The URL can be used to link to this page

Home My WebLink About04-4434 Barbara Sump1e.Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774.1445 ELLEN W. NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 01./- 1I4JY CIVIL ACTION - LAW IN DIVORCE Qio~trEILl-J JOHN A NAEGELE, III., Defendant 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 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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, Pennsylvania 17013 (717) 249-3166 Barbara Sumple.Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774.1445 ELLEN W. NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. OL.{ - ill.f~Y c..,ut.L ~I CIVIL ACTION - LAW IN DIVORCE JOHN A NAEGELE, III., Defendant COMPLAINT IN DNORCE 1. PlaintiffisElIen W. Naegele, an adult individual residing at 994 Spa Road, Apt. 201, Annapolis, Maryland 21403. 2. Defendant is John A. Naegele, III, an adult individual residing at 2210 Warren way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on August 21, 1988 in Frackville, Schuylkill County, Pennsylvania. 5. There are no minor children born of this marriage. 6. The parties separated on July 24,2004. 7. There have been no prior actions for divorce or annulment between the parties. 8. 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 ofthe Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs I through 9, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with ~ 3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Ellen W. Naegele, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; and 2 Dated: B . Awarding other relief as the Court deems just and reasonable. bara Sumple-Sullivan, Esquire ttorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 3 Barbara Sumple.Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774.1445 ELLEN W. NAEGELE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 0'1-4'13'1 JOHN A NAEGELE, III., Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING 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 require 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. Dated: ~ . 'h-l) ~o+- ELLEN~~~~ Barbara SumpJe-Sul1ivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774.1445 ELLEN W. NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. JOHN A. NAEGELE, III., Defendant CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, Ellen W. Naegele, 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 I understand that any false statements made herein are subject to penalties of 18 Pa. C. S.A. Section 4904 relating to unsworn falsification to authorities. Dated;~~. ~ I ,2004 EIlen~~:g~l~ k ~k- ~~ - ~~ ..a ~ ~ - ..0 o 111 C ~ ~ ~ -:-~ j () .- c. ~. ", ro eel ,r V) rq -0 , c) ~l cG --1 -r: -, ~~~i~;l :LC;:; C~~lL.) ~._,.-- '-. ; ~,~- "<1 {.",J.CJ i":..;ITJ .' ~1.~ "1:J :x ';? co Barbara Sump Ie. Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774.1445 ELLEN W. NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4434 JOHN A. NAEGELE, III, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certifY that I served a copy of the Complaint In Divorce in the above-captioned matter by Unitt:d States Mail, Restricted Delivery, Certified No. 7003 05000001 65640142, Return Receipt Requested, on the above-named Defendant, John A. Naegele, III, on September 10, 2004 at Defendant's last known address: 2210 Warren Way, Mechanicsburg, Mechanicsburg, Pennsylvania 17050. The original receipt and return receipt card are attached hereto as Exhibit" A". I hereby certifY that the facts set forth above are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. S4904 relating to unsworn falsification ./ // Dated: September 13, 2004 rtJ :T r'I CJ :T ..D Ll1 ..JJ U S Postal Service CERTIFIED MAILM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) rr1 CJ CJ l'- _. iA()5i ...~ 0"1'.".. r...;;;'''' ~"'"". !!!1W 4d" "!Wi"} Po_. $ $0.60 r'I CJ CJ CJ Certified Fee Return Reciept Fee (Endorsement Required) C Restricted Delivery Fee o (Endorsement Required) Ll1 CJ Total postage & Fees $1.75 $3.50 $ S8.15 ~ EXHIBIT "An - (2 r--> 0 '7'::') 0.,::.'::1 -n '. , -"" -l (/) :c j"'" m -0 :9 A-' ~. -l7 b/ _I,. T. ZO ::i S:.~2 5>2 ,'--', ~ ~':-: ~ (:) ..... \P Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A ] 7070 (717) 774.1445 ELLEN W NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 04-4434 JOHN A. NAEGELE, III, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VlT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 1, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 5. I verity that the statements made in this affidavit a.re true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities DATE: ~/~/I! J ~n_ ck~ ~ NAEGELE ;~- 1 (- cu ;",':- :{ en Barbara Sumple.SulIivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717)774.1445 ELLEN W NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 04-4434 JOHN A NAEGELE, III, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREl!: UNDER 93301(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! 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 statement herein are made subject to the penalties of 18 Pa.C.S. !l4904 relating to unsworn falsification to authorities. DATE: ,~<< ~/oJ~ ho1~ ~ NAEGELE r'~.) , ,;..rl (- :::J ; II ('" ~'{~ t'.' , , (li ,. Barbara Sump Ie. Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 77 4.1445 ELLEN W. NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4434 JOHN A. NAEGELE, III, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 1, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 5. I verifY that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C. S.A. Section 4904 relating to unsworn falsification to authorities. DATE: {J/-06 -O.b NA.{.&E~~~? Cj "'-_.1 ,....} >":. ) C_" C) -, I L_ .,-~ M'l- ,i C) - I I. I \f .c ". ., en .,. Barbara Sumple.Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774.1445 ELLEN W. NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4434 JOHN A. NAEGELE, III, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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! 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 immediatdy after it is filed with the prothonotary. I verity that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S. ~904 relating to unsworn falsification to authorities. DATE: 01- (), -0..5 ~ N A. /A!.L&t1h- r'-.' '-- ---1 ~r _.;--- c:) >".) r (FI Barbara Sumple.Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 77 4.1445 ELLEN W NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 04-4434 JOHN A. NAEGELE, III, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infonnation, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under S3301( c) of the Divorce Code. 2. Date and manner of service of the complaint: United States Mail, Certified Mail, Restricted Delivery on September 10, 2004. 3. Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by Plaintiff: January 13,2005; by Defendant: January 6, 2005. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in S3301(c) DivOlrce was filed with Prothonotary: Jannary 14, 2005. Date Defendant's Waiver of Notice }~~~3 l(c) Divorce was filed with Prothonotary: January 14, 2005. / / /, / ~~ // Dated. January/] , 2005 I :~ ~=S"~W, 549 Bridge Street New Cumberland, P A 17070-1931 (717)-774-1445 Supreme Court ill #32317 Attorney for Plaintiff Barbara Sump Ie. Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774.1445 ELLEN W NAEGELE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4434 JOHN A. NAEGELE, III, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certifY that on this date, I served a true and correct copy of the foregoing Plaintiffs Praecipe to Transmit R4:cord, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: DATED: January /3 , 2005 Keith O. Brenneman, Esquirl~ Snelbaker, Brenneman & Spare, P.C. 44 West Main Street J Mechanicsburg, P A 17055 / ~ .~ / Barbara Surnple-Sullivan, Esquire l 549 Bridge Street New Cumbf:rland, P A 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff , <.:....rl c_ C:.' -;( l-" Ul :+;'f.:+::+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;/',. '+' '+' 'l';+; T:+: T;+; Of.:+: :+::+: :+: Of.:+: T + :+: + ;+; Of.:+: T:+: + :+: + :+: + :+::+: 'l':+: :+: + +:+ + Of. + + :+::+: :+: ;+;:+: + :+: + + + +:+: ++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , , , , , , , , . , , , . . . . ++'+''+'++++;+;+ '+'+:+:+:+:++++'+'+++++++++++++++++++++++++++++++~ :+::+;:+::+: . ... +:+::+;:+: .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ELLEN W. NAEGELE, Plaintiff VERSUS JOHN A. NAEGELE, III, Defendant AND NOW, DECREED THAT AND PEN NA. No. 04-4434 DECREE IN DIVORCE <j~.~ /'11- 2005 , IT IS ORDERED AND ELLEN W. NAEGELE , PLAINTIFF, JOHN A. NAEGELE, III , DEFEN DANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None. . :+::f.:f.:f. .. . . By THE COURTA~ {1~ - PROTHONOTARY J. ........~,.v-4-Tr;;;/ P ~ ~P'#~;L, 517, It:"", ~..~ ~4l- ~~V' 4/'/"1/ ~'ir;" I~/ , . Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 ELLEN W NAEGELE, Plaintiff . IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . NO. 04-4434 JOHN A NAEGELE, III., Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE is hereby given that Plaintiff in the above-captioned matter, having been granted a final decree in divorce on the 19th day of January ,20(17" hereby intends to resume and hereafter use the previous name of Ellen Wiley Sleat and gives this written notice avowing her intention in accordance with the provisions of the Act of 54 Pa. C.S, ~704. al,~ J1:1':'f '!/ & ~ Ellen Wiley Naegele TO BE KNOWN AS: /fo I}U~JtJt~ ~Viley Seat COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND On this, the 24th day of January , 2005, before me, a Notary Public, the undersigned officer, personally appeared Ellen W. Naegele, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the foregoing Notice ofIntention to Resume Prior Name for the purposes contained therein. TNESS WHEREOF, I hereunto set my hand and official seal. /'NOT UBLIC . My Commission Expires. NOWlW. WWA SUMPlE-lUWYAH Notary N:lIc UMllBllAND 8OIOUC~ COUNIV Comm Noll 16. 200' (SEAL) ?V (.J ;S 1 ~ 8 "- ....... ~ ~ ~ ...... -.() -..0 ...... f € --( - Ot.c~' CUL' 0~~ r::c. ~~~; ~:i '-, C) c,: ....., CJ C::.J CJ"I ~:t;~ -I ::I::-n jTli'::::-~ -nf.!i -.']\. , (~.I') ;:I'" >",.j{ "..),., !::s r~t~ <- > :;-: N (J1 ""'D r.n 0"'1 :~:~ .1.) .<