HomeMy WebLinkAbout02-0617BLANDA NACE, :
Plaintiff :
.
v. '
:
MARJORY NACE, :
Defendant :
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
No. 0a- 6 17
1N DIVORCE
NOTICE
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, High and Hanover Streets, Carlisle.
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
Phone: (717) 249-3166
BLANDA NACE,
Plaintiff
V.
MARJORY NACE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
No.
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Blanda Nace, who currently resides at 321 Bayley Street, Carlisle,
Pennsylvania, since November 8, 2001.
2. Defendant is Marjory Nace, who currently resides at 2502 Walnut Bottom Road, Carlisle,
Pennsylvania, since January 1, 1996.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married in November 18, 1995, in Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right
to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree in Divorce.
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. § 4904, relating to unsworn
falsification to authorities.
Blanda Nace, Plaintiff
By: /~~- ~-~
~K~i E. Rominger, Esquire
Attorney for Plaintiff
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
BLANDA NACE,
Plaintiff
V.
MARJORY NACE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
No. 02-617
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
February 5, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing 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 tree 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.
Blanda Nace/Plaintiff
BLANDA NACE,
Plaintiff
V.
MARJORY NACE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
No. 02-617
IN DIVORCE
AFFIDAVIT OF CONSENT
AND ACKNOWLEDGEMENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February
5, 2002, and I acknowledge receipt of a copy of the same, which was served on me on February 12,
2002, by Certified Mail.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. 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.
5. I have been advised of the availability of marriage counseling, and do not request that the
Court require that my spouse and I participate in said counseling.
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:
Marjory Nafe/D~.t~endant
BLANDA NACE, :
Plaintiff :
:
.
V. :
:
MARJORY NACE, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
No. 02-617
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
:
COUNTY OF CUMBERLAND )
AND NOW, this 15t~ day of May, 2002, I, Karl E. Rominger, Esquire, attorney for Blanda Nace,
Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce
Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the
same in the U.S. Mail, postage prepaid, certified, return receipt requested, restricted delivery. The
original return receipt card signed by the Respondent on February 12, 2002, indicating service was
effected, is marked Exhibit "A", attached hereto and made a part hereof.
Dated: May 15, 2002
By:
Karl E. Rominger, Esquire
Attorney for Plaintiff
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
I.D. # 81924
· Complete items ~ 2, and 3. Also comptete ~-'.:.
II~n.4 if Restricted Deltve~y is desired. .~.~ ..
~ Print your name and address on the revers~
~ that we can retum~the card to you. ·
· A#ach this card to the back of the mailpiece,
1. A~lcle Addressed to:
D. I$ delive~ address ffSfem~ fl~m item 17
ff YES, enter delivery address below:
RCer tif.~l Mail
egistered
[] Insured Mail
[] Express Mail
~.P, etum Receipt for Merchandl~
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4. Restricted Delivery? (Ex~a Fee) ll~{~fes
2. ~ Nu_mber (_Copy fror~ ~ I~ ~
~s Form 3811, Ju~ ~eee
102595-00-M-09~2
EXHIBIT "A"
BLANDA NACE, :
Plaintiff :
:
:
V. :
MARJORY NACE, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
No. 02-617
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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Certified mail, February 12, 2002.
3. Date of execution of the affidavit of consent required by § 3301(c) or The Divorce
Code: by the Plaintiff, May 13, 2002; by the Defendant, May 13, 2002.
4. Related claims pending: None
5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: May 15, 2002.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: May 15, 2002.
Date: May 15, 2002
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID No. 81924
iNTHE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE Of ~~~ PENNA.
Plaintiff
VERSUS
MARJORY NACE
Defendant
NO. 02-617 CIVIL - ACTION
DECREE IN
DIVORCE
BLANDA NACE
DECREED THAT
~0~_ , it IS OrDErED AND
, PLAI NTIFF~
AND
MARJORY NACE
,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;
None
BY THE COURT:
PROTHONOTARY