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Home My WebLink About04-0666 HAROLD S. IRWIN, III, ISQUIRI ATTORNIY ID NO. 2lIlI20 114 SOUTH Pin STRlIT CARLISLI PA 17013 (717) 24U080 ATTORNIY POR PLAINTIFF CURTIS L. NIIILSIIN, Plaintiff : IN THII COURT OF COMMON PLUS OF : CUMBIIRLAND COUNTY, PIINNSYLVANIA v. : CIVIL ACTION - LAW I I NO. 04 - t.!oc. CIVIL TIIRM : CUSTODY M. CHARLIINII NIIILSIIN, D.fendant 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 -. CURTIS L. NII!LSI!N, Plaintiff I IN THI! COURT OF COMMON PLUS OF I CUMBI!RLAND COUNTY, PI!NNSYLVANIA v. I CIVIL ACTION. LAW M. CHARLI!NI! NII!L8I!N, D.fendant . . I NO. 04 . ~ CIVIL TI!RM I CUSTODY COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301 (d) OF THE DIVORCE CODE NOW, comes the plaintiff, Curtis L. Nielsen, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Curtis L. Nielsen, an adult individual residing at 5 Westgate Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is M. Charlene Nielsen, an adult individual with a mailing address of P. O. Box 1121, Winnemucca, Nevada 89446. 3. The plaintiff has been a resident 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 October 17, 1986, in Roberts, Idaho. 5. Pursuant to the Divorce Code, Section 3301(d), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken and that the parties hereto have lived separate and apart for a period of at least two years. The parties have lived separate and apart since December, 2000. 2 - 6. The plaintiff avers that she has been advised of the availability of counseling and that said party 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 parties and for such further relief as your Honorable Court may deem equitable and just. J verify that the statements made in this complaint 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. February .-t., 2004 (/~L CURTIS 1. NIELSEN, Plaintiff HAROLD S. IRWIN, III Attorney for plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 3 CURTIS L. NIIlLSIlN, PlaIntIff : IN THIl COURT OF COMMON PLI!AS OF : CUMBIlRLAND COUNTY, PIlNNSYLVANIA . . v. : CIVIL ACTION - LAW : M. CHARLIlNIl NIIlLSIlN, Defendant : NO. 04 - : CUSTODY CIVIL TIlRM NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in December, 2000, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. of 4904 relating to unsworn falsification to authorities. February 4. 2004 cL tJ CURTIS L. NI:Ls~~ntiff 4 ~ A(\ ~ ....., ~\ - .J: ~ ~ ~ 6' \.0 G \1"\ ',j\ u, W G ~J '" => c:-::) "'''' --" P1 co _J -~ r:"? _~ C't C n ""T'l --I :1: _ fll_-,J -r'1~Tl ~X~J ~; -H C:i rn CURTIS L. NIELSEN, Plaintiff : IN THE COURT Ic)F COMMON PLEAS OF : CUMBERLAND C:OUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW M. CHARLENE NIELSEN, Defendant : NO. 04 . 0666 CIVIL TERM : CUSTODY AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 a 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 amended complaint in divorce was served upon the defendant on or about February 23, 2004, by certified mail, addressed to the defendant at p. o. Box 1121, Winnemucca, New York 89446, return receipt No. 7002 2410 0007 8504 4385. 3. That a copy of the 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 are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsific ion authOl'ities. May 3, 2004 Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17C113 717-243-6090 Supreme Court 10 No. 29920 LO <0 m :T :T e LO <0 l"- e e e e r-'I :T ru ru ~ ~~::::r;,,-~~~-~:..~.,:!-~-~_._,.._,,,,..._.__._... citY:.stBi8;Z1P;:;;.uuu:uu....nnnnu __u_u. "nun_un__...._._..o..__.__ 1.0 ll'll'\ -e... ~ ec. 1\1 " 'i'q Y U.S. Postal Service" CERTIFIED l\1I.^!!.." RECEIP'f (Domestic Mail Only; No Insurance Covera ProvIded) .' . , '. !.l;j'''''1IlOlOIU I OFFICIAL USE _e $ j,'l'l 'LIt? Certified Fee 2.3D 1 Re"m - Fee 1.75 - (Endorsement RequIred) He.. { Aes.r1cted Delivery Fee 3.50 (Endorsement Required) Total Postage & Fees $ ~.~~ . Complete Items 1, 2, and 3. Also complete item 411 Restricted DellvOf}' Is desired, . