plaintiff Vs. MARC DOUGLAS WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 7290 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 3, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony LAW (V„CCS MARLIN R. MCCALES pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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: z `'. 2000 Y,r- ??. ?J• .,ri Plaintiff Sharon Louise Wagner, ,I ? ' ul LJ C? : ,• _ 'jilij O U 03,1via" '!1 NIIHV W !::1.1..1.10 My I 33T-4uTutd 'zau6uM asrnoZ uozugS : aa2Q /-'",5. ?. _? JL,.-• ;eiJ _.r?.y.?\( I _ D ' --7-77- 00Z V •saT-4Tzogpnu o; uoT:juoT3Tsju3 uzoMsun o?4 6uT:IuZaz 'v06b§ uoTgoaS 'S'O 'ud et 3o saTgZuuad aqp o-4 aoaCgns apuw azu uTazaq s:juawa:ju--js astu3 qugp puuaszapun i 'aoazzoo puu awn azu :ITAUpT;;u sTq-4 UT apuw s:juawa-Au-4s agq quq:l AJTzaA I Azu:10uogpozd aq; g;TM p9ZT3 ST 3T zaa3u AZa:4uTpawwT aw 0:1 ;uaS ag ITTM aazoap agp ;o Adoo u :4aq-4 puu -4zno0 aq:l Aq pazaqua sT aazoap aozoATp u TT-4un paO.zoATp aq -40u ZZTM I :IugP puugszapun I £ pa-3uuz6 ST aozoATp u 9zo3ag wag-4 wTuZo aou op 13T sasuadxa zo saag s,zaAMUZ 'A:jzadozd 30 uoTSTATp 'AuowTtu 6uTuzaouoo s-4g6TZ asot Auw I :lugq puu:ls.zapun I Z aoTpou nog;TM aozoATp 3o aa.zoap 7[uui3 u 3o A.I'Aua aga 0:1 Iuas[IOO I -E 3000 a5u0AIa 3HL d0 o TO££ uaaNn agwaa aaxOAIQ v d0 xuINN ISHn 821 OS NOIINSINI do 20110K A0 HaAIVM SDIIOAIQ NI - NOIIDV rIIAIO MEL UAIO 06ZL - 66 'ON MHrI - NOIIOK UAIJ VINVArI7,SNNSd '7,INROJ QNTIESEKBO d0 SK3'Id NOWWOO aO Z2InOO SHI NI juupua3aQ ' ZISNJKM SKrIJf10Q Z)HVW SA 33T'quTUid lHHN0VM $SIIlOrl NOUVHS r Ln I u N ;ti l0 O SHARON LOUISE WAGNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 7290 CIVIL TERM MARC DOUGLAS WAGNER, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 3, 1999, and was served on me by certified mail on December 6, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 5. 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. 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 verify that the statements made in this affidavit are LAW 110 1 WVS MARLIN R. MCCM.EO 11 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: MtlRcI\ 13 2000 Marc Douglas Wagner.; Defendant LAW of I Ina MARLIN H. WCALHO -2- .4 J t: u)c c ? ? r . : Q •` c f 1" Q- ll A - O U ?? SHARON LOUISE WAGNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 99 - 7290 CIVIL TERM MARC DOUGLAS WAGNER, Defendant CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER r43301 (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 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. Section 54904, relating to unsworn falsification to authorities. Date: /1?AF-C?nl? 2000 4 - ()O(" 1rs_ ( JARAJL- Marc Douglas Wagner, Defendant LAW 01"„ICI:S MARLIN R. MCCALER ..- ... - ---- mot.+'1':r? ?. 1'1