HomeMy WebLinkAbout04-5480
II
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LEON C. GETTLE,
vs.
CIVIL ACTION - LAW
NO. OLf- ~~ Po
DIANE M. SHIPP-GETTLE,
Defendant
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 foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 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
Telephone: (717) 249-3166
II
LEON C. GETTLE,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 0'1 - J-<f to
DIANE M. SHIPP-GETTLE,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that
in accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
II
LEON C. GETTLE,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. O'l.:5lJ fa
DIANE M. SHIPP-GETTLE,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, LEON C. GETTLE, by his attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is LEON C. GETTLE, an adult individual who currently resides at 4
Richland Lane, Apartment 206 in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is DIANE M. SHIPP-GETTLE, an adult individual who currently
resides at 32 Arrow Court in Jonestown, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 28 July 1993 in Indiantown Gap,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
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COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
s&.~~W~~
Attorney for Plaintiff
Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, Pa 1 7043
(717) 761-5361
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I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 1 8
Pa. C.S. 4904 (unsworn falsification to authorities).
Date: ;)/0<1
L~J;o
LEON C. GETTLE
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PLAINTIFF
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LEON C. GETTLE,
vs.
CIVIL ACTION - LAW
NO. 2004-5480
DIANE M. SHIPP-GETTLE,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
I, DIANE M. SHIPP-GETTLE, hereby accept service of the original Complaint in Divorce
: and acknowledge receipt of a copy of the Complaint.
Date: II---Cj .-6lf
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LEON C. GETTLE,
vs.
CIVIL ACTION - LAW
NO. 2004-5480 CIVIL TERM
DIANE M. SHIPP-GETTLE,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
29 October 2004 and served upon the Defendant on or about 9 November 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice
of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand
that the Court maintains a list of marriage counselors and that I may request the Court to
require my spouse and I to participate in counseling and, being so advised, do not request
that the Court require that my spouse and I participate in counseling prior to the divorce
becoming final.
I verify that the statements made in this Affidavit are true and correct and 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.
,1.-1-[itJ
J61illu:
DIANE M. SHIP
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LEON C. GETTLE,
vs.
CIVIL ACTION - LAW
NO. 2004-5480
DIANE M. SHIPP-GETTLE,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
29 October 2004 and served upon the Defendant on or about 9 November 2004.
2. The marriage of Plaintiff and Defendant is irretriHvably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the complaint
on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and 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.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LEON C. GETTLE,
vs.
CIVIL ACTION - LAW
NO. 2004-5480
DIANE M. SHIPP-GETTLE,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 IC) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorc<3 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 Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
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LEON C. GETTLE
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Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LEON C. GETTLE,
vs.
CIVIL ACTION - LAW
NO. 2004-5480 CIVIL TERM
DIANE M. SHIPP-GETTLE,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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 Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
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II
LEON C. GETTLE,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2004-5480
DIANE M. SHIPP-GETTLE,
Defendant
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PRAECIPE TO TRANSMIT RECORD
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IN DIVORCE
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TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court fa.t';ent~of
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown undHr Section 3301 (c).
2. Date and manner of service of the Complaint: Acceptance of ServicH filed bv Plaintiff's
counsel indicatinQ service on or about 9 November 2004 on Defendant.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent .required by Section 3301
(c) of the Divorce Code: By Plaintiff: 7 Februarv 200El By Defendant: 7 Februarv
2005
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
4. Related claims pending:
None.
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 Section 3301 (c) Divorce was filed
with the Prothonotary: Dated 7 Februarv 2005 filed contemporaneouslv herewith.
Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 7 Februarv 2005 filed contemporaneQusly herewith.
Date: 7 February 2005
~~
Samuel L. Andes
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
DECREE IN
DIVORCE
NOW'~ \<'
STATE OF
LEON C. GETTLE,
Plaintiff
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VERSUS
DIANE M. SHIPP-GETTLE,
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Defendant
AND
DECREED THAT
LEON C. GETTLE
PENNA.
NO.
2004-5480
2005 , IT IS ORDERED AND
, PLAINTIFF,
AND
DIANE M. SHIPP-GETTLE
, 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;
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ATTEST;
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PRO
ONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LEON C. GETTLE,
Plaintiff
: FILENO. 2004-5480
20
VS.
IN DIVORCE
DIAN~ M. SHIPP-GETTLE,
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that thel'P{i!.lfifl:ff/Defendant in the above matter, having
been granted a Final Decree in Divorce on the 15 th day of February
hereby elects to resume the prior surname of Shipp
and gives this written notice pursuant to the provisions of 54 P.S. 704.
DATE:
.1 /J.r!c ,)
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gna e
Si~na~b~]
COMMONWEALTH OF PENNSYL V AN1A
SS.
COUNTY OF CUMBERLAND
On the ..J) ,) ~_ day of ~~ d..M-C"'.w...M , 20~, before me, a
Notary Public, personally appeared the above affiant known(10 me to be the person whose name
is subscribed to the within document and acknowledged thatlB<i/she executed the foregoing for the
purpose therein contained.
In Witness Whereof, I bave hereunto set my hand and official seal.
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