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Home My WebLink About07-2047 F:AD0CS\FLVDIV\13ENTZEL,GE0RGE-3301D(ADULTRY) GEORGE M. BENTZEL, IV Plaintiff V. JENNIFER M. BENTZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . NO. 07 - .),G47 66c. i L" -hl : CIVIL ACTION - 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 Courthouse, Carlisle, PA 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 32 South Bedford Street Carlisle. PA 17013-3302 Telephone: (717) 249-3166 -1- I l 44 tl\divABENTZEL,GEORGE-3301 D(ADULTERY) GEORGE M. BENTZEL, IV Plaintiff V. JENNIFER M. BENTZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . NO. 07 -- .2DY7 CIVIL ACTION - IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is GEORGE M. BENTZEL, IV, an adult individual residing at 203 Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is JENNIFER M. BENTZEL, an adult individual residing at 98 Herman Avenue, Apartment E, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. The plaintiff and defendant have been bona fide residents of the Commonwealth of Pennsyl- vania for more than six months before filing the complaint in divorce. 4. The plaintiff and defendant were married on June 17, 2005, in Camp Hill, Cumberland County, Pennsylvania. 5. The plaintiff and defendant are citizens of the United States. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. The defendant is not a member of the Armed Services of the United States. -2- t. 9. The plaintiff avers that one child has been born of this marriage. 10. The plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. WHEREFORE, plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to § 3301(c) of the Divorce Code. Respectfully Submitted, STONE LaFAVER & SHEKLETSKI DATE: ?n I e ?-- -3- ? 41W VERIFICATION George M. Bentzel, IV states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Geor M. Bentzel, IV Date: , 5- ? Z- /O-- 0 -7 t? W .D a ?J L` I-__, G,3 L1 I rTD -?1 Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 GEORGE M. BENTZEL, IV, Plaintiff vs. JENNIFER M. BENTZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2047 CIVIL TERM IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as attorney for Defendant, Jennifer M. Bentzel, in the above-captioned action. Respectfully, Date: X, X- o ey I . D? P?o.. 0704 4"Box ocust Street 11489 Harrisburg, PA 17108-1489 (717) 232-6600 w CERTIFICATION I hereby certify that I am this day serving a true and correct copy of the attached Praecipe For Entry Of Appearance on the following individual by First Class U.S. Mail addressed as follows: Elizabeth B. Stone, Esquire Stone, LaFaver & Shekletski 414 Bridge Street New Cumberland, PA 17070 Date: rman, Esquire No.: 07047 X26 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 0 ? 0 -n ? G'? f tV -? j t' ?J zt. rv VTI _4 Fl\di v\BENTZEL,GEORGE-affofservice GEORGE M. BENTZEL, IV, Plaintiff V. JENNIFER M. BENTZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2047 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, Jennifer M. Bentzel, at 99 Herman Avenue, Apartment E. Lemoyne, Pennsylvania 17043, by United States Certified Mail, postage prepaid, restricted delivery, on April 17, 2007, as evidenced by the attached Certified Mail return receipts. SWORN TO AND SUBSCRIBED before me thi day of 200 7. r° Notary Pu 'c _. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KATHLEEN KEIM, Notary Public New Cumberland Boro., Cumberland Co. My Commission Expires Dec. 5, 2010 CERTIFIED MAIL RECEIPT A Q^ r-? 4S6Z)f $ • •,? ? O ' 117 Certified Fee O C O ? Return Receipt Fee C3 (Endorsement Required) O Restricted Delivery Fee -7D Q C3 (Endorsement Required) O Total Postage & Fees $ S-6 ru rl.l a (Pitese Print Clearly, o be co)(pleted by mailer) . ... i _ . ....... Apt. ; or PO Box No. Er STU 117 % 1.1_144h.. - :............................ LJ• ,M RY .?. a Y Fi I?U ¦ Oontffieb pears 1, 2, mid 3. Abo oompieee psm 4 if Reehioted DoWery Is desired. ¦ PrMrt your name and address on the reverse so that we can return the card to you. ¦ Af2ach this card to the back of the maflpiece, or on the front If space permib. 1. Irude to: X, 1, `? t2e-lA.??o D Y)" o w? ',7ZA P ? e X I AgelrR ? Addlsawe D. Is de&vy eddrees dffe wd from Item 1? ? Yee it YES, wow delivery address below: 0 No 3. S9rGlce lype m clKUfled Mall a Mail a Ropletersa tFAKrn Receipt for merchwidee O kwired Mau O C.O.D. 4. Reatrioted Delivery? (Extra Feell re. 2. ArMb Number (Awnfar ffenr aerwtioo "0 ? ? M 3a? c? o op-1 OG 01 51 of l PS Form 3811, Febrwry 2oo4 Dormetb Pakwn Raoelpt toww.ae4r?.ta4o r-z ? C= c ? 7;* F C7 PJ C:) Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717) 232-6600 Fax: (717) 238-3816 E-mail: jraderman c(?thewiselawyer.com Attorney for Defendant GEORGE M. BENTZEL, IV, Plaintiff vs. JENNIFER M. BENTZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2047 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 April 13, 2007. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and 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 Decree. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. 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: Ay/ f;/ , 2eV y GEO GE M. BEN EL IV f'? rv 77 r 1 }. Q Jay R. Braderman, Esquire Attorney I. D. No. 07047 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717) 232-6600 Fax: (717) 238-3816 E-mail: jbradermant?thewiselawver.com Attorney for Defendant GEORGE M. BENTZEL, IV, Plaintiff vs. JENNIFER M. BENTZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-2047 CIVIL TERM : CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 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 understand 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 unsworn falsification to authorities. Date: avy _ GE GE M. BE L IV -D C-30 LX rri rn? G2 Jay R. Bradennan, Esquire I.D. No. 07047 Lavery Faherty Young 8 Patterson, P.C. 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Tel. (717) 233-6633 Fax: (717) 233-7003 Attorney for Defendant GEORGE M. BENTZEL, IV, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-2047 CIVIL TERM JENNIFER M. BENTZEL, CIVIL ACTION - IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 13, 2007. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and 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 Decree. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. 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: 11-0-09 =-Y7 r, Jay R. Braderman, Esquire I.D. No. 07047 Lavery Faherty Young & Patterson, P.C. 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Tel: (717) 233-6633 Fax: (717) 233-7003 Attomey for Defendant GEORGE M. BENTZEL, IV, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JENNIFER M. BENTZEL, Defendant : NO. 07-2047 CIVIL TERM CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 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 understand 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 unsworn falsification to authorities. Date:- ?? .- i ""' :?' ie; - 1`^? , ?;> ?:, t.. ..? G" GEORGE M. BENTZEL, IV, Plaintiff V. JENNIFER M. BENTZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-2047 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: 1. Ground for divorce: Irretrievable breakdown under §3301(c) 330) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: 04/17/2007 via United States Certified Mail, Postage Prepaid, Restricted Delivery 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 ; by Defendant (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiffs affidavit upon the respondent: 4. Related claims pending: All claims settled 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 §3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 1/ Elizabet one, orney for Plaintiff 1-11 M it R gm . µ -? Co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GEORGE M. BENTZEL, IV, V. JENNIFER M. BENTZEL, NO. 07-2047 01VORCE DECREE AND NOW, _kr..w 9 ` Z0o8 , it is ordered and decreed that GEORGE M. BENTZEL, IV, , plaintiff, and JENNIFER M. BENTZEL, defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") No issues raised. By the Court, ,tee Atte :' J Prothonotary nl- Cl o f el