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HomeMy WebLinkAbout02-0534JULIA A. STITZEL, Plaintiff MICHAEL W. STITZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : : NO., tgoQ- 2002 CIVIL TERM 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 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 marriage counselors is available in the Office of the Prothonatary, 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 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Respectfully Submitted, ABELN LAW OFFICES Brian P. Raney~ Attorney for the Plaintiff 37 E. Pomfret Street Carlisle, PA 17013 (717)245-2851 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. § 4904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. JULIA A. STITZEL, Plaintiff MICHAEL W. STITZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .' : CIVIL ACTION - LAW : IN DIVORCE .' : : No.- ao~ ~ 2002 civ,L T~ CERTIFICATE OF SERV/CE I hereby certify that I have this day served the foregoing COMPLAINT FOR DIVORCE by mailing a true and exact copy addressed to the following: Mike W. Stitzel 91 Cranes Gap Road Carlisle, PA 17013 Date Respectfully submitted, ABELN LAW OFFICES Darlene F. Cramer Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 JULIA A. STITZEL, Plaintiff Vo MICHAEL W. STITZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO.- 02~534 CIVIL TERM AFFIDAVIT OF CONSENT A complaint in divorce under {}3301 (c) of the Divorce Code was filed on the 29th day of January 2002. o The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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: ~(ia A. Stitzel, Plaintiff- JULIA A. STITZEL, Plaintiff MICHAEL W. STITZEL Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : NO.- 02-534 2002 CIVIL TERM 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 wiflaout 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: P~ntiff JULIA A. STITZEL, Plaintiff Vo MICHAEL W. STITZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO.- 02-534 CIVIL TERM 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 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 JULIA A. STITZEL, Plaintiff Vo MICHAEL W. STITZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO.- 02-534 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on the 29th day of January 2002. 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. JULIA ANN STITZEL, Plaintiff MICHAEL WILBUR STITZEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : NO. 02-534 CIVIL TERM AMENDED PRAECIPE TO TRANSM/'T RECORDS TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: a. irretrievable breakdown under § (3301(c)) 2. Date and manner of service of the complaint: 1/31/02. COMPLETE EITHER PARAGRAPH (A) OR (B) a. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff.' 5/13/03; by defendant 2/11/03. Related claims pending: None COMPLETE EITHER (A) OR (B) ......... mit b. Date plaintiff's Waiver of Notice was filed with the Prothonotary: 3/3/03. Date defendant's Waiver of Notice was filed with the Prothonotary: 3/3/03. Gregory BmXon Abeln, Esquire Attorney for Plaintiff 37 E. Pomfret Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS Cf CUMBERLAND COUNTY ST/~ TE Of PENNA. JULIA ANN STITZEL NO. 02-534 VERSUS MICHAEL WILBUR STITZEL DECREE iN DIVORCE AND NOW, -.~ ~}~ ~- ~--O , ~, IT IS ORDERED AND DecReeD That JULIA ANN STITZEL , PLAINTIFF, AND MICHAEL WILBUR STITZEL ,DEFENDANT, ARE DIVORCED FROM TIlE 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; bY THE COUR/T:/ / ~ ~OTHONOTARY