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HomeMy WebLinkAbout99-07371 ?' IN A 1 THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY STATE OF PENNA. REGINA L. WARDLE, ................................. ....._.............._.................... Plaintiff ................................................................................ e Versus JEFFREY F. WARDLE, ..... .....................................__. _........ .......... ........ .... Defendant No...... ?.U7 ........ t:Iuk... l) 99 DE CRE E IN DI VO RC E is i AND NOW, ......... +9- ...... it is ordered and REGINA L. WARDLE decreed that .................................................. plaintiff, JEFFREY F. WARDLE 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 . .t...... fop Attest: J, Prothonotary . ??:. •a:• •A:• :?:• <?. <?:• ;o} :o>. :o:• :%•. <o:• cE• •:o: •:o:•^•:o:••s? <o:? o:? •C?• •:v <q. •:eh •:e:• e: •:e> •:e7^0: <%•^;a 0 i i 0 i ,::.. ... ?, . ,. REGINA L. WARDLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY F. WARDLE, Defendant NO. 99-7371 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: Ground for divorce: irretrievable breakdown under Section 3301(c) of the divorce code. 2. Date and manner of service of the complaint: Defendant signed an Acceptance of Service form on December 13, 1999. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required under Section 3301(c) of the divorce code: by the plaintiff March 15, 2000 by the defendant March 16, 2000 (b) (1) Date of execution of the plaintiff s affidavit required bySection 3301 (d) of the divorce code N/A (2) Date of service of the plaintiffs affidavit upon the defendant 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 plaintiffs waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: March 15, 2000 Date defendant's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: March 16, 2000 Michael A. Scherer, Esquire Attorney for the Plaintiff, Regina L. Wardle uj? N O! pu- r ,I l.- J LL: Q' •-i LU f1. -y G f?] a. a U ?c . 1 REGINA L. WARDLE, Plaintiff V. JEFFREY F. WARDLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 73'71 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 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 House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone: (717) 249-3166 REGINA L. WARDLE, Plaintiff V. JEFFREY F. WARDLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- '73 TI CIVIL TERM CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301(Cl AND 3301(D) OF THE DIVORCE CODE 1. Plaintiff is Regina L. Wardle, an adult individual who currently resides at 30 Shank Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey F. Wardle, an adult individual who currently resides at 30 Shank Road, Carlisle, 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 October 19, 1991 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 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. S. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER 94, Al - Michael A. Scherer, Esquire I. D.# 61974 17 West South Street Carlisle, PA 17013 (717) 249-6873 i .- C` I . Attorney for Plaintiff, Regina L. Wardle r' VERIFICATION 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. C7C?.\GI???L JcC? a 0 Regina L. Wardle Y Date: 1 -3() REGINA L. WARDLE, Plaintiff V. JEFFREY F. WARDLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7371 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on December 8, 1999. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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. 6. 1 have been advised of the availability of marriage counseling and understand that 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: 3 -tai c;n j Regina L. Wardle i? . L ? r Of fy? wtu ?c aJ r_ a o o v REGINA L. WARDLE, Plaintiff V. JEFFREY F. WARDLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7371 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S 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 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 8, 1999. 2. Defendant acknowledges receipt and accepts service of the Complaint on December 13,1999. 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 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. 7. 1 have been advised of the availability of marriage counseling and understand that 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: to 0D 1! 1 ., Jeffrey F. ardle i a? WO U-= N j ?y L? ? Q Q O ? o U REGINA L. WARDLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-7371 CIVIL TERM JEFFREY F. WARDLE, CIVIL ACTION-LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this --3 day of December, 1999, I, Jeffrey F. Wardle, Defendant above, hereby accept service of the Complaint 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. ? 0` Jeffrey F. Wardle C-' l.J U REGINA L. WARDLE, Plaintiff V. JEFFREY F. WARDLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7371 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce from the Bonds of Matrimony on the 27th day of March, 2000, hereby elects to retake and hereafter use her prior name of Regina L. Sipes, and gives this written notice avowing her intention in accordance with the provisions of the act of May 25, 1939, P.L. 192 (23 P.S. 98), as amended. Dated: 112,12-coo 0l on C1 1 UhR AC Regin L. Wardle TO BE KNOWN AS 10 RRegInb L. Sipes % COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the 1-2 d'day of April, 2000, before me, a notary public, personally appeared Regina L. Wardle to be known as Regina L. Sipes, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto setAy hand and official seal. Angela E Unrer. Carlisle Bore. Cunb.^.rLrr- (. !Ay Commission Exp.e!,-. Oci 7. o% h P m r a rr?? v0 u: r= _ IJ G