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back 01 the mailpiece, or on the front il space pannlts. 1. Article Addressed to: o Agent o Addressee CQ:'a.~r o. Is deliverf address different from Item 1? 0 Yes If YES, enter delivery address below: 0 No 'itf M, Ch~\ene N\e.\se~~ ~. o. Bo~ \ 1'2 \ vJ; ",,,e. (Y\.\I cc.2I.. I N V Cll t'r~ 3. Service Type ~Certified Mail tJ Registered 1= o Express Mail o Return Receipt for Merchandise .0.0, 2, Mlcto_ ~....._~ PS Fonn 3811 , August 2001 7002 2410 0007 &504 43&5 DomesticRettwn Receipt 102595-02-M-<ll!35 EXHIBIT "A" .~~ ( l ) ~ -.,.. z-' i: 055 -< I ;:>""- c..J ::;::c ~c 3I 5>0 c::: ry ~ 0 -..J ( f ) " , J ...., ~ .c-- !fl ~:t! 'r- :-om ,~? :.::,0 .....,-. --. .I:;:'?~~ -~ Tn ;;5 :~ HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-8090 ATTORNEY FOR PLAINTIFF CURTI8 L. NII!L81!N, PI.lntltf I IN THI! COUR1' OF COMMON PLl!A8 OF I CUMBI!RLAND COUNTY, PI!NN8YLVANIA v. I CIVIL ACTION. LAW M. CHARLI!NI! NII!L81!N, Defend.nt . . I NO. 04. (.(.'" CIVIL TI!RM ICU8TODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint and agreement for custody, representing as follows: 1. The plaintiff is CURTIS L. NIELSEN, an adult individual residing at 5 Westgate Drive, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is M. CHARLENE NIELSEN, an adult individual with a mailing address of P. O. Box 1121, Winnemucca, Nevada 89446. 3. The parties are the natural parents of a minor daughter, namely SHAUNTAE NIELSEN. (born April 7, 1987, age 16). 4. The child resided with both of the parties from her birth until the defendant left the marital home in December, 2001. The child has resided with the plaintiff since that time. 15 5. The plaintiff has not participated as a party, witness or in any other capacity in other litigation concerning the custody of the child in this or another court. 6. The plaintiff has no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 7. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The plaintiff believes and therefore avers that Ilhe best interests and permanent welfare of the child require that the parties have joint legal custody of the child, that the plaintiff have primary physical custody of the child and that the defendant have temporary physical custody and visitation of the child in accordance with the parties' mutual agreement. 9. Both parties, as evidenced by their joint execution of this complaint, have mutually agreed upon an amicable arrangement for the legal, physical and temporary custody of the child and request that the Court enter an order as provided below without the necessity of a hearing: A. The parties shall have joint legal custody of their minor daughter, SHAUNTAE NIELSEN (born April 7, 1987, age 16). B. Father shall have primary physical custody of the child. C. The Mother shall have temporary physical custody and visitation of the child as the parties may mutually agree. D. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. 16 E. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. F. The parties shall do nothing that may 'estrange the child from the other party or hinder the natural development of the child's love or affection for the other party. G. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agre'3ment of the parties. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. H. Any modification or waiver of any of th'e provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. I. The Court of Common Pleas of CumbElrland County, Pennsylvania has jurisdiction over these issues and shall retain such jurisdiction should circumstances change and any party desire further or require further modification of said Order. WHEREFORE, the plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. JIII-f G, .2004 17 VERIFICATION AND CONFIRMATION OF AGREEMENT We do hereby verify that the acts set forth in this complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.SA 9 