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HomeMy WebLinkAbout91-0763IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOTICE TO DEFEND AND CLAIM RIGHTS MANDATED BY R.C.P. 1920.71 NORMA M. OLSEN : Civil Action - Law vs. i No. ROBERT A. OLSEN : Action in 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, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-5387. 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. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle PA 17013 1-(717) 697-0571 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA M. OLSEN : Civil Action - Law ROBERT A. OLSEN : Action in Annulment COMPLAINT 1. Plaintiff is Norma M. Olsen, who currently resides at 400 North Market Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Robert A. Olsen, who 249 Bradley Avenue, State College, Centre 16801. currently resides at County, Pennsylvania, 5. The Parties 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 the defendant were married on February 25, 1989 in Centre County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is voidable and subject to annulment for the reason that defendant is and was naturally and incurably impotent at the time of the marriage, which condition was not known to plaintiff prior to the marriage, all in accordance with ~205(a)(4) of the Pennsylvania Divorce Code. 7. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. annulment on Code. Plaintiff requests the court to enter a decree of the basis of §205(a)(4) of the Pennsylvania Divorce I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made sub,eot to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: / ~/' ..2 .~ · Plai~ff NORMA M. 0LSEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ROBERT A. OLSEN, : No. 765 CIVIL 1991 Defendant : Action in Annulment DECREE OF ANNULMENT AND NOW, this 3~) day of ~~--~. , 1991, it is ordered and decreed that the marriage of Norma M. 01sen, Plaintiff, and Robert A. Olsen, Defendant, be, and the same hereby is, annulled and voided. The Court retains jurisdiction of the following claims which have been raised ofyrec°rd ~ ~ action final order has not yet been e.~ered:/ ?. J. Attest: Prot~onotars/ ~- for which a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. NORMA M. OLSEN Plaintiff vs. No. 763-Civi1-1991 F, DBERT A. OLSEN Defendant Civil 19 91 It appearing that the Master's report in the above stated case has been filed for ten days, that no exceptions have been filed thereto, that the costs have been fully paid and that all the requirements of law and Rules of Court have been met, you are hereby directed to submit the said case to the Court of Common Pleas of Cumberland County, Pa., at the next sitting thereof. Attorl~'v for i'ln[ntifr. Prothonotary Dated I, OUghtS, d~ Prothonotary of the Court of Common Pleas of Cumberland C hereby certify that the costs in the above stated case, have all been paid, including the Master's fee. ~5~ . PrOthonotary. NORMA M'. OLS~N, Plaintiff ¥o ROBERT A. OLSEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 76S CIVIL 19 91 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court a decree of annulment: for entry of ~ 4ivoroo dooroc: annulment: impotency under Section 1. Ground for-4-i-w~e, i~e~rievabl~ b~akdG~,, umdcr Ccction (201(c)) (20~<d) (1) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner 'of service of the complaint: Certified mail March 19, 1991 B. (Complctc cithcr paragraph (a) or (b) .) (a) Date of execution of the affidavit of consent required b~ e~ction 33ol ~ -~8~(c) of the Divorce Code: by the plaintiff by defendant ~ (b) (1) Date of exec~laintiff's affidavit required by 3301 ~ Section ~8~(d) of~l)ivorce Code: , · -~-~ ....... (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file 330~ praecipe to transmit record, and attach a copy of said notice under section ~I (d) (1) (i) of the Divorce Code. Attorney for (Plaintiff) (Defendant) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, NORMA M. OLSEN VS. ROBERT Ao OLSEN PENNSYLVANIA CIVIL ACTION - LAW NO. 765 CIVIL 1991 ACTION IN ANNULMENT AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK SS: Personally appeared before me, the undersigned officer, a Notary Public in and for said County and Commonwealth, Joel 0. Sechrist~ Esquire, who being duly sworn according to law, doth depose and say that he caused a true and correct copy of the Complaint in the above cited case to be served upon the defendant~ Robert A. Olsen, by delivering same to the United States Post Office at Lewisberry, Pennsylvania, on March 14, 1991, and mailing said Complaint by certified mail number P825 751 807 copies of the receipt for certified mail and return receipt card being attached hereto. SWORN and SUBSCRIBED to before me, this~ day CUMBERLAND COUNTY, ss: THE COMMONWEALTH OF PENNSYLVANIA, [Commission to take Testimonyl ................................................ GREETING: Know you that in confidence of your prudence and fidelity, we have appointed you, and by these presents do give unto you full power and authority, in pursuance of an orde~ made in our County Court of Common Pleas for the County of Cumberland in a certain cause there depending wherein ............................................ .............................. _N_o_ .r~_ .a_ .~_. _ _0_1_~ _~_n_ ........................ Plaintiff ................ and .............................. - ............................................................. Robert A. Olsen ............................. Defendant , to calL ............................................... before you at a certain day and place by you for that purpose to be appointed, all and every person who may be named by you on the part of the ----P--1-a.'.lan-~-i-~.f-..an-.d__-l~--~.