The URL can be used to link to this page

Home My WebLink About09-0776AL F. STETLER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. -771- CIVIL TERM 'ENDY S. STETLER, Defendant 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 that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, OU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO OT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 (717) 249-3166 SNELBAKER & BRENNEMAN, P.C. By: Attorneys for Plaintiff LAW OFFICES SNELBAKER & BRENNEMAN, P.C. , i VAL F. STETLER, II, V. S. STETLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. O 9' 7 7 L CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE. Plaintiff Val F. Stetler, 11, by his attorneys, Snelbaker & Brenneman, P. C., hereby bmits this Divorce Complaint as follows: COUNT I DIVORCE 1. Plaintiff Val F. Stetler, II is an adult individual residing at 70 Springers Lane, New Cumberland, York County, Pennsylvania 17070. 2. Defendant Wendy S. Stetler is an adult individual residing at 424 Parkside Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on February 6, 19931 in I t ennessee. 5. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction since the date of the marriage averred in Paragraph above. 6. Neither party is a member of the armed forces of the United States of America. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. i 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have ?I 1he right to request that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. WHEREFORE, Plaintiff Val F. Stetler, II requests this Court to enter a Decree of ivorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the laintiff and Defendant. COUNT II - EQUITABLE, DISTRIBUTION 10. Paragraphs 1 through 9, inclusive, of this Complaint are incorporated by reference herein. 11. The Plaintiff and Defendant have legally and beneficially acquired property and debts during their marriage from February 6, 1993. 12. The Plaintiff and Defendant have not agreed as to any equitable distribution of the marital property and debts. WHEREFORE, Plaintiff Val F. Stetler, 11 requests this Court to order equitable distribution of marital property and debts. LAW OFFICES SNELBAKER & -2- BRENNEMAN, P.C. WHEREFORE, the Plaintiff Val F. Stetler. II requests this Court to: (a) enter a decree of divorce. divorcing the Plaintiff from the bonds of matrimony, (b) order equitable distribution of marital property and debts; and (c) order such other relief as this Court deems just and reasonable. SNELBAKER & BRENNEMAN, P.C. By:-.- r l Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Date: February 11, 2009 Attorneys for Plaintiff Val F. Stetler, II LAW OFFICES SNELBAKER 8C BRENNEMAN, P.C. VERIFICATION I verify that the statements made in the foregoing 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. Val F. Stetler, II Date: III( Joe( LAW OFFICES SNELBAKER & BRENNEMAN, P.C. JAL F. STETLER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v ; NOv - '7 ?4- CIVIL TERM WENDY S. STETLER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT VAL F. STETLER, II, duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I 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 Office of the , which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Va F. tetler, II laintiff) LAW OFFICES SNELBAKER & BRENNEMAN, P.C. L'i i `v?`\I \4 4;) (1: ? _ , R ,i AL F. STETLER. IL : IN TIIF COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND ('OtTNTY, PENNSYLVANIA V. DY S. STE"I'LER, NO. 09-776 CIVIL TERM Defendant CIVIL. ACTION -- LAW IN DIVORCE AFFIDAVIT OF SERVICE OMMONWEALTH OF PENNSYLVANIA) OUNTY OF CUMBERLAND ) SS. Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that e is a principal in the law firm of Snelbaker & Brenneman, P. C., being the attorneys for Val F. tetler, 11, Plaintiff in the above captioned action in divorce; that on February 12, 2009 he did and to Defendant Wendy S. Steller by certified mail, return receipt requested, restricted elivery, a duly certified copy of the Divorce Complaint which was filed in the above captioned as evidenced by the attached cover letter of the same date and Receipt for Certified Mail o. 7004 1350 0004 1256 4491; that both the Complaint and cover letter were duly received by Wendy S. Steller as evidenced by the return receipt card for said certified mail dated ebruary 14, 2009; that a copy of the aforementioned cover letter dated February 12, 2009 is hed hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by ce herein as "Exhibit B". and that the foregoing facts are true and correct to the best of his LAW OFFICES SNELBAKER & BRENNEMAN, P.C. knowledge, information and belief. Keith O. Brenneman worn to and subscribed before me 17t" day of February, 2009. Notary Public COMMONWEALTH OF PENNSYLVANIA NOU M Seal Susan L. MabzA Notary Pubic My?ffMw EVkw 42Nov 2MI Member, Pennsylvania Association of Notaries LAW OFFICES SNELBAKER 8C BRENNEMAN, P.C. SNELBAKER 8 BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 RICHARD C. SNELBAKER • P. O. BOX 318 KEITH O. BRENNEMAN 717-697-8528 FACSIMILE (717) 697-7681 Februarv 12, 2009 Wendy S. Steller 424 Parkside Road Camp Hill, PA 17011 Dear Ms. Steller: Enclosed please find a certified copy ol'u Divorce Complaint, the original of which was filed this date with the Prothonotarv in Cumberland C'ol.inty. Yours truly Keith C). Brenneman KOB/sire Enclosure CC: Val F. Steller, II (w/enclosure) By certified mail, return receipt requested. restricted deliver. parcel