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Home My WebLink About03-4457STEVE M. WHISTLER, Plaintiff V VICKIE M. WHISTLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO~.3 ~ ~¥5'1 CIVIL TERM : 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania, 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, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 STEVE M WHISTLER, Plaintiff V VICKIE M. WHISTLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. o.~ - N ,~,3 7 CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(C ) OR (D) OF THE DIVORCE CODE Plaintiff, Steve M, Whistler, by his attorney, Lindsay D. Baird, Esquire, sets forth the following: Plaintiff, Steve M. Whistler, is an adult individual residing at 109 Big Spring Terrace, Newville, Pennsylvania 17241. Defendant, Vicki M. Whistler, Gardners, Pennsylvania. 2 is an adult individual residing at 196 Georgetown Road, 3 The parties were married on October 13, 1984, in Cumberland County, Pennsylvania. 4 Defendant has lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no pdor actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c ) of the Divorce Code, the marriage between the parties is irretrievably broken. 8 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. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. Lindsay D.~ I~ird, Esquire Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 ~ verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that raise statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities, STEVE M. WHISTLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2003-4457 CIVILTERM VICKIE M. WHISTLER, Defendant · IN DIVORCE 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 September 10, 2003. 2. Defendant acknowledged receipt and accepted service of the Complaint on September 13, 2003. 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. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I 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. Steve M. Whistler, Plaintiff STEVE M. WHISTLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2003-4457 CIVILTERM VlCKIE M. WHISTLER, Defendant :IN DIVORCE 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 September 10, 2003. 2. Defendant acknowledged receipt and accepted service of the Complaint on September 13, 2003. 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. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I 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: ~;~'(~' (~ ~ ~'JQ. 4~ Vickie M. Whistler, Defendant STEVE M. WHISTLER, plaintiff VIcKtE M. wHISTLER, Defendant : iN THE cOURT OF COMMON pLEAS OF · CUMBERLAND CouNTY, pENNSYLVANiA · NO. 2003-4457 CiViL TERM ~ iN DIvoRCE ~ that a taw do depose and state n with a copy of a Notice to plead .... ,-.~ ~,~ the above-capt, on..ed ,m~,a~.~esrea~;gon the Defendant.,.V~ifcsk~dMreturn I, Lindsay Dare Baird, Esquire, being duly sworn according to -' '~-e Compla~n~ m=u ,,,~ -.~..~ne counseling w.,= ~ copy v~.,~_,~,;~ of Availability °~_w~"_'~.~eint Requested, Whistler, by Gem~ ?' · a~ached hereto. Said sewice on September 13, 2003. receipt evidencing deltve~ bemg Carlisle, PA 17013 717 - 243-5732 Sworn and SubSCribed to "-is q'~ day., before me u, ~ onn~f' · COmplete items t, 2, and 3. Also Complete ite. m 4 if Restricted Delivery ia desired. · Pnnt your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits, A. Received by (P/ease Print Clearly) Is Mh~ 1~31 ~ 17 E-lye~ 2. A~t~IS Number . P~~U~mUU/~.,,? 91 6023 STEVE M. WHISTLER, Plaintiff V VICKIE M. WHISTLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-4457 CIVILTERM :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: September 13, 2003, certified mail, restricted delivery, return receipt. 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: March 9, 2004; by Defendant: March 9, 2004. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: March 9, 2004 Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: March 9, 2004 ndsay Dar aird, Esquire Attorney for the Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF p ,~~ ~, PENNA. STEVE M. WHIST~,~ Plaintiff VERSUS VICKIE M. WHISTLER Defendant NO. 2003-4457 DECREE IN DIVORCE AND N O W ,/~~~ DECREED THAT STEVE M. WHISTLER , PLAINTIFF, AND VICKIE M. WHISTLER , 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; BY THE COURT: PROTHONOTARY