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HomeMy WebLinkAbout08-39910 ANGELA M. MANN, vs. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA No. O k- 3 9,?/ Civil Term CHARLES F. MANN, II Defendant 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 ANGELA M. MANN, Plaintiff vs. CHARLES F. MANN, II Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 65--)M Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Angela M. Mann, a competent adult individual, who resides at 5509 Mooreland Court #4, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Charles F. Mann, II, a competent adult individual, who resides at 5509 Mooreland Court #4, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 24, 2006 in Bellefonte, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I 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. §4904 relating to unsworn falsification to authorities. Respectfully submitted, Date: ? -76 g J e Adams, Esquire 7a No. 79465 W. South St. rlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ??? .? ?? ?:. ?, ?? ? "` '° °? ?u ?' d ANGELA M. MANN, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. ©?- 3CJ0` \ Civil Term CHARLES F. MANN, II ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE The undersigned Constable, upon oath, deposes and says: I served Defendant, Charles F. Mann, II, of 5509 Mooreland Court #4, Mechanicsburg, Pennsylvania, 17055 a copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT, in the above-captioned action, as follows: Date Served: ? /? /P 0.1 Time Served: <Z'.1 I',, Person Documents Delivered to: Location where served: Signed: Lindsay d before me this Sworn to and Subscrib3uly 9?dayof 2008. % Lut M. b&uj- Not Public COMMONWEALTH OF PENNSYLVANIA NotarW Seal Julie M. Good. Notary Pubes Cartlsle Boro, CumberlwW C ur ty My Carmt sion E*km Dec. 4 2019 Member, Penne0varria As"Clation of Notaries ? . { 4 ryny ?: i 7 '??ar?.I} VrxR ANGELA M. MANN, vs. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CHARLES F. MANN, III Defendant No. 08 - 3991 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on July 7, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 01 105107 Charle F. M n, III Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 consent to 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 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 re ting sworn falsification to authorities. Date: o f l Q S/ Q 9 I ` Ch s F. Vann, Defendant ev ? r-?: - ? ^ - , . ? -- -,, '? ,?? C ._ - 1-rl :? ?' ='? ANGELA M. MANN, Plaintiff vs. CHARLES F. MANN, II Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08 - 3991 Civil Term ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on July 7, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating unsworn falsification to authorities. Date: 1, 1, ; WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND §3301() OF THE DIVORCE CODE 1. 1 consent to 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 verify that the statements made in this affidavit ar K?d stand t false statements herein are made subject to the penalties of 1 a.lati to u sw f I sificE to authorities. Date: Angel laintiff rv <?? Ya3 co '< ANGELA M. MANN, Plaintiff vs. CHARLES F. MANN, II Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08 - 3991 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to 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 of the Divorce Code. 2. Date and manner of the service of the Complaint: Served via Constable, on July? 2008, Affidavit of Services filed July 10, 2008. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: January 14, 2009. By Defendant: January 5, 2009 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 14, 2009. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 15, 2009. oe,e W1o9 Respectfully J Adams, Esquire 1. 0.79465 1 South St. Car isle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff rry?_ co w IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANGELA M. MANN, Plaintiff V. CHARLES F. MANN, II, Defendant NO, 08 - 3991 Civil Term DIVORCE DECREE AND NOW, it is ordered and decreed that ANGELA M. MANN, Plaintiff plaintiff, and CHARLES F. MANN, II, Defendant , 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.") None. the Court, Attest: J. Prothonotary G??: ? ,1 _., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x' j --F6nor to the entry of a Final Decree in Divorce, or JZ after the entry of a Final Decree in Divorce dated 1 'OL ate hereby elects to resume the prior surname written notice avowing his / her intention Date: oc D COMMO TH OF PENNSYLVAt COUNTY OF On the day of"'?? , 20 I_, before me, the Prothonotary or the notary public, personally apperh affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. (I .? ' NOTARIAL SEAL Notary Public TINA L FULLERTON Notary Public LOWER PAXTON TOWNSHIP DAUPHIN COUNTY [My Commission Expires Jan 19, 2011 d w? N©