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