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Home My WebLink About01-1006MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT LINGLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. G I._T m CIVIL ACTION - LAW : COMPLAINT IN DIVORCE NOTICE TO: ROBERT GRANT LINGLE, Defendant 3101 Hillside Street Harrisburg, PA 17109 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 office of the Prothonotary at the Cumberland County Courthouse, 1 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 Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Document #: 196536.1 MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT L1NGLE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. o/- : CIVIL ACTION - LAW : COMPLA1NTIN DIVORCE COMPLAINT IN DIVORCE 1. The Plaimiffis Marcie Leigh Lingle, an adult individual residing at 6 Lynn Avenue, Newburg, Cumberland County, Pennsylvania 17240. 2. The Defendant is Robert Grant Lingle, an adult individual residing at 3101 Hillside Street, Dauphin County, Pennsylvania 17109. 3. Plaintiff and Defendant have been a bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint, 4. The Plaimiff and Defendant were married on August 26, 1995 in New Cumberland, Cumberland County, Pennsylvania. 5. 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 Rights Act of the Congress of 1940 and its amendments. 6. Plaintiff's social security number is 078-70-9477 and Defendant's social security number is 223-37-6247. 7. There have been no prior actions of divorce or for annulment between the parties. Document#'194824.1 8. Plaintiffhas been advised that counseling is available and that Plaimiffmay have the right to request that the court require the parties to participate in counseling. 9. The parties have one reinor child who was bom during the marriage. COUNT I Divorce 10. The averments of paragraphs 1-9 hereof are incorporatedherein by reference. The marriage is irretrievablybroken. The parties have been living separate and apart since June 23, 2000. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and 11. 12. 13. Defendant. WHEREFORE, Plaintiffrequests that this Court enter a Decree in Divorce and enter such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB By Attorney I.D. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Date: Document #: 194824.1 VERIFICATION I, Marcie Leigh Lingle hereby certify that the facts set forth in the foregoing Complaint in Divorce are true 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 falsificationto authorities. Document #.. 194824.1 MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT LINGLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1006 Civil Term CIVIL ACTION - LAW COMPLAINT IN D1VORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 20, 2001 and served upon Defendant on February 20, 2001. 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 ora 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. § 4904 relating to unswom falsification to authorities. M~r~ie L%ig~h ~.~mg4Jll e~ ~1~e-ff Document#.'2059221 MARCIE LEIGH L1NGLE, Plaintiff ROBERT GRANT L1NGLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01ol006Civil Term CIVIL ACTION - LAW COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQ6EST ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal 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 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 unswom falsification to authorities. Document #: 205922 ] MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT LINGLE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-1006 Civil Term : : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 20, 2001 and served upon Defendant on February 20, 2001. 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 affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Robert Grant Lingle Document#.'2059221 MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT L1NGLE, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1006Civil Term CIVIL ACTION - LAW COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a f'mal 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 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 unswom falsification to authorities. Date: Document ii. 205922.1 MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT L1NGLE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1006 Civil Term : CIVIL ACTION - LAW : COMPLAiNT iN DIVORCE AFFIDAVIT OF SERVICE I, Melissa L. Stickel, counsel for Plaintiff, Marcie Leigh Lingle, hereby certify that a true and correct copy of the Complaint in Divorce was served upon the following, by certified mail, return receipt on February 20. 2001. Attached hereto, marked as Exhibit "A" and incorporated herein by reference is a letter from the United States Post Office indicating the time and date of service of the Certified Mail. Attached hereto, marked as Exhibit "B" and incorporated herein by reference is a copy of a letter to the Defendant, Robert Grant [,ingle enclosing the Divorc. e Complaint. METZGER, WICKERSHAM, KNAUSS & ERB. P.C. Date: May ~7// ,2001 Melissa L. Stickel, Esquire I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document (4' 205117.1 Exhibit A February 15, 2001 VIA REGULAR AND CERTIFIED MAIL Robert Grant Lingle 3101 Hillside Street Harrisburg, PA 17109 RE: Lingle v. Lingle Our File No. 86-23 SINCE 1888 3211 North Front Street EO. Box 5300 Harrisburg, PA 17110-0300 717-238-8187 Fax: 7l 7-234-9478 Other Offices Colonial Park 717-652-7020 Mechanicsburg 717-691-5577 Shippe~sburg 717-530-7515 Dear Mr. Lingle: Enclosed please fred a copy of a Complaint in Divorce which was filed in the Court of Common Pleas of Cumberland County. