The URL can be used to link to this page

Home My WebLink About08-5682{ 4% DAVID C. WAGNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW KRISTY L. WAGNER, :NO. S??a CIVIL TERM Defendant : 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NO'(' HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 Phone: (717) 249-3166 or (800) 990-9108 r, DAVID C. WAGNER, Plaintiff V. KRISTY L. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. b ?- 54 Qz-- CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is David C. Wagner, an adult individual currently residing at 42 Fickes Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Kristy L. Wagner, an adult individual currently residing at 40 Crestwood Lane, McClure, Mifflin County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 22, 2004, in Frederick County, Virginia. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Hannah Herman Snyder, Es uire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: -9 /a3/0i' DAVID, WAGNER, Plaintiff ? ? ? ?. ?. ?. ? t w w u 1? ? Cl c..:; ,.?_.. ?.? .? _??-? N ??,.? cs? ? ??-, .?, ; ?, :? -, ??-t ? -.`6 DAVID C. WAGNER, Plaintiff V. KRISTY L. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2008-5682 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Hannah Herman-Snyder, Esquire, counsel of record for Plaintiff, state that a true and attested copy of a Complaint in Divorce was sent to Defendant, Kristy L. Wagner, at her address of 40 Crestwood Lane, McClure, Mifflin County, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on October 10, 2008. Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this & M day of 2008 NO RY BLIC .wrnr? ?-, ?, ?.. .. ,. ,: ?N ?. • - . ru O For delivLry information visit our website at www.usps.com OFFICIAL USE, I .D VIA lo, Postage Certified Fee d Retum Receipt Fee Q (Endorsement Required) d ResMeted De (Endorsement Rliveery Fee quired) ? ru Total Postage & Fees $ t O Sent To o u?tr?3t --- ?--- 70? 'C - APt. - O or PO Box NoTV City SSAtiki ----- - r ¦ Compido ftm 1 2, and 3. Mao mrvk e Item 4 it Ra*iftd DeBvery Is deWmd. ¦ Print your -name and address on the tweree so the we start Mum fJ're curd to you. ¦ AttWh this cod to the back of the mak)lece, or on the faart if space pem*L 1. Artlde Addressed to: Arjsl L- - WZn r 4?b Ccl e Ad / 7Sy? A. gap" Ix fh,&? ? Agent ttti'?PriVrledNam* - C. Date# Do" I M6 G' l O o Is a?3ses nt *cm item 1? E3 Yef If YES enter ddtmyt addmn below: ? No r S. Servioa Type JSCertltNd MaN O Express Md ? Ro toed i# %k m Receipt for Marc wWbs O k0sw Mid ? C.O.D. 4. Reslrkted Deewpr? Aft Fssd Iff yes ArUcW xrber 7007 0220 01]Q2 2526 6025 PS Form 1811,Fe Dp nm* ftown Reodtrt 1tt qry .- C'? P?" `.?' ; r :? : a --i ?,?, ,,,_, -..t r? ` ? ?? ? ? ?? DAVID C. WAGNER, Plaintiff V. KRISTY L. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-5682 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on September 28, 2008, end service °vas --n-de on Octaber 10, 2008 by ;c.stilcted delivery, certified mail. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING 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: 46 Cy xjav-CA 641--J? J C DAVID C. WAGNER, Plaintiff na ? F ? '1 7 ,c..,? . i DAVID C. WAGNER, Plaintiff V. KRISTY L. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2008-5682 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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 ''v SWGniv r lxLS FICAT!Oiv T O AU irnGi?i i I-C,3. DATE: ?9 0C gJagw-41 DAVID C. WAGNER, Plaintiff CZZ) ? C17 _? L .,.. C.} e j I DAVID C. WAGNER, Plaintiff V. KRISTY L. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2008-5682 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on September 28, 2008, and service was made on October ; 0, 200E by restricted. delivery, certified mail. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING 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: ? il, ad-1 KRIST L. WA ER, Defendant r?°, ?:'? ??? - ? ;:_.. ;.? ?_ s`-. . '? ??: t;? - {°: ? `` ?.? .?: ?.? ?. , DAVID C. WAGNER, Plaintiff V. KRISTY L. WAGNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW NO. 2008-5682 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in aivorce 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 THE FOREGOING 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: J?bSC KRIST L. WAG ER, Defendant C`? r.a t: :. 3 _ ?..? G.., " '? °? - » - Tea? f.?J :.ay r DAVID C. WAGNER, Plaintiff V. KRISTY L. WAGNER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 08-5682 CIVIL TERM 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 §3301(c) 3301(d)(1) of the Divefee Gede. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on October 10, 2008. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: January 20, 2009 by Defendant: January 14, 2009 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: January 23, 2009 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: January 15, 2009 "A c??. ?. a k NA du .d1,.>` Hannah Herman-Snyder, Esqui GRIFFIE & ASSOCIATES Attorney for Plaintiff {0.""5 ? :;_,? - ,ra _ C?. _..{ ?? " _ --.,# ""i? c,. t DAVID C. WAGNER, V. KRISTY L. WAGNER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5682 DIVORCE DECREE AND NOW, . f?? O*k % 008 , it is ordered and decreed that DAVID C. WAGNER, , plaintiff, and KRISTY L. WAGNER , 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 By fkre Court, Attest: ?J. r.- Prothonotary V,?? -.,, p?0