No. 7004 1350 0004 1256 4401 EXHIBIT A r1 o, Ln ti r-q f Y Total Postage & Fees c/ 55"' O c3 c Wendy S. Stetler r ?W)w ; -- ---------------- ------- ---------------------------------------- 424 ar No. Parkside Road cny snare z??a -- - -- ----- - - -- - Camp Hill; PA 17011 Y -----'""'--'"'- °_ LAW OFFICES SNELBAKER 8C BRENNEMAN, P.C. ¦ Complete items 1, 2, and 3. Also complete Ilnm 4 if Restricted Delivery is desired. ¦ P*ft your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Wendy S. Stetler 424 Parkside Road Camp Hill, PA 17011 ash X ° Agent ? Addwnera B. Received by (pd%W ame) C. Date of "VNY /7 D. Is delivery address diffefent from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type XU Certified Mali O Express Mail ? Registered ? Retum Receipt for Merchoufte ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Ir yes 2. Article Number (Thwl from service /abet) 7 0 0 4 13 5 0004 1256 4491 PS Form - 3811, -- -- February 2004 um eceipt 102595.024A-1540 EXHIBIT B a i co ?, c r way i?t-' t M ? Stephanie E. DiVittore, Esquire John M. Coles, Esquire RHOADS & SINON LLP One South Market Square, 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Wendy Stetler VAL F. STETLER, II, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 09-776 Civil Term WENDY STETLER, CIVIL ACTION --LAW IN DIVORCE Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO: Curtis Long, Prothonotary Cumberland County Court of Common Pleas 1 Courthouse Square Carlisle, PA 17013 Kindly enter the appearance of Stephanie E. DiVittore and Rhoads & Sinon LLP as counsel on behalf of Defendant Wendy Stetler in this action. Respectfully submitted, By: RHOADS & SINON LLP Stephanie E. DiVittore One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Wendy Stetler 735433.1 CERTIFICATE OF SERVICE I hereby certify that on this I dam' 'day of March, 2009, a true and correct copy of the foregoing Praecipe for Entry of Appearance was served by means of United States mail, first class, postage prepaid, upon the following: Keith O. Brenneman, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055-0318 .rte •, ? ?3 :?? "? ,, rr C.w? 3:J . 1f ; _.i __ "?:"' ? ;..? (?{? .. -? ?.7 ??? VAL F. STETLER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-776 CIVIL TERM WENDY S. STETLER, Defendant CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 12, 2009. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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. 4. 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, relating to unsworn falsification to authorities. Date: uw ?, 0005 Val F. St , II LAW OFFICES SNELBAKER & BRENNEMAN. P.C. FUD--C) 'lGE. OF THE PR `-,DNOTARY 2009 JUN 12 PPS 1* 24 Pir-,t',i`\,j4 1 L.M. v 11 1 VAL F. STETLER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-776 CIVIL TERM WENDY S. STETLER, Defendant CIVIL ACTION -LAW : IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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. 4. 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 relating to unworn falsification to authorities. Date: JGU?c ?? ?0S \` e?? Val F. Seter, LAW OFFICES SNELBAKER & BRENNEMAN, P.G. ALED-O ffiCE OF THE PR )YHONOTARY 2009 JUN 12 PM 1: 24 VAL F. STETLER, II, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION -- LAW IN DIVORCE WENDY S. STETLER, NO. 09-776 CIVIL TERM Defendant AFFIDAVIT OF CONSENT - WENDY STETLER 1. A Complaint in divorce was filed on February 12, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: 7 Wendy , tetler 745062.1 RLEO-OFFICE OF THE PROTHONOTARY 2009 JUN 12 PM 1: 24 GUMEL-iii '?L) -?OUNTfY PEA NSYLVA.II A, VAL F. STETLER, II, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW IN DIVORCE WENDY S. STETLER, NO. 09-776 CIVIL TERM Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(C) OF THE DIVORCE CODE - WENDY STETLER 1. I consent to the entry of a final decree of 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 herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: 611 Po - (4,W Wendy Stetler 2 BLED-CIFFICE OF THE PROTHONOTARY 2009 JUN 12 PM 1: 25 cum?bya71 j???r? WU?10v-)`UNTY T"N -:p VSY4YniNIA VAL F. STETLER, II, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-776 CIVIL TERM WENDY S. STETLER, Defendant CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD ITO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court for entry Iof a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce l Code. 2. Date and manner of service of Complaint: by certified mail, restricted delivery on Defendant on February 14, 2009 (See Acceptance of Service filed February 18, 2009). 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff: June 9, 2009; by the Defendant: June 9, 2009. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: June 9, 2009; by the Defendant: June 9, 2009 5. Related pending claims: None. Date: June 12, 2009 SNELBAKER & BRENNEMAN, P. C. By: lhl--\- Attorneys for Plaintiff LAW OFFICES SNELBAKER & BRENNEMAN, P.C. RL[.:D -ts. i'"r1(,,, . OF TNIE PR,() l,a-tNlOTAPY 2009 JUN 12 PH 1: 2 Z C?' y VAL F. STETLER, II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. WENDY S. STETLER NO. 09-776 CIVIL TERM DIVORCE DECREE t, a- 4j/. AND NOW, it is ordered and decreed that VAL F. STETLER, II plaintiff, and WENDY S. STETLER , 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 parties' Post Nuptial Agreement dated June 9, 2009 is incorporated but not merged into this Decree. the Court, Attest: J. K-14; Prothonotary !?- /Sl •p9 daf - t 4 ll* owl? L 4