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HomeMy WebLinkAbout01-1436HAROLD $. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF JILL A. TICHNELL, Plaintiff Vw MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION .. LAW ::NO. 0t- /~'__ CIVIL TERM : IN DIVORCE NOTICE 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 plaintiff. You may lose money or property or other dghts 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, r)lVlSlON 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, Pennsylvania 17013 717-249-3166 JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : .' CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(d) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Jill A. Tichnell, an adult individual residing at 152 Elm Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Michael R. Tichnell, an adult individual residing at 152 Elm Street, Carlisle, Cumberland County, Pennsylvania 1'7013. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on May 16, 1992, in Newville, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request thet the court require the parties to participate in counseling, WHEREFORE, the plaintiff demands judgment dissolving the mardage between the parties and for such further relief as your Honorable Court may deem equitable and just. 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. Section 4904, relating to unswom falsification to authorities. March 12, 2001 JIl~. TICHNELL, Plaintiff HAROLD S. IR.W.~ Attorney' for plaintiff ~ 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 JILL A. TICHNELL, Plaintiff MICHABL R. TICHNELL, Defendant : IN THB COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 0t - __ CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's 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 divome decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.$. Section 4904 relating to unsworn falsification to authorities. March/~--, 2001 JI~A. TICHNEI..L, /~// Plaintiff JILl. A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant · . IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01 - 1436 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about March 13, 2001 served upon defendant on or about March 16, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the 3enalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. JILL A. C. TICHNELL JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01 - 1436 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about March 13, 2001 and served upon defendant on or about March 16, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. November/~, 2001 JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01 - 1436 CIVIL TERM : IN DIVORCE 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. 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. Section 4904 relating to unsworn falsification to authorities. November/__~, 2001 JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01 - 1436 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330t{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. 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. Section 4904 relating to unsworn falsification to authorities. November//2001 MICHAEL R. TICHNELL JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01 - 1436 CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and under,stand 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 Prothonotary's 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. November /~, 2001 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. Section 4904 relating to unsworn falsification to authorities. JiLL A1 Cl TICHNELL JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON 'PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01 - 1436 CIVIL TERM : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, 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 Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. November's__, 2001 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (7t 7) 243-6090 ATTORNEY FOR PLAINTIFF JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 01 - 1436 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about March 16, 2001, by certified mail "restricted delivery", addressed to him at 152 Elm Street, Carlisle, PA 17013, certified mail, return receipt No. Z 339 O62 170. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsifica/~on~uthorities. March 19, 2001 _Harold S. Irwin, III / ) Attorney for plaintiff ~ / · Coml~ete items 1, 2, item 4 if · Print your name and ~ so that we can return · Attach this card to' or on the front if space permits. 1~ Article Addressed to: [] Addres,~ee em1? rlyes If YE~, ente~ delivery ~ddmss below: F1 No 3. e Type ~eer~lfled Ma~l .. [] ~oress Mail [] Registered ,~i~retum Receipt for Merchandise [] Ir)sured Mail [] C.O.D. ~.. PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 I PS Form3800, Apri11995 IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF ~ PENNA. .JILL .A.C..-T~.C~NELI~ ........................ ......................... -Plai~ti.f f .............. Versus .~IC~%EL..~.,...~ICHN~L~ ................. ............. Defen~lant ....... DECREE IN DIVORCE ~AND NOW,.. NaV~.~.~m ..... .~..~. ........ 19.20.Ql, it is ordered and decreed that . JZL~.. ~,¢,..TZCm~E~.~. ........................... plaintiff, a nd ........... ~:remu~ .IR, · ~I. CHN~Ln ........................ 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: I~QN]E: ....................................................................... By The Court'ff~ /~ / HAROLD S. IRWIN~ lilt ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (7t 7) 243-6090 ATTORNEY FOR PLAINTIFF JILL A. TICHNELL, Plaintiff MICHAEL R. TICHNELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA I .' CIVIL ACTION - LAW : : NO. 01 - 1436 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and manner of service of the complaint: On or about March 16, 2001, defendant was served with a copy of the divorce complaint. See Affidavit of Service filed on March 19, 2001. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: November 13, 2001. By the defendant: November ~, 2001. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None November ~.~, 2001 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: N/A (b) Date plaintiff's Waiver of Notrice in Section 3301(c) divome was filed with the Prothonotary: November ~, 2001. Date defendant's Waiver of Notice in Section 3301© Divorce was filed with the Prothonotary: November '~..~, 2001.