HomeMy WebLinkAbout02-0601BRENDA S. RESSLER,
Plaintiff
VS.
DOUGLAS K. RESSLER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
No.
CML ACTION - LAW
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
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
Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania
17013.
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
BRENDA S. RESSLER,
Plaintiff
DOUGLAS K. RESSLER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
No.
CIVIL ACTION - LAW
IN DIVORCE
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas
expuestas en las pfiginas siguientes, debe tomar acci6n con prontitud. Se le avisa que si no se defiende,
el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por
la Corte. Una decisi6n puede tambi6n ser emitida en su contra por cualquier otra queja o compensaci6n
reclamados por el demandant. Usted puede perder dinero, o propiedades u otros derechos importantes
para usted.
Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio,
usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales estfi disponible en la
oficina del Prothonotry, en la Cumberland County Courthouse, One Courthouse Square, Carlisle,
Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE
DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A
RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE
O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO
PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
BRENDA S. RESSLER,
Plaintiff
VS.
DOUGLAS K. RESSLER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
..
NO.
.*
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE
COUNT I
AND NOW, this ~,~~day of ~ ,2002, comes the
Plaintiff, Brenda S. Ressler, by her attorney, Jan~. Alexander, Esqui}e, an~lles this Complaint upon
a cause of action of which the following is a sta~e, vt~ent.
1. Plaintiff is Brenda S. Ressler, 36 years of age, who currently resides at 165 15th Street, New
Cumberland, Borough of Cumberland, Cumberland County, Pennsylvania, 17070.
2. Defendant is Douglas K. Ressler, Jr., 37 years of age, who currently resides at 165 15th
Street, New Cumberland, Borough of Cumberland, Cumberland County, Pennsylvania, 17070.
3. Plaintiff and Defendant have both resided in the Commonwealth of Pennsylvania for at least
six (6) months prior to the filing of the Complaint in Divorce.
4. The Plaintiff and Defendant were married on October 21, 1989 in Cumberland County,
Pennsylvania by a minister.
5. There was a child born between the parties during the marriage; Courtney Ressler, age 10,
born April 19, 1991.
6. There were no prior actions in divorce or annulment commenced by the parties.
7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and
property division.
8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through
no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows
the bonds of matrimony.
and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to
render her condition intolerable and life burdensome.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from
COUNTII
10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference
and made a part hereof.
11. The marriage is irretrievably broken.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from
the bonds of matrimony.
COUNT III
12. The allegations of Paragraph one (1) through nine (9) and Paragraphs ten (10) and eleven
(11) are incorporated herein by reference and made a part hereof.
13. Plaintiff and Defendant have acquired property, both real and personal during their
marriage.
14. Plaintiff and Defendant have been unable to agree as to an equitable division of said
property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property of whatsoever kind and wheresoever situate and for such further relief as the Court may deem
equitable and just.
Respectfully Submitted,
Ja~e M. Alex~d~d~r, L~squir~
Attorney for ~he Plaintiff
I.D. No. 07355
148 S. Baltimore Street
Dillsburg, PA 17019
(717) 432-4514
VERIFICATION
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 un-sworn
falsification to authorities.
Date: B~'nd~a~~~
COMMONWEALTH OF PENNSYLVANIA :
: S.S
COUNTY OF YORK :
Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and
County, Personally appeared Brenda S. Ressler who, being affirmed according to law, deposes and
says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her
knowledge, information and belief.
,/B~dhda S. Res~ier
Sworn to and subscribed before
me this ~0 ~'2L day of
,2002.
Notary Publ
I Notarial Seal
Halyard E. Alexander, Notary Publlo
DIIlaburg Boro, Yo¢¢ County
My Commission Expires Apr. 23, 2005
Malff~er, pennsylvania Association ot Notmies
BRENDA S. RESSLER, :
Plaintiff :
:
vs. : NO. 2002-601
:
DOUGLAS K. RESSLER, JR., : CIVIL ACTION - LAW
Defendant : IN DIVORCE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
AFFIDAVIT OF SERVICE
AND NOW, this E?~day of ~~4~~/~ 2002 personally
/
appeared Jane M. Alexander, Esquire who swears according to law, that ~'~'ue and correct copy
of a COMPLAINT IN DIVORCE was caused to be served by certified mail with return receipt
requested upon the said,
Douglas K. Ressler, Jr.
165 15th Street
New Cumberland, PA 17070
on February 7, 2002 by leaving the same at the Dillsburg Post Office with postage pre-paid
thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part
hereof.
