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Home My WebLink About09-8061Andrew C. Sheely, Esquire 197 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K. NEDZEL, Plaintiff vs. JOHN R. NEDZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 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 against 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 Plaintiff. You may lose money or property or other rights important to you, including custody or visitation with 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 the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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, PENNSYLVANIA 17013 (717) 249-3166 BY ndrew C. Sheely, squire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 1?7 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K. NEDZEL, Plaintiff VS. JOHN R. NEDZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - IN DIVORCE NOTICE OF RIGHT TO COUNSELING YOU are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 1217 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K. NEDZEL, Plaintiff VS. JOHN R. NEDZEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is JAIME K. NEDZEL, an adult individual who currently resides at 12 South Filbert Street, Apartment A13, Mechanicsburg, Borough of Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is JOHN R. NEDZEL, an adult individual who currently resides at 1428 Apple Drive, Apartment 198, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married in Jackson, Wyoming, on March 26, 2004. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request 1 j that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8. Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing and service of the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11. This divorce action is not collusive. 12. The parties separated on or about September 1, 2008. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT II - DIVORCE - 3301(d) 13. Paragraphs 1 - 12 are incorporated herein as if set forth at length. 2 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. Respectfully submitted, rr Date: November 2009 Andrew C. ?Sheely-,,Ess e Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 3 I e VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: November I? 2009r CCCC??? aime K. edzel Andrew C. Sheely, Esquire 12' S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K. NEWEL, Plaintiff VS. JOHN R. NEWEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - IN DIVORCE AFFIDAVIT Jaime K. Nedzel, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may 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 Domestic Relations office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in 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.A. Section 4904 relating to unsworn falsification to authorities. November ? 2009 acme K. zel C PLED-O -FCE OF THE 2 0 G 9 N2V 20 k 111113: 3 9 6 ITS,/ 1? ax- j,-r, T 211 oo J ? - /7?S( Andrew C. Sheely, Esquire 127 S. Market St~~eet P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7054 (Phone} ?17-697-7065 (Fax) JAIME K. NEDZEL, IN THE COURT OF COMMON PLEFS OF Plaintiff CUMBERLAND COUNTY, PENNSYLtiANIA vs. CIVIL ACTION - LAW JOHN R. NEDZEL, 09 - 8061 ~ c n' Defendant IN DIVORCE n ~'.` ~ "'"~ ~~-_: ~ ~ cy; ~: _ ~ ~ C~'7 c::: ~ AFFIDAVIT OF CONSENT T~- ~ ~~~ ..- c_ .~- 1. A Complaint in Divorce under Section 3301(c) of the Divorce Cade was filed on November 20, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of f it ing and serving the Complaii~~t . - 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 undez~stand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. ~;, /~ - _ ' ~~ ,~... DATE: ie K. Nedze /r Andrew C. Sheely, Esquire 127 S. Market Street P.O. Hox 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-647-7050 (Phone} 717-697-7065 (Fax) JAIME K. NEDZEL, Plaintiff vs. JOHN R. NEDZEL, IN THE COURT OF COMMON PLEFS OF CUMBERLAND COUNTY, PENNSYLLANIA CIVIL ACTION - LAW 09 - 8061 Defendant IN DIVORCE o Divorce Code was filed on November 20, 2009. o -r~ U~ 3C r_'_ [_ ~ CJJ ~ AFFIDAVIT OF CONSENT ~~_, ~,`_;^, ~_ 1. A Complaint in Divorce under Section 3301(c} of'tc_ iv rn 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of f it ing .and serving 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 here ix are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. +r+ rr s DATE : ~ ~~ /" ~ ._ ie K. Nedze y ~~ '"" ~? -~ --j'i c~ CJ ~ -c Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 71?-697-7065 (Fax) JAIME K. NEDZEL, Plaintiff vs. JOHN R. NEDZEL, Defendant IN THE COURT OF COMMON PLEPS OF CUMBERLAND COUNTY, PENNSYLZANIA CIVIL ACTION - LAW 09 - 8061 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE .UNDER X3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. rv ~? ,M, -,' ~ a ~ ~ ~, ~ .~ ` i .' j ~.< ~J Jil ~ ~~ _~ ~ ~ ~ .e '-- e- -_ ~ -~ .~, _~_ C~ ~_i ~ ~ ~ N rz'1 i v i 2. I understand that I may lose rights concerning alimony, divis-ion of property,- lawyer' s~ fees- or -expenses--if I- do not claim them before a divorce decree 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 this affidavit are true and correct. I understand that false statements rerein are made subject to the penalties of 18 Pa.C.S.A. Section 9904 relating to unsworn falsification to ..,% DATE : ~ '~ _ authorities. Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K. NEDZEL, Plaintiff vs. JOHN R. NEDZEL, Defendant IN THE COURT OF COMMON PLEFS OF CUMBERLAND COUNTY, PENA?SYL~ ANIA CIVIL ACTION - LAW 09 - 80b1 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST MNTRY OF A DIVORCE DECREE .UNDER X3301 (C) OF THE DIVORCE CODE ~ c a ~: -„ ~ ~; ~, a ~,-; ~ ~ -C .-_ r" CJ1 ~ C:.d --s :x~ ~ ~rn .r •• ~ tr+ . 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 decree 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 this affidavit are true and correct. I understand that false statements 1-erein are made subject to the penalties of 18 Pa.C.S.A. Section 9904 relating to unsworn falsification to { RATE e !~ ~ _ , , /~ - authorities. amie K. Nedz Andrew C. Sheelp, Esquire 127 S. Market Street P.O. Sox 95 Mechanicsburg, PA 17055 PA ID NO. 62969 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K. NEDZEL, . Plaintiff . vs. IN THE COURT OF COMMON PLE,~S OF CUMBERLAND COUNTY, PENNSYL'IANIA CIVIL ACTION - LAW JOHN R. NEDZEL, 09 - 8061 C Defendant IN DIVORCE '~7 r-r? ~; -~._, ~~r.~ F1J . I- ~ ~_ C ~ ~~ _, AFFIDAVIT OF CONSENT -'-t- yam: 1. A Complaint in Divorce under Section 3301(c) of tha tV d A C!i '~ t~ .~- rn Divorce Code was filed on November 20, 2009. I accepted ser•~ice of the divorce complaint on November 26, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. T understand. that. false statements herein-are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. DATE: -~ L.~ l~ John R. Nedzel ~~ C"7 0~ Andrew C. Sheely, Esquire 127•S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K. NEDZEL, Plaintiff vs. JOHN R. NEDZEL, Defendant IN THE COURT OF COMMON PLE;1S OF CUMBERLAND COUNTY, PENNSYL'TANIA C7 0 . CIVIL ACTION - LAW ~ o ~ m~~ ~ ~ Q9 - 8061 F_, ~ ~ ~ -o ,~~= , ~ IN DIVORCE ~~- °~ 0 - ~ ~ ..... ~y\~y 1'' ~ -. -' ~ ~.,~ . w~ ~p ~~ ,~ ~ ~ ~~ AFFIDAVIT OF CONSENT "~ •• r m ~~/ -~c 1. A Complaint in .Divorce under Section 3301(c) of the Divorce Code was filed on November 20, 2009. I accepted ser,~ice of the divorce complaint on November 26, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3-. I consent to the -entry of a f 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 hereir-are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. -i r' DATE: 3-2-t~ _ John R. Nedzel Andrew C. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 {Fax) JAIME K. NEDZEL, Plaintiff IN THE COURT OF COMMON PLE.3S OF CUMBERLAND COUNTY, PENNSYLIANIA vs. JOHN R. NEDZEL, Defendant CIVIL ACTION - LAW 09 - $061 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301 (C) OF THE DIVORCE CODE C? o ,`, ~ -rl ~ ~~N c ~: " ~ ~~ ~ ( ~' ~ .~ p m _ tv rn 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 ii I do not claim them before a divorce decree is granted. ;~. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy cf the decree will be sent to me immediately after it is filed wit h the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements terein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. DATE : f, ~~---~~ 3 --2--1 c~ John R. Nedzel Andrew C. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) JAIME K, NEDZEL, E.~Sp F IN THE COURT OF COMMON PL ~-, Plaintiff CUMBERLAND COUNTY, ~ PENNS~CL~IA~A . ' ' ~ vs . CIVIL ACTION - LAW "~ 3~ t'}L ~~%`- ~ 'c ~y _ ~~+ ~ ,~:_ ~. /'f) ~~~ ~ JOHN R. NEDZEL~ 09 - 8061 ~.:~- -,~, ~_= Defendant IN DIVORCE =~~{~-- ~ ~rn -L~j "'` ~ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER X3301 (C) ;. OF T8E 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 ii T do not claim them before a divorce decree is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy cf the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this aff_davit are true and correct. I understand that false statements t.erein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. DATE : G ~ ' 3 ~ Z_~ y ~~ John R. Nedzel JAIME K. NEDZEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JOHN R. NEDZEL, 09 - 8061 Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD n N TO THE PROTHONOTARY: ~ o -~ '~ ~ 3 ~r_' ~' rn~ Kindly transmit the record, together with the following Vic;:` ~ ~~ information to the Court for entry of a divorce decree: ~.<~~ cn ~~? c. -~ .:: -~ 1. Ground for divorce: ~~_ N Irretrievable breakdown under 3301(c) ~ .3 2. Date and manner of service of the complaint: Acceptance by Defendant on November 26, 2009. 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit required by 3301(c) of the Divorce Code: by plaintiff 2/26/10; by defendant 3/2/10. b. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code N/A (2) Date of filing and service of the plaintiff's affidavit upon the respondent: N/A 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: 3!5 /10 Date defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 315/10 Andrew C. Sheely, Esquire Attorney for Plaintiff 127 South Market Street Mechanicsburg, PA 17055 (717) 697-7050