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Home My WebLink About09-7153A/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, : CASE NO. Of, 716-5 9/ ?l V. JACQUELYN WERT, : CIVIL ACTION -LAW Defendant : IN DIVORCE NOTICE TO DEFENDANT 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 Defendant. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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 at the Prothonotary at the 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, PA 17Q,13 ?heri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 i AMERICANS WITH DISABILITIES AS OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the office of the Cumberland County Court Administrator, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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. J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, : CASE NO. 09- 71<3 Cc, jJ ??.?•- V. JACQUELYN WERT, CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is William Wert who currently resides at 75 Fickes Road, Newville, Pennsylvania 17241. 2. Defendant is Jacquelyn Wert who currently resides at 203 Fairfield Street, Newville, Pennsylvania 17241. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on June 27, 1987. 5. There have been no prior actions commenced for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of counseling and that he may have the right to request the Court to require the parties to participate in counseling. 7. Plaintiff avers that no issues regarding the custody of children result from this action. COUNT 1 3301(e ) IRRETRIEVABLE BREAI?OWN 8. Paragraphs 1 through 7 are incorporated herein by reference. . -s 9. The marriage is irretrievably broken and the parties are estranged due to marital difficulties with no reasonable expectation of reconciliation. 10. Plaintiff requests the Court to enter a decree in divorce. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order dissolving the marriage between the parties. 41?ri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, V. JACQUELYN WERT, Defendant CASE NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, William Wert hereby state that I am the plaintiff in the foregoing action and that the facts contained herein are true, correct and accurate to the best of my knowledge, information and belief. I further understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. -William Wert • Date: ?o - LJ ?F rH? 2009 OCT 20 AM 8: 4 J G'iJlf??, ?iC'? ?73aa?y I • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, CASE NO. 09-7153 V. JACQUELYN WERT, CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Sheri D. Coover, Esquire hereby certify that I did serve a true and correct copy of the Complaint for Divorce, upon the Defendant, Jacquline Wert, by depositing or causing to be deposited in the U.S. mail certified, restricted delivery, postage prepaid on Jacqueline Wert at Carlisle, Pennsylvania addressed as follows: Jacqueline Wert 203 Fairfield Street Newville, PA 17241 Return card acknowledging receipt on October 26, 2009 is attached as Exhibit "A." submitted, S D.-Coover, Esquire ttorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Date: w a- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, : CASE NO. 09-7153 V. JACQUELYN WERT, : CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 2nd day of November, 2009, I caused the foregoing AFFIDAVIT OF SERVICE to be served upon the following individual by depositing or causing to be deposited same in the United States mail, First-class mail, postage prepaid, addressed to the following: Jacquline Wert 203 Fairfield Street Newville, PA 17241 submitted, "oover, Esquire ID 93285 44 S. Hanover Street Carlisle, PA 17013 ¦ Complete items 1, 2, and 3. Also complete a Agent Item 4 if Restricted Delivery is desired. 1111 Print your name and address on the reverse X i 13 Addressee I JL64 A so that we can return the card to you. ¦ Attach this card to the back of the mailplecb, 6 ( ame) f a /Lo v Date of Delivery or on the front If space permits. It t f ry dd diff d li 1? 