Esquire/
[ ~kttomey I.D(~#07355
~ ~48 S. Baltimore Street
'xxjDillsburg, PA 17019-0421
(717) 432-4514
Sworn and subscribed before
me this ~ ~ day of
Notary Public
HaJvard E. Alexander, Notary Publ~
DIIIsbur9 Boro, York County
My Commission Expires Apr. 23, 2005
Memi0ef, Pennsylvania Associati~ of Notaries
BRENDA S. RESSLER,
Plaintiff
VS.
DOUGLAS K. RESSLER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
NO. 2002-601
CIVIL ACTION ~ LAW
IN DIVORCE
"~C°~P~. ~e item~ 1 and~r 3 for edditlO~al servlcea ' ~ I al~ wi~ to ~eive ~e
~ ,~ ~ ~ ~of ~ ~.~,~ ~ n~ e~ra ~e):
C~su~ ~a~r ~r fee.
~ Ex~e~ Mail ~ In~r~
a~ ~ /s ~)
~c~-~ ~ Return Receipt
BRENDA S. RESSLER,
Plaintiff
VS.
DOUGLAS R. RESSLER, JR.,
Defendant
TIlE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
:
NO. 02-601
:
: CIVIL ACTION- LAW
: INDIVORCE
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this ~' ,~ay of ~~2 , 2004, by and
betxveen Brenda S. Ressler of 143 15th Street, No. 3, New Curr~erland, Cumberland County,
Pennsylvania 17070 (hereinafter referred to as "WIFE") and Douglas K. Ressler, Jr. of 110
Pleasant View Terrance, New Cumberland, Cumberland County, Pennsylvania 17070
(hereinafter referred to as "HUSBAND".)
WITNESSETH: WHEREAS, HUSBAND and[ WIFE were lawfully married on
October 21, 1989 in Cumberland County, Pennsylvania. WIFE instituted an action in divorce
to No. 02-60l in the Court of Common Pleas of Cumberland County, Pennsylvania on
February 4, 2002. The pleadings in the case requested dissolution of the marriage between
the two parties and for such further relief that the Court may deem equitable and just; and
WHEREAS, the parties have reached an agreement as to the settling of all matters
relating to the divorce and to the custody and support of their child bom of this marriage,
Courtney Ressler, born April 19, 1991, 12 years of age.
NOW, THEREFORE, in consideration of the promises and the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable
consideration, receipt of which is hereby acknowledged by each of the parties hereto,
ItUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as
follows:
1. The parties intend to maintain separate and permanent domiciles and to live apart
Page I of 7
from each other. It is the intent and purpose of this Agreement to set forth the respective
rights and duties of the parties while they continue to live apart from each other.
2. The terms of this Agreement and their effect have been fully explained to the
WIFE by her counsel, Jane M. Alexander, Esquire. HUSBAND has been advised as to his
right~ duties and responsibilities under the term of this agreement and their effect have been
fully explained by his counsel, Susan Kay Candiello, Esquire. The parties acknowledge that
they have received independent legal advice from counsel of their choice and have been fully
inlbrmed as to their legal rights and obligations or have chosen not to do so. The parties
understand the facts and acknowledge and accept this Agreement as fair and equitable.
3. The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard tc, the rights of each party. It is the
intent of the parties that such division shall be final and shall forever determine their
respective rights. The division of existing marital property is intended by the parties to
constitute in any way a sale or exchange of assets, and the division is being affected without
the introduction of outside funds or other property not constituting a part of the marital estate.
4. Neither party shall molest, harass, annoy, injure, threaten or interfere with the
other party in any matter whatsoever. Each party may carry on and engage in any
employment, profession, business or other activity as he or she may deem advisable for his or
her sole use and benefit. Neither party shall interfere wilh the uses, ownership, enjoyment or
disposition of any property now owned and not specifiedl herein or property hereafter
acquired by the other.
5. The consideration for this contract and agreernent is the mutual benefits to be
obtained by both of the parties hereto and the covenants and agreements of each of the parties
to the other. The adequacy of the consideration for all agreements herein contained is
stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound
hereby.
Page 2 of 7
6. DEBTS OF THE PARTIES:
It is further mutually agreed and understood by and between the parties that all
oint debts have been paid including open accounts, credit cards, and bank liabilities except
as hereinafter set forth:
6.1) HUSBAND shall assume all liability for and pay and indemnify the WIFE
against liability for all debts and bills in his name alone, particularly those incurred since date
of filing Complaint in Divorce.
6.2) HUSBAND has agreed and does hereby agree to accept full responsibility for
payment of the unpaid marital debts listed on Schedule "A" attached hereto and made a part
hereof. HUSBAND agrees to make all payments in a prompt time so as to avoid late charges
and impairment of their party's respective credit rating and to hold WIFE harmless from any
liability in regard to any of said debts.
6.3) WIFE shall assume all liability for and pay and indemnify the HUSBAND
against liability for all debts and bills in her name alone, particularly those incurred since date
of filing Complaint in Divorce.
