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HomeMy WebLinkAbout01-6576MANDY L. NEAL, Plaintiff SCOTT L. NEAL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 6q76, : NO. 2001- CIVIL TERM : : 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 MANDY L. NEAL, Plaintiff SCOTT L. NEAL, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-(ZK.~r~CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Mandy L. Neal, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Mandy L. Neai, is an adult individual who currently resides at 59 South High Street, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Scott L. Neal, is an adult individual who currently resides at 15 McBride Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 8, 2000 in Boiling Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The 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. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Mandy L. Neal, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Date: Respectfully submitted, Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX VERIFICATION I verify that the statements made in this Complaint are tree 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. MANDY I'0D~, Plaintiff MANDY L. NEAL, Plaintiff SCOTT. L. NEAL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6576 CIVIL TERM : : C1VIL ACTION - LAW : IN D1VORCE AFFIDAVIT OF SERVICE AND NOW, this 28th day of November 2001, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Mandy L. Neal, and states that he had cause to be mailed a certified copy of a Complaint in Divome to the Defendant, Scott L. Neal, by certified, restricted delivery, return- receipt requested. A copy of said receipt is attached hereto indicating service was made on November 27, 2001. Respectfully spbmijlm~ Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX $ ,7a7 · Print your name ~ so that we · Attach this card to the back of the mailpiece, or on the fTont if space permits. SCOT~ L. NEAL 15 M~B~IDE AVENUE CARLISLE, PA 17013 a. Rec~edby~%~ntCma,,y) s. DmeofD~k~y delNety addm~ different from item 1 ? i-lyes If YES, enter deliv~y address below: i-1 No 2. Ntic, ie Numb~ PS Form 3811, Marc~ 2001 3. Se~lce ~ype ~[Certifled Mail i-"l Express Malt 7099 3220 0009 5574 0439 MANDY L. NEAL, Plaintiff SCOTT L. NEAL, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-6576 CIVIL TERM : : CIVIL ACTION - LAW : 1N DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 21, 2001. 2. The marriage of the 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unsworn falsification to authorities. MANDY~lqgAL, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(0 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 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. § 4909 relating to unsworn falsification to authorities. Date: ~// /O0- ~~{/ MANDY I~AL~ Plaintiff MANDY L. NEAL, Plaintiff SCOTT L. NEAL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6576 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 21, 2001. 2. The marriage of the 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unswom falsification to authorities. Date: ~,-"/- 4rC-OT~. NEAL, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(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 ifI 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 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 tree and correct. I understand that false statements herein are made subject to the Date: [/~ /- ~,=:~falsificati°n' to authorities, penalties~7~~_,/~/~~jof 1,8'~a.~,~. § 5~909 relating to unsworn <~C6T~eL~. NEAL' IS~e~d ~nt MANDY L. NEAL, Plaintiff SCOTT L. NEAL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6576 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THEPROTHONOTARY: 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) 33~,i(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on November 27, 2001 by certified, restricted mail signed for by the Defendant. 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 the Plaintiff: March 1, 2002; by the Defendant: June 1, 2002. (b) (1) Date of execution of the Plaintiffs Affidavit required by § 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 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, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by § 3301(c) of the Divorce Code: by the Plaintiff: March 1, 2002; by the Defendant: June 1, 2002. Date: June6,2002 ~~ Thomas S Diehl,' Esquire Attorney for Plaintiff iN The cOUrT Of COMMON pleas OF CUMBERLAND COUNTY STATE OF MANDY L NF:AL; Plaintiff VERSUS SCOTT L_ NE_AL, Defendant PENNA. NO. 2001'6576 DeCrEE IN AND NOW, DECREED THAT DIVORCE MANDY L. NEAL · IT IS ORDERED a~D , PLAINTIFF, AND SCOTT L. NEAL , 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_ ATTEST: //~~r OTb O N OTA ~'