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Melissa L. Stickel MLS/dlr Enclosure Document #: 198135.1 Robert Grant Lingle ' 'gi~i~ 7~biT-g~ ~-67~5-~Z~;i' .................................................... 3101 Hillside Street ' '~'~,' ~£a-~ - MP~ ........................................................................ HarrisburgI PA 17109 Exhibit B Delivery Record: 7099.3400001418322005 Page 1 of 1 UNITED .;ERVICE Date: 05/02F2001 Dear Postal Customer: The following is in response to your 05/02/2001 request for delivery information on your Certified item number 70993400001418322005. The delivery record shows that this item was delivered on 02/20/2001 at 03:59 PM in HARRISBURG, PA 17112. There is no delivery signature on file for this item. Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please take this receipt to your local Post Office or postal representative. Sincerely, United States Postal Service http://trkcnfrm.usps.g~v/n.../~etter?id-~abe~=7~9934~~~~~4~8322~~5&key-sfx=~&id-trackEv= 5/2/01 MARCIE LEIGH L1NGLE, Plaintiff ROBERT GRANT LINGLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW COMPLAINT IN DIVORCE CERTIFICATE OF SERVICE I, Melissa L. Stickel, Esquire, do hereby certify that I served a copy of the Affidavit of Service upon the Defendant by mailing a copy to him, regular first class mail, on the 4th day of May, 2001, at: Robert Gram Lingle 3101 Hillside Street Harrisburg, PA 17109 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Melissa L. Stickel, Esquire I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document #: 194824.1 MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT LINGLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1006 Civil Term CIVIL ACTION - LAW COMPLAINT IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divome: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of Complaint: A Complaint in Divorce was filed on February 20, 2001, and served on Defendant by certified mail on February 20, 2001. Affidavit of Service was filed May 7, 2001. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code: Plaintiff- May 24, 2001, and filed May 25,2001 Defendant- May 24, 2001, and filed May 25, 2001 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of service of the Plaintiffs affidavit upon the defendant: N/A 4. Complete the appropriate paragraphs: (a) Related claims pending: None Document #: 206883. I (b) (c) Claims withdrawn: None Claims settled by agreement of the parties: N/A (d) State whether any written agreement is to be incorporated into the Divorce Decree. No (a) Date and manner of service of the Notice of Intention to File Praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i)ofthe Divorce Code: N/A (b) Date plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: May 25, 2001 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the prothonotary: May 25, 2001 Dated: 5///v/ METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Melissa L. Stickel, Esquire Attorney I.D. No. 85,869 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 206883.1 MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT L1NGLE, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1006Civil Term CIVIL ACTION - LAW : COMPLAINT IN DIVORCE CERTIFICATE OF SERVICE ANDNOW, this ]~o3 of -..J~/[..[ ,2001,I, MelissaL. Stickel, Esquire, of Metzger, Wickersham, Knauss & Erb, attorneys for Plaimiff, Marcie L. Lingle, hereby certify that I served a copy of the Praeeipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Robert Grant Lingle 3101 Hillside Street Harrisburg, PA 17109 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Melissa L. Stickel Document #: 206883. ] Exhibit A MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT LINGLE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1006 Civil Term : : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divome under Section 3301(c) of the Divorce Code was filed on February 20, 2001 and served upon Defendant on February 20, 2001. 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 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: Robert Grant Lingle Document #: 205922. I MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT LINGLE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01~1006 Civil Term : : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 20, 2001 and served upon Defendant on February 20, 2001. 2. The man/age 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 afier 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. § 4904 relating to unsworu falsification to authorities. Document #' 205922 1 Exhibit B MARCIE LEIGH L1NGLE, Plaintiff ROBERT GRANT LINGLE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-1006 Civil Term : : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consem 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 sero to me immediately after it is fried 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. § 4904 relating to unswom falsification to authorities. Date: Robert Grant Lingle z r~:~_~. _,- Document #: 205922. I ' MARCIE LEIGH LINGLE, Plaintiff ROBERT GRANT L1NGLE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-1006 Civil Term : : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301fc) OF THE DIVORCE CODE 1. I consem to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alitnony, 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 in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4~904 relating to unsworn falsification to authorities. Document #. 205922 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MARCIE LEIGH LINGLE NO. o1-1oo6 civil Term VERSUS ROBERT GRANT LINGLE AND NOW, DECREE IN DIVORCE ., IT IS ORDERED AND DECREED THAt MARCIE LEIGH LINGLE , PLAINTIFF, AND ROBERT GRANT LINGLE , 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: PROTHONOTARY