6.4) WIFE has agreed and does hereby agree to accept full responsibility for
payment of the unpaid marital debts listed on Schedule "B" attached hereto and made a part
hereot: WIFE agrees to make all payments in a prompt time so as to avoid late charges and
itnpairment of their parties' respective credit rating and to hold HUSBAND harmless from
any liability in regard to any of said debts.
7. PERSONAL PROPERTY:
As to all items of personal property which the parties have divided to their mutual
satisfaction, henceforth, each of the parties shall own, have and enjoy independently of any
claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are now owned or held by or which may hereafter
belong to the HUSBAND or WIFE, with full power to the HUSBAND or the WIFE to
Page 3 of 7
dispose of same as fully and effectually, in all respects and for all purposes as if he or she
were not married. Specific disposition of major items or personal property is as follows:
7.1) Bank Accounts:
Each party has opened and maintained their own separate bank accounts since
the time of separation. Neither party will make a claim against those funds.
7.2) Vehicles:
a) HUSBAND shall retain possession, title, and sole ownership of his 1995
Jeep Wrangler and with a Kelly Blue Book value of $3,600.00 and shall be responsible for
the balance due on the IVCFCU loan and save WIFE harmless from any liability or
responsibility for payment of said debt.
b) WIFE has possession of the 2000 Chevrolet Malibu Sedan, which has a
Kelly Blue Book value of $5,885.00. WIFE has been making the payments on the loan on
this vehicle. WIFE shall be responsible for payment ofl:he balance and save HUSBAND
harmless from any liability or responsibility for payment of said debt.
7.3) Household fumishin3~:
The parties have divided the household fi~rnishings to their mutual
satisfaction.
7.4) Pensions, Stock options, Retirement funds, IRAs:
a) HUSBAND states that he has no retirement plan.
b) WIFE has IRA with a value of $I,065.16. HUSBAND agrees to make no
claim against said funds..
8. SPOUSAL SUPPORT/ALIMONY:
Neither party has or will make claim for spousal support and/or alimony.
9. CHILD SUPPORT:
Support for Courtney Ressler has and will continue to be established by the action
in support in the Domestic Relations Section of the Couvl of Common Pleas of Cumberland
Page 4 of 7
County, Pennsylvania with an order entered to No. 00135-DR-03, PACSES Case Number
143105 ! 98 on December 22, 2003, which may be amended as conditions warrant.
10. CUSTODY OF THE CHILD:
There is no court order providing for custody of Courtney Ressler. It is agreed by
the parties that WIFE shall have legal custody and primary physical custody of the child with
HUSBAND having visitation at such time as the parties, agree. Neither parent will dispute
the providing of psychotherapy for Courtney until age eighteen (18) as long as it is
recommended by a physician or therapist.
11. BANKRUPTCY:
The parties hereby agree that the provisions of this Agreement shall not be
dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained
herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of
any obligations assumed hereunder, the other party shall have the right to declare this
Agreement to be null and void and to terminate this Agreement in which event the division of
the parties' marital assets and all other rights determined by this Agreement shall be subject
to court determination the same as if this Agreement had never been entered into.
I2. STATUS OF SETTLEMENT:
The property settlement as provided herein between the parties shall be considered
an equitable distribution of marital property and both pm'ties waive any and all rights or
claims, which they may have been entitled to raise with respect to the issue of equitable
distribution under the Provisions of the Pennsylvania Di¥orce Act.
13. The parties agree that simultaneously with the signing of this Agreement they
will sign the necessary affidavits of consent and affidavits acknowledging notice of marriage
counseling in order to conclude the divorce action filed by WIFE under the no-fault
provisions of the Pennsylvania Divorce Act.
14. The waiver or unenforceability of any term, condition, clause or provision of this
Page 5 of 7
Agreement shall in no way be deemed or considered to be a waiver of or forfeiture of right to
enIbrce any other term, condition, clause or provision of this Agreement.
15. This Agreement shall be construed and interpreted according to the laws of the
Commonwealth of Pennsylvania.
16. It is understood and agreed that the heirs, administrators, executors and assigns of
thc parties hereto shall be bound by all the terms, cond/itions, clauses and provisions of this
Agreement.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day
and year first above written, intending to be legally bound.
uire /7~ renda ,'~. ~(bssl}~, Plaintiff
Attorney fo~. ~nt Douglas pessler, Jr., ~::~t
Page 6 of 7
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS:
On this, the ~;~-~ day of ,~20,a-~ u-- ,2004, before me, a Notary Public
for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared Brenda S.
Ressler known to me (or satisfactorily proven) to be the person whose name is subscribed to the
within Marital Property Settlement Agreement, and acknowledged that she executed the same for
the purpose therein contained.
