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HomeMy WebLinkAbout99-07645Lt. 1 'e bb r fa- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF t}q" ?' PENNA. Michael E. Neil Plaintiff No. e4_7649 r;v;t mArm VERSUS Nanette M. Neil Defendant DECREE IN DIVORCE AND NOW, Fehrnwryalsk- , 2001 , IT IS ORDERED AND DECREED THAT Michael p Neil , PLAINTIFF, AND Nanette M Neil -,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; PROTHONOTARY r - , J? HAROLD 5. IRWIN, 111, E50UIRE ATTORNEY ID NO. 29920 35 EASY HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF MICHAEL E. NEIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NANETTE M. NEIL, : NO. 99 - 7645 CIVIL TERM Defendant : IN DIVORCE I? To the Prothonotary: decree: Transmit the record, together with the following information, to the court for entry of a divorce 1. 2. 3. 4. 5. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and manner of service of the complaint: On or about December 30, 1999, defendant was served with a copy of the divorce complaint via certified mail, "restricted delivery", addressed to the defendant. See affidavit of service filed by plaintiffs counsel. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff. August 19, 2000. By the defendant: August 22, 2000. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. Related claims pending: None 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: N/A (b) Date plaintiffs Waiver of Notrice In Section 3301(c) divorce was filed with the Prothonotary: August 24, 2000. Date defendant's Waiver of Notice in Section 3301© Divorce was filed with the Prothonotary: August 24, 2000. February 12, 2001 Attorney for Plaintiff ..:t u' =. C.. i? ?. t5; <'? L cc = _ ?,? ?<: ?i `-, _:. n ;? ?:: c. ?: i:r L•_ 'J `-' CU a HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 2439090 ATTORNEY FOR PLAINTIFF MICHAEL E. NEIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 99. 71211 CIVIL TERM NANETTE M. NEIL, Defendant : IN DIVORCE NOTICE 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 in 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013• 717-249-3166 MICHAEL E. NEIL, Plaintiff V. NANETTE M. NEIL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 -'91 y1? CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Michael E. Neil, an adult individual residing at 256 Pattison Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 2. The defendant is Nanette M. Neil, an adult individual residing at 430 Newville Road, Newburg, Cumberland County, Pennsylvania 17240. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on June 5, 1998, in Newburg, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. 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. December J 1999 in ,CA&('C' 4:, Oy??Q MICHAEL E. NEIL, Plaintiff HAROLD S. IRWI , III Attorney for Plaint 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29.920 MICHAEL E. NEIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 99 - A, V/ CIVIL TERM NANETTE M. NEIL, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFID"IT The 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. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. 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. December GS, 1999 MICHAEL E. NEIL, Plaintiff ' ?'t HAROLD S. IRWIN, 111 ESQ. ATTORNEY ID NO. 92585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 2436090 ATTORNEY FOR PLAINTIFF MICHAEL E. NEIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 99 -7645 CIVIL TERM NANETTE M. NEIL, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1520.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about December 30, 1999, by certified mail "restricted delivery", addressed to the defendant at 4340 Newville Road, Newburg, PA 17240 (Certified Mail Receipt No. Z 339 062 163). 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made a e subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsifcatio o authorities. January 12, 2000 Wj Harold S. Irwin,il Attorney for plain i r:. lL N rill S I also wish to receive the follow- follow- m s v SENDER: ing services (for an extra fee): ' T ' o n Complete items l andfor 2 for ad60ooal seh,icos. Complete items 3.4a, and 4b. to Print your name and address on the revemo of INS torte so lhal we can return Isis t (:I Addressee's Address u o card to you. OAnach lNstam to the front of ee mailpleca, or on the bad it spare does not 2.?Restficled Delivery Y ' permit. ?Write'Refum Racoipl Raqueslad'on the nUIROoce bolo, the arnica number. tum Receipl will show lowlwln the article was delivered and the dale R Th c o ' v e e 0 debvered. 3. Article Addressed to: 4a. Article Number Z ?39 • m -TrF- ??'1 ? L Iv/ I •l 4b. Service Type ?Registered ACenilied 2 y1?/ 7? yO lV6GJIJ It-LE 3 O Express Mail []Insured rchandise []COD i M f 7 pt or e Return Rece /)r1 vo / f co -8 U-/66?AZ7 7. Date of sit cry , re ante) s (Only requested antl B. Addressee's Addr 5. Received B : fee is paid) 03 5 6. i a ure A resse o Age 0 i2 mber 1994 D 102595.9se.02 Domestic ReNrn Rece ece pg o m _n ra M N "w o :C a d rn U d u O o ZOV N 4" c n dm x07 a U d jIXZ z: rqi u c' ti a c 0 0 c L.; :IJ3 m C3 0 MICHAEL E. NEIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 99 - 7645 CIVIL TERM NANETTE M. NEIL, Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about December 23, 1999 and served upon the defendant on or about December 30, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. 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. August), 2000 /Y1 'L .k xuf , F /Y? J I Q MICHAEL E. NEIL (J ? ?? v ?% ?-' ?.). ^- :in cam: c: i??? -', u ?; MICHAEL E. NEIL, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NANETTE M. NEIL, Defendant : CIVIL ACTION - LAW : NO. 99 - 7645 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about December 23, 1999 and served upon defendant by certified mail on December 30, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. 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. August, 2000 +? A E TE M. NEIL ', J L1 LI .? U MICHAEL E. NEIL, v. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NANETTE M. NEIL, Defendant CIVIL ACTION - LAIN NO. 99 - 7645 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE TINDER SECTION 3301(C, OF THE DIVORCE CODE 1. I 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 this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. August, 2000 ?, ?Tlv dP ?- , 7V' MICHAEL E. NEIL . A.:T %. -,'I I MICHAEL E. NEIL, v. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NANETTE M. NEIL, Defendant : CIVIL ACTION - LAW : NO. 99 - 7645 CIVIL TERM IN DIVORCE WAIVER OF MOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTIONI 3301(C) OF THE DIVORCE CODE 1. I 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 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. August,-0, 2000 A A M"NETTE M. NEIL `; r J _ ' A C L, MICHAEL E. NEIL, V. Plaintiff NANETTE M. NEIL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 - 7645 CIVIL TERM :IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 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. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's 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. 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. August!j,2000 mA,,?(,n?? mpq( MICHAEL E. NEIL ?J I 1- _< 1 J MICHAEL E. NEIL, V. Plaintiff NANETTE M. NEIL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 - 7645 CIVIL TERM IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The 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. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. 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. August-49-,2000 l/ r4ANETTE M. NEIL i-{ i I % rt'i C) (• ? l (!) JI. n =j U