4904, relating to unsworn falsification to authorities. Furthermore, by the execution of this Confirmation, we do each unequivocally express our mutual and voluntary agreement to the amicable custody arrangement provided above and request that the terms thereof be entered as an Order of Court without the necessity of a custody conciliation, hearing or other proceeding. /'vJ/1 Y ~ .2004 -, ff // '/y C ~,.N C EN (SEAL) QpiJ In .2004 (SEAL) \ 18 '. COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this (;r.. day of /vi A L I " 2004, CURTIS L. NIELSEN, . ( known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunt~et my hand and official seal. STATEOF::J;lEV A:JJ1&-. :SS: COUNTY . ;)UA46tJLb T. PER~?~~~~ Y d'AAPPEARED BEFORE ME, a notary public for Gum130Fland [/11vy County, ~f{his -LiL.. day of C~ _' 2004, M. CHARLENE NIELSEN, known to me (or satisfactorily Pro~l the person whose name is subscribed to the within agreement, and acknowledged that she executed the same for the purposes therein contained. ___''':_~:E_=_~::_=:~~ I :~~:~"~OO ~d~ ~ FRANCES R PETERSON ~ ~_ _ _ _ ~ ' Notary Public, State of Nevada ~ Notary Public Appointment Recorded in Humboidl County ~ No: 93-1790-9-Ex.pires August 3, 2005 : 19 '"';"1" !-'':~i G! ~',; C..:, >(' '-9 ~ (') C :;..-.; ....., = = .r- ::!rJ: :.0:.'",' -c I -.l ~ .... I., fl1l= -0 rrl CO? 0... ---ll.,J :J: ,. C')::;,] ,",0 O:.q ~... ,,> ~D ,<; :0 r:? w CURTIS L. NIELSEN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 04-666 CIVIL ACTION LAW M, CHARLENE NIELSEN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 12, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 11, 2004 , the conciliator, at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order, The court hereby directs the parties to furnish auy aud all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinll:. FOR THE COURT, By: Isl Hubert X. Gilroy. Esq. Custody Concilialtor mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 ~ ~# ~ ~.;'fP'/~.? ,,~~ /"17 :;p"y ~u; fZ.-n 'P"~"" ~ -n ~-F~ ~ - .1c7- C/.,.> ~(/. 0...> ~O. ['/ :-> VIN\iiOASi\J~(Jd UN'~"~ ,.. ." '~~'iJ\)'~J I 'I 'i j, I f ~;,,,-: ,:+';H' ; I "."'- -, ',' .'... '",', II zz :~ lid t: I AVj,JIiOUZ Abvl0NOHlOUd 3Hl :10 3:JL:!:lO-G31!:! CURTIS L NIIIUIIN, Plaint... I IN THII COURT OF COMMON PLIIAII OF I CUM.IIRLAND COUNTY, PIINNSVLVANIA . . Y. I CIVIL ACTION. LAW . . M. CHARUNII NIIIUIIN, ""'ndant I NO. 04 . 0188 CIVIL TIIRM I DIVORCII 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 February 17, 2004. Service of the complaint was made on or about February 23,2004 (see Affidavit of Service filed May 3,2004). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I 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. understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. ...- AUGUST~, 2004 ~ CURTIS L. NIELSEN r 0" i :~:; -(" c! -" c.rr to> ....., C':".) C J -,,- C) -" --:J ~:'j;~~.r :-r7~!"! "t."J :.: -'! .Co, :r"i"; . , -- ,. l:) :.:, -...: CURTIS L NII!L8I!N, PI.lnt... IIN THI! COURT OF COMMON PLI!A8 OF I CUM.I!RLAND COUNTY, PI!NNSYLVANIA v. I CIVIL ACTION - LAW M. CHARLI!NI! NII!L8I!N, D.rend.nt I I NO. 04 . 0188 CIVIL TI!RM I DIVORCI! 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights conceming 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 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 unswom falsification to authorities. CURTIS L. NIELSEN ---- August L. 2004 n " ',' "j,-. c. ~.. -:::, ..( ......' .'-:~ l.".) .L- C:.. -n -., ."f.'r" \;)f" -7.':"1 ;i.' ~l' . 'f' ~ . \ " ~~{~ ...r.' ~.<~ :.~ ~ ....0 -- c.." c.> ,': ~ CURTIS L NIIIL8I1N, PI.lnt... I IN TNII COURT OF COMMON PL1!A8 OF I CUM.IIRLAND COUNTY, PIINN8YLVANIA . . v. I CIVIL ACTION. LAW . . M. CHARLI!NII NIIIL8I1N, Defenant I NO. 04 . 0188 CIVIL TIIRM I DIVORCII PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 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. I 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. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. "guo, ~.... c / / CURTIS L. NIELSEN ).-.,~: ,- ::'.i- -< Q ....., C.:> ~-= o -iJ .-< :1:-n lllr:- .~~ :..;.~ ~"': " ...... \.D . ; (~.~ -,.., . ~ . -,, : {. ~ .-:'11 <.n w < '.~l :..:J CURTIS L NIIIL8I1N, Plalntl" I IN THII COURT OF COM.ON PL1!A8 OF · CU.BIIRLAND COUNTY, PIINNSVLYANIA Y. I CIVIL ACTION. LAW . I NO. 04 . 0188 CIVIL TIIRM . DIYORCII M. CHARLI!NII NIIIL8I1N, Defendant 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 February 17, 2004. Service of the complaint was made on or about February 23,2004 (see Affidavit of Service filed May 3,2004). 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. I 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. AugustD, 2004 0 "" r::..... C. ( .:....,1 -n ..... ~ . _.~, . :T:_ l."'; ~:~F~! u; .. -- 1 :..~: (~~ - , , - " ~; i : -- " /- :~ c.n :.q w CURTIS L. NIIlLaIlN, PI.lntlfl Y. I IN THII COURT OF COMMON PL1!A8 OF I CUMBIIRLAND COUNTY, PIINNSYLVANIA I I CIVIL ACTION. LAW . . M. CURLIINII NIIlLaIlN, Defen_nt I NO. 04 . G888 CIVIL Tl!RM I DIVORCII JbI~B Q.f.JiIOTIGI OtltgEN't.I2tlDL.BImIm 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights conceming 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 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 unswom falsification to authorities. AugustO.. 2004 (! ...-> CJ , ~, , ':..~ -, 1 .. .. .. . ::? .0..1' ,'. , .' .- .....-. ~ - ..-1:.." , .;~J \.D ,. ii.., ; , -, " , ., , ,. , '. ., n '. " ~..~\ U'I ." , -~ V; CURTIS L. NIIlLaIlN, PI.lntlff I IN THII COURT OF COMMON PLUS OF I CUM.IIRLAND COUNTY, PIINNSYLVANIA Y. I CIVIL ACTION. LAW . . M. CHARLIINII NIIlLaIlN, D...nd.nt I NO. 04 . ... CIVIL TIIRM I DIVORCII 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. I 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. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Au9ustj2.2004 r~ ':-' ( .:) ,-- -n J_- .--\ - '. :j"- .. I , i - ...; ~:~ ~~.} c:; , , , ", , .. --r-: -,' " , , , , " : ... ~ .:;... ::~ VI :..~ -<-. W - HAROLD S. IRWIN, III, ESQUIRI! ATTORNEY ID NO. 28820 14 SOUTH PITT STREET CARLISLI! PA 17013 (717) 243-8080 ATTORNEY FOR PLAINTIFF CURTIS L. NIELSEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL ACTION - LAW . . M. CHARLENE NIELSEN, Defendant : NO. 04 . 0666 CIVIL TERM : 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: On or about February 23, 2004, defendant was served with a copy of the divorce complaint (See Affidavit of Service filed May 3, 2004). 3. 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 5, 2004 By the defendant: August 10, 2004 (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 plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None 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: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: August 19, 2004 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: August 19, 004 /J ~?~' August 19,2004 HAROLD S. IRWIN, III Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . STATE OF CURTIS L. NIELSEN, PENNA. Plaintiff No. 04 - 0666 Civil Term VERSUS M. CHARLENE NIELSEN, Defendant DECREE IN DIVORCE t f.{~ r;s-(J/A . AND NOW, 2004 , IT IS ORDERED AND DECREED THAT Curtis L. Nielsen , PLAINTIFF, AND M. Charlene Nielsen , 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. . J. .~ 1Z' /f?""'OV ~H, ~ ~!?- ~ '~1V -4v1 -/W - . . . . "'\ ..~. fI'.1Io........ . .,- ,. . A(/, 0,,9 ,J,(J. ~/. b SEP 0 5 200~ CURTIS L. NIELSEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYL VANIA vs. M. CHARLENE NIELSEN, Defendant NO. 04-666 CIVIL ACTION _ LAW IN CUSTODY ORDER AND NOW, this rvtr day of September, 2006, the above case being previously assigned to the Conciliator and thcrc being no activity on this case for a period of six months or more, the Conciliator relinquishes jurisdiction. a- Hubert X. Gilr , Esquire Custody Conciliator --' ,'.-' q" '"' '~<'V\Jl !<,J no . 'I \ 1'1 t) i . 1 ;':i1:-: g_ ,n~ ()f1\I' _ '1_''-' JU,A.. v