~-n-d-a--n~ .................................... as witnesses in the said cause, and then and there to examine each of the said witnesses upon their oath or solemn affirmatima touching the pr~mlses, and reduce their testimony to writing; and when you shall have done so, you are to send the ~me bc4ore our Judge at Carlisle, at our said Court, together with this writ and a report of the proce~ding~ before you and your opinion of the ease under your hand and seal. IN TESTIMONY WHEREOF, we have caused the seal of our said Court to be hereunto affixed. WITNESS, the honorable ___H__a~'__o~_d___Ez__S_h__e_e_lv ............... President Judge of our said Court at Carlisle the ____8.1;.h_ ............. day of ..... a~.Ll~. .................. in the year of our Lord one thousand nine hundred To the Honorable the Judge. Prothonotary. The execution of this commission appears in a certain schedule hereunto annexed. .......................................... (Seal) IVfaater. ' IN T~E COURT OF COM~-ON PLEAS OF CL%MBEILLAND COUNTY, p~"TNSYLVANIA NORMA M. OLSEN Plaintiff VS · RCBER7 A. OLSEN NO. 763 Civil MOTION FOR APP0tNT~%NT OF MASTER Norms M. Olsen (Plaintiff) a mas=er with respect Co the following cla~-: ( ) Divorce ( x ) Annulment ~( ) Alimony ( ) Alimony Pendeute LiCe a~x~ in support of the motion states: moves the court to appoint Distribution of Propert? Support Counsel Fees Costs and Expenses (1) Discover7 is complete as Co the claims(s) for which the a~ointment'of a master is requested. ,r- (2) The defendant (base-(has not) appeared in the action (personally) (by his a~rney, ,Esquire). , (3) The statutory ground(s) for divorce (is) (are) AnnUlment §205 (a) (4) (4) Delete the inapplicable paragraph(s): (a) The actio~ is not co~tested. or fact. (c) The action is contested wi~h respect to the following (5) The action (~vetv~s~ (does uot involve) complex issues of law (6) The hearing is expected to taka 1 (hours) (7) Additional information, if any. relevant to :he motion: Date: 5/23/91 A~e.v for (P~15609 ORDER ~POINTING ~S~R is appo~:e~sC~ ~ch respect :o :h~follow~g cla~s: ~ ~ ~'~ By the! Court: NORMA M. OLSEN, Plaintiff ROBERT A. OLSEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 763 CIVIL 1991 Action in Annulment plaintiff; Joel 0. Sechrist, defendant, as indicated by Master's Report. PROOF OF NOTICE OF MASTER'S HEARING AND FILING OF MASTER'S REPORT COMMONWEALTH OF PENNSYLVANIA) : ss. COUNTY OF CUMBERLAND ) J. Wesley Oler, Jr., Master in the above-captioned matter, being duly sworn according to law, deposes and says: That he gave notice of the Master's hearing by ordinary mail on July 20, 1991, to the plaintiff~ Joel O. Sechrist, Esq., plaintiff's counsel; and the defendant, as indicated by the attached Notice; and That he gave notice of the flling of his report, including its recommendations, by ordinary mail on August 29, 1991, to the Esq., plaintiff's counsel; and the the attached Notice of Filing of Jr/wesley 01~, Jr. ,~sq. M~/ster Sworn to and subscribed before me this ~ day of d~Lc~ 1991. NORMA M. 0LSEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : ROBERT A. 0LSEN, : No. 765 CIVIL 1991 Defendant : Action in Annulment NOTICE OF FILING MASTER'S REPORT NOTICE IS HEREBY GIVEN that the undersigned Master has this date filed his report and recommendations in the above matter. A copy of the same is enclosed. Withln ten days after the mailing of this notice, excep- tions may be filed by any party to the report or any part there- of, to rulings on objections to evidence, to statements or findings of fact, to conclusions of law, or to any other matters occurring during the hearing. If no exceptions are filed to the Master's report the ten-day period, the Court will review the report and, is approved, will enter a final decree or decrees. Dated and Mailed: COPIES TO: Norma M. 01sen C00 North Market Street Mechanicsburg, PA 17055 Joel 0. Sechrist, 568 Old York Road Etters, PA 17519 Esq. Robert A. Olsen 299 Bradley Avenue State College, PA 16801 Bulletin Board Frothonotary's Office Cumberland County Courthouse within if it NORMA M. OLSEN, Plaintiff ROBERT A. OLSEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 763 CIVIL 1991 CIVIL ACTION - LAW IN ANNULMENT NOTICE YOU ARE HEREBY NOTIFIED that pointed to take testimony and file Tuesday, August 27, 1991, at 1:30 the undersigned Master ap- a report thereon has fixed p.m., at his office at 37 as the time and at which time and if you so desire. South Hanover Street, Carlisle, Pennsylvania, place for taking testimony in the above case, place you and your witnesses may appear Carlisle, Pennsylvania Dated: July 20, 1991 COPIES TO: Norma M. Olsen 400 North Market Street Mechanicsburg, PA 17055 Joel 0. Sechrist, 568 Old York Road Etters, PA 17319 Esq. Robert A. 01sen 299 Bradley Avenue State College, PA 16801 Bulletin Board Prothonotary's Office Cumberland County Court House WesleYMastvrOi~, Jr., ~'.' NORMA M. 0LSEN, Plaintiff ROBERT A0 OLSEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW : : No. 765 CIVIL 1991 : Action in Annulment MASTER'S REPORT TO the Honorable Judges of the said Court: The Master appointed by Your Honorable Court to take testi- mony of witnesses and return the same, together with his find- ings of fact and conclusions of law, respectfully submits the following report: I. PROCEDURAL HISTORY OF CASE 1. The Complaint in Annulment was filed on March 7, 1991, requesting an annulment based upon a natural and incurable impotency on the part of the defendant at the time of the mar- riage, and still extant, which condition was not known to plaln- tiff prior to the marriage. 2. The Complaint was served upon the defendant on March 19, 1991, by certified mail at his residence in State College, Pennsylvania. 3. On July 8, 1991, J. Wesley Oler, Jr., was appointed Master in the case. 4. A hearing was held by the Master on August 27, 1991, at which time the plaintiff and her counsel appeared; neither defendant nor a representative of defendant appeared. Notice of the hearing had been sent by ordinary mall to the partles and plaintiff's counsel on July 20, 1991. -1-