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Home My WebLink About07-5800-ft F: \FILES\Clients\7122\7122 331. com l Created: 9120/04 0:06PM Revised: 10/2/07 3:49PM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DANIEL W. NICKEL, Plaintiff V. NICOLE M. NICKEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 DANIEL W. NICKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, /PENNSYLVANIA V. NO. 07- .epez CIVIL ACTION - LAW NICOLE M. NICKEL, Defendant IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Daniel W. Nickel, who currently resides at 47 Spring Garden Estates, Carlisle, Cumberland County, PA. 2. Defendant is Nicole M. Nickel, who currently resides at 47 Spring Garden Estates, Carlisle, Cumberland County, PA. 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 December 30, 2003, in Florida. 5. There have been no prior actions of divorce or for annulment between the parties. 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 the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage between Plaintiff and Defendant. MARTSON LAW OFFICES By Thomas J. W isms, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: 0) 1D7 / 0 7 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Danial Nickel t.IJ V E F: \FILES\Clients\7122\7122.3 31. aos Created: 9/20/04 0:06PM Revised: 10/4/07 10:31 AM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DANIEL W. NICKEL, Plaintiff V. NICOLE M. NICKEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5800 CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, Nicole M. Nickel, Defendant in the above action, hereby accepted service of the Complaint in Divorce on October a 2007. Date: f 0 J ( ?-? Nicole M. Nickel Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DANIEL W. NICKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-5800 CIVIL ACTION - LAW NICOLE M. NICKEL, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 26, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. § 4904 relating to unsworn falsification to authorities. q Date: I ' Daniel W. Nickel, Plaintiff C :EZ C= ,.} t rn " ca r ?r3 (Jl l C7 Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DANIEL W. NICKEL, Plaintiff V. NICOLE M. NICKEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5800 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301 (d) 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 waiver 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: 1 0 LOX- Daniel W. Nickel, Plaintiff .."- ; -. C-13 co -n 0 0 M M + f C7 F.\FILES\Clients\7122 Hyatt\331\7122.331. consent Created: 9/20/04 0:06PM Revised: 1/28/08 1:32PM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DANIEL W. NICKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-5800 CIVIL ACTION - LAW NICOLE M. NICKEL, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 26, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. § 4904 relating to unsworn falsification to authorities. Date: C 3b C)V Nicole M. Nickel, Defendant rv 0 r r3` rrs CD ?,. 4 Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff n K? DANIEL W. NICKEL, Plaintiff V. NICOLE M. NICKEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5800 CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301(d) 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 waiver 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: l 3b 00 Nicole M. Nickel, Defendant C c°ti ? i7 Cf1 ) "Z7 "1: F.\FILES\Client012: Hyatt\331\7122 . 331.pra Created. 9;'20/04 0.06PM Revised: 1/7/08 2 .:7PM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DANIEL W. NICKEL, Plaintiff V. NICOLE M. NICKEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5800 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Via Acceptance of Service on October 17, 2007, and filed on October 26, 2007. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; January 29, 2008; by the Defendant January 30, 2008. 4. Related claims pending: None. All claims have been resolved. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 6, 2008. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 6, 2008. MARTSON LAW OFFICES By a-?-. Thomas J. Willi s, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: February 7, 2008 Attorneys for Plaintiff m° ? ?? cxz r? t ? _ ,.,,? , . -` ? r ?... ? ?, ...? t + t t+++ t t+ t i i+ t+ i t+++ t+ i t++} t+++ i i+ 4+ t ++ +} } 4 t t t t t+} t t ------------------- --- ------ I N THE COURT OF COMMON PLEAS + + + OF CUMBERLAND COUNTY + + t t + + STATE OF PENNA. + t + + DANIEL W. NICKEL + + NO. 2007-5800 + i Plaintiff + VERSUS + t NICOLE M. NICKEL, + Defendant + DECREE IN + 4 + 4 + DIVORCE t + + AND NOW, IT IS ORDERED AND + + DECREED THAT DANIEL W. NICKEL PLAINTIFF, + + 4 + AND NICOLE M. NICKEL 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; + + NONE. + BY T COURT- + + ATTEST: J. + + + +"?, ?' PROTHONOTARY + .a .-