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HomeMy WebLinkAbout01-4925ANTHONY L. NELSON SUSANNE L. NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO.OI.-~q,2~.~ CIVIL TERM :: 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 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 COURTHOUSE, 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 Dated: ~"'~o~1/~/ ances H. Del Duca 10 West High St. Carlisle, PA 17013 ANTHONY L. NELSON V. SUSANNE L. NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO.tD/-,qc~o2,S- CIVIL TERM :: IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Anthony L. Nelson, who resides at 134 North Hanover Street, Apartment 1, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Susanne Nelson, who resides at Box 138, Roaring Springs, Blair County, Pennsylvania, 16673. 3. Plaintiff Anthony L. Nelson has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married in November 1997 in Spring Lake, North Carolina. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. Dated: "Frances H. lJel Duca, Esq. Attorney for Plaintiff 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 10 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: nthony L. Nelson ANTHONY L. NELSON V. SUSANNE L. NELSON :: 1N THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. OI-/-/c?,=.2,~ CIVIL TERM :: :: IN DIVORCE NOTICE AND AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. 1. The parties to this action separated August, 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this affidavit are true and correct. U understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: ~-~//o/ ~r~,- ~ A~thony L. Nelson ANTHONY L. NELSON SUSANNE L. NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. E2)/- 6/(?,,2x5 CIVIL TERM :: IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. IfI fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counteraffidavit 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. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. Dated: ~"/g//O [ L. Nelson ANTHONY L. NELSON V. SUSANNE NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-4925 CIVIL TERM :: :: IN DIVORCE _NOTICE TO DEFEND AND CLAIM RIGHT,,; 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 proce~ without you and a decree of divorce or annulment may 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 COURTHOUSE 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 Dated: ances H. Del Duca #06265 -- 10 West High St. Carlisle, PA 17013 ANTHONY L. NELSON V. SUSANNE NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-4925 CIVIL TERM :: :: 1N DIVORCE ~AMENDED COMPLAINT * COMPLAINT UNDER SECTION 3301 c OR 3301 d OF THE DIVORCE CODE Apartment 1, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Susanne Nelson, who resides at 217 Filbert Street, Apartment 12, Milton, Pennsylvania, 17847. 3. Plaintiff Anthony L. Nelson has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) monthsdmmediately previous to the filing of this complaint. Plaintiff is Anthony L. Nelson, who resides at 134 North Hanover Street, 4. The plaintiff and defendant were married in November 1997 in Spring Lake, North Carolina. parties. There have been no prior actions of divorce or for annulment between the 6. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. Dated: ~ *See Exhibit "A" trances H. Del Duca, esq. Attorney for Plaintiff 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 10 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: 8u~nne Nebon 217 Filbert Street Apt 12 Milton, PA, 17847 Augur27,2001 Frances H. Del Duca Attorney At Law Ten West High Street Carlisle, PA 17013 Dear Sir, In reply to your divorce paperwork dated 8/21/01, NO. 01-4925, Anthony L. Nelson v. Susanne L. Nelson. I talked to Mr. Nelson on 8/23/01, when he tried to gat me to sign this paperwork. I explained to him that Suzanne L. Nelson is not my correct name, and that such important documents as these, need to have my correct name on them. I went to Yocum's Motor Sports Shop to have these notarized, and he won't do it because of the name discrepancy. You may contact him at S. Front & Lower Markat Street, Milton, PA 17847. (570) 742-4706. My full correct name is Susanne Nelson. Thero is no middle name or initial, and no z in my name. Thank you, Susanne Nelson E~{IBIT "A" ANTHONY L. NELSON V. SUSANNE NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-4925 CIVIL TERM :: :: IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): V// (a) I do not oppose the entry cfa divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): '~ (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divome Decree, the divorce decree may be entered without further notice to me and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counteraffidavit are tree 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. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. Dated: ~_ f~,.,~..~.~/ Susanne Nelson ANTHONY L. NELSON SUSANNE NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: 4t¢~$ :: NO. 01-40z~ CIVIL TERM :: :: IN DIVORCE AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA :: SS COUNTY OF CUMBERLAND :: ANTHONY L. NELSON, being duly sworn according to law, deposes and says that he is the Plaintiff in the above divorce action and that he served the Complaint in Divorce in the above matter on the Defendant, Susanne Nelson, by hand delivering a tree and correct copy of said Complaint to her on August 23, 2001, at the Domestic Relations Office, Northumberland County, 370 Market Street, Sunbury, Pennsylvania. AJa~hony L. Nelson SUBSCRIBED and sworn to before me this a~Pqffflay of~ ~' , 2001. 14otary Publ~" ~/ ANTHONY L. NELSON SUSANNE NELSON :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-44~ CIVIL TERM :: :: IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 1. (a) The correct date of our marriage is December 27, 1996, in Lillington, Harnett County, North Carolina, not as stated in the Complaint. 2. I understand that I may lose fights 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 divomed 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: Susanne Nelson, Defendant