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Home My WebLink About01-7073TAMELA M. WERNER, Plaintiff LEROY F. WERNER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 707,3 CIVIL ACTION - LAW IN DIVORCE TO: Leroy F. Wemer, Jr. 12 Caravan Court Middletown, PA 17057 YOU HAVE BEEN SUED IN COURT. If you wish to defend against thc 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 office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, 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, PA 17013 (800) 990-9108 TAMELA M. WERNER, Plaintiff LEROY F. WERNER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE COMPI,AINT IN r~IVOliCE 1. The Plaintiff is Tamela M. Wemer, an adult individual, currently residing at 4012 Gettysburg Road, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Leroy F. Wemer, Jr., an adult individual, with a last known address of 12 Caravan Court, Middletown, Dauphin County, Pennsylvania. 3. The Defendant has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 1, 1989, in Camp Hill, Cumberland County, Pennsylvania. 5. Plaintiff's Social Security Number is 169-44-7463. Defendant's Social Security Number is 169-44-5025. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Document #: 212886. I 10. 11. 12. Defendant. There were no children bom of the marriage. The marriage is irretrievably broken. The parties separated on May 28, 1995. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and W}tEREFORE, Plaintiff requests that this Court enter a Decree in Divorce, and enter such other orders as are appropriate. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By Melissa Van Eck, Esquire Attorney I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 212886.1 VEJ~IFICATION I, Tamela M. Wemer, hereby certify that the facts set forth in the foregoing Complaint in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. {}4904 relating to unswom falsification to authorities. Date: I'~11 ~ IO~ T~nel/i M. Weber Document #: 212886.1 CUMBERLAND RECORD OF DIVORCE OR ANNULMENT ~ (CHECK ON~ ~ 1. NA~E (First) HUSBAND (M~*) (Day) T.FROy 3. RESIDENCE Stre~ or R. D. 12 Caravan Court MARRIAGE 2 [] 8. MAIDEN NAME (F*~t) : ~/ty, ROTC. or Tv~. C~r~/ SMte IL P~E Middleto~ Dauphin, PA WIFE OF 12 6 1q56 (Sta~e or F~,,~,~ CounUy) PA (Monm) (D~y) C(eal 12 ~ ~958 (State or F,~,, Count~/) STEPHENSON TAMF. T.A 10. RESIDENCE Sheet orR. D. City, Bo~. or Tv~. County 4012 Gettysburg Road, Camp Hill, Cumberland, PA 1~- NUg~ER I3. RACE OF THIS WHITE MAPaiA~E 1 [] 1~. PLACE OF (Courtly) THIS ,?~ wu OF Ira' .UMBER OF OE~NRENT ~. DA~ ~ DECREE (~) PA BLACK OTHER (Sp~c~/) 14. U~UAL OCCUPATION [] [] Self-emoloved (S~.JeorF~.o;~-,Coumry) [6. O.~T~ O~ (Mon~) THIS PA MARRIAGE 0 7 119 DECREE GRANTED TO 18. pLRINTIFF [ ' HU~]~NO HUSBAND WIFE OTHER (Speedy) SPUT CUSTOOY OTHER (~pe~) [ 21. LEGAL GROUNDS FOR DIVORCE OR ANNULMENT (Year) J2~. DATE REPORT SENT (Mort/h) (Day) TO VITAL RECORDS O(Mr) {)1 lqgq V~FE OTHER (s~c~y) 24. SIGNATURE OF TRANSCRIBING CLERK TAMELA M. WERNER, Plaintiff LEROY F. WERNER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. o ddl CIVIL ACTION - LAW 1N DIVORCE .AFFIDAVIT OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Plaintiff, Tamela M. Wemer, hereby certify that a true and correct copy of the Complaint in Divorce was served upon Defendant, Leroy F. Werner, Jr. via certified and regular mail on December 19, 2001. The certified mail came back unclaimed however the copy sent regular mail has not been returned to our office, therefore he is deemed served on January 7, 2002. Attached hereto, marked as Exhibit "A" are copies of the letters sent via regular and certified mail. Also attached hereto, marked as Exhibit "B" is a copy of the envelope returned marked '~.nclaimed". METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Document #.. 224609.1 Melissa L. Van Eck, Es~uire'~ I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Exhibit A December 19, 2001 VIA REGULAR AND CERTIFIED MAlL Leroy F. Wemer, Jr. 12 Caravan Court Middletown, PA 17057 Werner v Werner Docket No. 01-7073 Civil Term Our File No. 86-110 SINCE 1888 3211 North Front Street EO. Box 5300 Harrisburg, PA 17110-0300 717-238-8187 Fax: 717-234-9478 Other Offices Colonial Park 717-652-7020 Mechanicsburg 717-691-5577 Shippensburg 717-530-7515 De~ Mr. Wemer: Enclosed please find a copy of a Complaint in Divorce which was filed in the Court of Common Pleas of Cumberland County. Please contact an attorney to discuss your rights which you may have in this matter. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Melissa L. Van Eck MLV/dlr Enclosure Docuraent #.- 223171. I $ $ Clark DeVere E. Ralph Godfrey Steven C. Courtney Francis J. Lafferty, IV David H. Martineau Andrew W. Norfleet Steven C. Skoff Melissa L. Van Eck Andrew C. Spears Young-Suh Koo Exhibit B