0 Ye§ om em ress eren e ve a s 1, Article Addressed to: If YES, enter delivery address below: 0 No Z03 F4r'- elf . . ?..??o -1 t' T Q1 f 1 f 3. Type ress Mail "[?I.CertNied Mail ? Ex p ,- 0 RegWWW 0 Return Receipt for Merchandise 0 insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (transfer from service iabeq ---..7009 1410 0000 1189 4230 PS Fort 3811, February 2004 Domestic Return Receipt 595-02-M-1540 EX "I bNT A,•? OF TH? 2009 NOV -2 AM 11.58 Ct t, ? NTY PE 4i-,IS'1_VANI A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, CASE NO. 09-7153 Plaintiff V. JACQUELYN WERT, Defendant CIVIL ATION -LAW IN DIVORCE AMENDED AFFIDAVIT OF SERVICE I, Sheri D. Coover, Esquire hereby certify that I did serve a true and correct copy of the Complaint in Divorce upon the Defendant, Jacquelyn Wert, by depositing or causing to be deposited in the U.S. mail, certified, restricted delivery, postage prepaid on Jacquelyn Wert at Carlisle, Pennsylvania addressed as follows: Jacquelyn Wert 203 Fairfield Street Newville, PA 17241 This Amended Affidavit of Service is filed to correct the spelling of Ms. Wert's name which was erroneously misspelled on the Affidavit of Service which was previously filed on November 2, 2009. Return card acknowledging receipt on October 26, 2009 is attached as Exhibit "A. submitted, 5 Teri D. Coover, Esquire Attorney ID 93825 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, CASE NO. 09-7153 Plaintiff V. CIVIL ACTION -LAW IN DIVORCE JACQUELYN WERT, Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certifies that on this 10d' day of November, 2009, I caused the foregoing AMENDED AFFIDAVIT OF SERVICE to be served upon the Defendant by United States First Class mail addressed as follows: Jacquelyn Wert 203 Fairfield Street Newville, PA 17241 Res tfully submitted, eri . Coover, Esquire Attorney ID 93825 44 S. Hanover Street Carlisle, PA 17013 R ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery 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 of the mailpiecb, or on the front if space permits. 1. Article Addressed to: 1C aline Z)3 2 4e(c .£ Pa 2. Article Number (Transfer from seMce kbeq PS Form 3811, February 2004 u !1 ,? a / J,p Agent .,n[eo nreme) ?. Date of Delivery T deliveryaddress different from "1? ? Yep If YES, enter delivery address below: ?'No 3. Type rtified Mail ? Express Mail 13 Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Exfra Fee O Yes 009 1410 0000 1189 4230 Domestic Return Receipt 2009 fib'°a i 0 Pr s IN THE COURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA WILLIAM WERT, No. 09-7153 Plaintiff ~ -. CIVIL ACTION -LAW ~ o ~~r' v. ~. ~ ~ , ~ - -~ -n r JACQUELYN WERT, ~ ~ _ ~"' ~ ~ F.J _~ ?~~; Defendant ~ = -~ , - - - - .. _ PRAECIPE c ~ _:.:~ '{ TO THE PROTHONOTl~RY: Please enter my ~ appearance on behalf of Jacquelyn Wert, Defendant, in the above- captioned matter. Date: July 16, 2010 Attorney ID No. 90946 4 Irvine Row Carlisle, Pennsylvania 17013 (717) 701-8412 Attorney for Defendant Respectfully submitted, LAW OFFICE OF SEAN M. SHULTZ, P.C. WILLIAM WERT, Plaintiff v. JACQUELYN WERT, Defendant AND NOW, thi; have this day served t delivery: IN THE COURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA No. 09-7153 CIVIL ACTION -LAW CERTIFICATE OF SERVICE 6`h day of July 2010, I, Sean M. Shultz, Esquire, hereby certify that I following person with a copy of the foregoing Praecipe by hand Sheri D. Coover, Esquire Attorney for Plaintiff Respectfully submitted, LAW OFFICE OF SEAN M. SHULTZ, P.C. ~i M. Shultz, Esquire Attorney ID No. 90946 4 Irvine Row Carlisle, Pennsylvania 17013 (717) 701-8412 Attorney for Defendant O� CU�f David D. Buell" i e, Renee 7C Simpson Prothonotary D 1St Deputy Prothonotary � Q t.' i �irkS. Sohonage, ESQ �n Irene E. Morrow Solicitor 1750 rd Deputy Prothonotary Office of the Prothonotary Cum6erCancf County, cpennsyCvania O9-g- 7/g3 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 291H DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Eax(717)240-6573