IN WITNESS WHEREOF, I have set my hand and note~al seal.
,~&ary Public
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
M1- Notarial Seal
{alvatd E. Alexander, Notary Public
Dil/s .~ Bom, York County
y CommJsslon Expires Apr. 23, 2005
Ma~ber, Ponnsyivania Association of Notaries
SS:
COUNTY OF CUMBERLAND
· ~ ·
On thzs, the ~ day of /~r~ I ,2004, before me, a Notary Public
for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared Douglas
R. Ressler known to me (or satisfactorily proven) to be the person whose name is subscribed to
the within Marital Property Settlement Agreement, and acknowledged that he executed the same
for the purpose therein contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
Notary Public
My Commission Expires:
I Gail p. Minnich, Nokqry Public ]
I MeChanicsburg Bo,o C , 'be ~ ~
' "~nd ~un~ ]
SCHEDULE A
DEBTS TO BE ASSUMED BY DOUGLAS
West Shore Emergency $350.00
Holy Spirit Hospital $243.60
PPL Electric $210.82
Bell Atlantic f $541.00
Utility Company $119.00
Bell Atlantic Telephone $128.00
Blue Mountain Anesthesia $117.00
10 Bell Atlantic $105.00
Verizon $103.00
Verizon $103.00
10 Bell Atlantic $100.00
Bell Atlantic $81.00
Quantum Imaging $63.00
Pinnacle Medical Service $50.00
Crystal Springs Water $128.00
Endontics Association $30.00
SCHEDULE B
DEBTS TO BE ASSUMED BY BRENDA
Brice Arndt Dentist
Capitol One Bank
Chartwood Dental Center
American Water
Members 1st Credit Union
Kearns & Ashley
Silver Springs Dental
P.P.&L
Pinnacle Medical Services
( Counseling for Courtney
8 bills at $90.00 each)
$663.00
$813.00
$287.00
$210.00
$192.00
$101.00
$130.00
$1,465.00
$720.00
BRENDA S. RESSLER
Plaintiff
VS
DOUGLAS K. RESSLER
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
NO. 02-601
CIVIL ACTION-LAW
IN DIVORCE
WAIVER OF NOTICE OE INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER CODE 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.
Date: if ' ~ ~ Oq
· - DoUglas' K. Ressldr-
BRENDA S. RESSLER
Plaintiff
VS
DOUGLAS K. RESSLER
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
NO. 02-601
CIVIL ACTION-LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER CODE SECTION 3301(C) OF TI-IE 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 o authormes. ~ · ~
Date:4/q/04 .
,/ Brenda S. Ressler
BRENDA S. RESSLER
Plaintiff
VS.
DOUGLAS K. RESSLER
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
NO. 02-601
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 30, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from date of filing and service of the Complaint.
3. I consent to the entry of a final decree of dtivorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in the 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.
Date:
/ / x~ Brenda S .~R'es sler
BRENDA S. RESSLER
Plaintiff
VS.
DOUGLAS K. RESSLER
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
biO. 02-601
CIVIL ACTION - LAW
115I DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 30, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from 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 the 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.
Date:
Dot~gias I~. Ressl[r
BRENDA S. RESSLER,
PLAINTIFF
VS.
DOUGLAS K. RESSLER,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
:
: NO. 02-601 CIVIL
:
: CIVIL ACTION - LAW
: 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 §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: was sent certified mail, restricted
delivery on February 5, 2002 and was served to the Defendant on February 7, 2002
N/A;
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent require by §3301(c) of the Divorce
Code: by Plaintiff_April 9, 2004; by defendant_April 9, 2004.
(b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code:
(2) (a) Date of filing of Plaintiff's affidavit upon respondent: N/A.
(b) Date of service of the plaintiff's affidavit upon the defendant: N/A.
4. Related claims pending: All claims are settled and satisfied by Marriage Settlement
_Agreement dated April 6, 2004 signed by both parties.
5. (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:
(b) Date Plaintiff's Waiver of Notice in Divorce was :filed with the Prothonotary:
_April 14, 2004.
(c) Date Defendant's Waiver of No~f~e in Divorce was filed with the Prothonotary:
IN THE COURT OF COMIMON
BRENDA S. RESSLER,
PLA ll~TIFF
OF CUMBERLAND COUNTY
STATE OF PENNA.
VERSUS
DOUGLAS K. P, ESSLER,
DEFEND~
N O. 02-601
PLEAS
Civil
DECREE IN
AND NOW,
DECREED THAT
DIVORCE
BRENDA S.
It IS ORDERED AND
, PLAINTIFF,
AND
DOUGLAS K. RESSLER
, 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;
PROTHONOTARY