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HomeMy WebLinkAbout01-1491CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Qto 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 without you and a decree of divorce or annulment may be entered against you by the Court. A judgrnent 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of n~tarriage counselors is available in the Prothonotary's Office, Cumberland County Courthouse, 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 (717) 249-3166 CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : : CIVIL ACTION - LAW .. : NO. 0~ I~qO ~ ~"~ _. : IN DIVORCE COMPLAINT AND NOW, comes the above-named Plaintiff, CAROLYN A. MANGOLD, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce fi.om the above-named Defendant, DAVID E. MANGOLD, upon the grounds hereinafter set forth. 1. Plaintiff is CAROLYN A. MANGOLD, an adult individual, who currently resides at 920 West Trindle Road, Mechanicsburg, Pennsylvania 17055. 2. Defendant is DAVID E. MANGOLD, an adult individual, who currently resides at 920 West Trindle Road, Mechanicsburg, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 7, 1985, in Vermont. parties. There have been no prior actions of divorce or for annulment between the 6. The Plaintiffand Defendant are both citizens of the United States of America. 7. The Defendant is not a member of the Armed :Services of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree irt Divorce. 2 WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce dissolving the marriage between the parties. Respectfully submitted, CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID# 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff 3 VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce 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. DATED: d///~/~' CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION .- LAW NO. 0! ~/¥ ~'/ ('tv~c 7TM IN DIVORCE ACCEPTANCE OF SERVICE above-captioned matter. DAVID E. MANGOLD, accept service of a copy of the Complaint filed in the Dated: ~(D~VID E: MCdOLD, D~fendant CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION - LAW : : NO. 01-1491 : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 14, 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: ~,//'~ 7//~/ ~--AROLYN ~. MANGOLD{ Plaintiff CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : CIVIL ACTION - LAW : : NO. 01-1491 : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C~ AND §3301(D} OF THE DIVORCE CODE 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 ifI 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 unsworn falsification to authorities. DATE: ~/2-?/~/ CAROLYI~A. MANGO~D P~aintiff ' CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. ._ : CIVIL ACTION - LAW : : NO. 01-1491 : : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 14, 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: t$/~Tt/a,? OLD, ;efendant CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. ._ : CIVIL ACTION - LAW : : NO. 01-1491 : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) AND §3301(D) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. 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 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. I~A-VID El MAI~(~LD, Plaintiff / CAROLYN A. MANGOLD, Plaintiff V. DAVID E. MANGOLD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. ._ : CIVIL ACTION - LAW _. : NO. 01-1491 : : IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD 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. 2. Date and manner of service of the Complaint: Acceptance Of Service by Defendant dated March 18, 2001, and filed herein. 3. Complete either paragraph (a) or (b). (a) Date of execution ofthe Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff on June 27, 2001; by Defendant on June 27, 2001. (b)(1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the Defendant: N/A. CAROLYN A. MANGOLD Plaintiff V. DAVID E. MANGOLD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : No. 01-1491 CIVIL Term : : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME To Be Known As: CAROLYN A. LANDIS Notice is hereby given that the Defendant in the above matter, CAROLYN A. MANGOLD, having been granted a Final Decree in divorce from the bonds of matrimony on the 11"' day of July, 2001, hereby elects to retake and hereafter use her previous name of CAROLYN A. LANDIS. COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN .~'t~. ,2001, before me, a Notary Public, personally appeared On the day of CAROLYN A. LANDIS, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand/ax~N~ Seal. [' Netar,e, Sea, / Constance R Brunt, Notary Public [ Harrisburg, Dauphin County [ My Commission Expires Oct. 20, 2001 Notary Public IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF PENNA. CAROLYN A. MANGOID Versus DAVID E. MANGOLD NO. 1491 2001 DeCreE IN DIVORCE AND NOW, DECREED THAT AND ! CAROLYN A. MANGOID DAVID E. MANGOLD ARE DIVORCED FROM THE 'BONDS Of MATRIMONY. ., IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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 BY THE ~OURT: ATT//~' '~/~ PROTHONOTARY