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HomeMy WebLinkAbout05-2278 : IN THE COURT OF COMMON LEAS OF : CUMBERLAND COUNTY, PE NSYLVANIA : NO. 05-;2..2/1 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE II Sean Detwiler, Plaintiff v. Angela Detwiler, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the clai s set forth in the following pages, you must take prompt action. You are warned that i you fail to do so, the case will proceed without you and a decree in divorce or annulm nt may be entered against you for any other claim or relief requested in these papers y the Plaintiff. You rnay lose money or property or other rights important to you, . eluding custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakd wn of the marriage, you may request marriage counseling. A list of marriage counsel rs is available in the Office of the Prothonotary at the First Floor, Cumberland C nty Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MAR TAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS RANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. I YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPH NE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEG L HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 II '1 Sean Detwiler, Plaintiff v. : IN THE COURT OF COMMON LEAS OF : CUMBERLAND COUNTY, PEN SYLVANIA : NO. 05- ,)).. '1i CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE Angela Detwiler, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Sean Detwiler, an adult individual, whom reside ce prior to enlistment in to the United State Navy was been 336 E. Burd Street, Shi pensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Angela Detwiler, an adult individual, currently esiding at 1739 Trenton Ave, Bremerton, Washington 983105-5065. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsy vania and has been so for at least six months immediately previous to his enlistmen in to the United States Navy; at no time has the Plaintiff changed his place of do icile and residence from Shippensburg, Pennsylvania regardless of his changed locati n due to his performance of duties in the United States Navy. 4. Defendant is a bonafide resident of Bremerton, Washington. 5. Plaintiff and Defendant were married on March 20, 1998 a Kitsap, Washington. 6. There have been no prior actions for divorce or annulment bet een the parties. 7. The Plaintiff, Sean Detwiler is in the United States Navy. 8. The parties' marriage is irretrievably broken. 9. A child was born during this marriage on October 13, 1999 and th child's name is Christion Detwiler. 10. The Plaintiff disputes the paternity of the child, Christion Detwiler. 11. The Plaintiff has been advised of the availability of counseling a d the right to request that the Court require the parties to participate in counseling. K wing II I ~ this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 12. Plaintiff requests the Court enter a Decree of Divorce. 13. Plaintiff and Defendant are citizens of the United States of A erica. 14. The parties have lived separate and apart since June ,1999 and continue to live separate and apart as of the date of this Complaint. 15. Plaintiff desires a divorce based upon the belief that Defend nt will, after ninety days from the date of the filing of this Complaint, consent to this divor e. WHEREFORE, Plaintiff prays this Honorable Court to enter an orde dissolving the marriage between the parties. Respectfully Submitted TURO LAW OFFICES Galen R. Waltz, Es 28 South Pitt StE Carlisle, PA 17013 (717) 245-9688 ext 22 Attorney for Plaintiff shJ~- Date c II 'I VERI FICA TION . I verify that the statements made in the foregoing Divorce Complai t are true and correct. I understand that false statements herein made are subject to th penalties of Pa.C.S. 94904 relating to unsworn falsification to authorities. S~.3~S Date' Sean C. Detwiler II '. CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Compl int in Divorce upon Angela Detwiler, by mailing same certified return receipt on the .J/}I,. day of /7?4 y , 2005, from Carlisle, Pennsylvania, addressed as follows: / Angela Detwiler 1739 Trenton Ave Bremerton, Washington 983105-5065. TURO LAW OFFICES j )/ Galen R. Waltz, Es 28 South Pit! Stre Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 ~ ~ ^~ f\ "-.... ~ l...I ~ >.J ""'- "" ~ ~ ~ ""'- ~ ~ '"', " n (..' i,~ .' :::;:.. ~~~~ -(' "', ~:;Jo ..;;:;;;.. cr' (J -n .-1 :'T,1 rn..'. r- -,~,n, '<r; /"'\ ,,;[1. (\: ).,...........' , ...1) ~ t.5rn -'~ _..c;: I W -0 -'-l... Cl N ,'n Sean Detwiler, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-2278 CIVIL TERM Angela Detwiler, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Complaint in Divorce filed in the above captioned case upon Angela Detwiler, by certified mail, return receipt requested on or about May 3, 2005 addressed to: Angela Detwiler 1739 Trenton Ave Bermerton, Washington 983105-5065 and did thereafter receive same as evidenced by the attached Post Office receipt card dated May 5, 2005. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES J;?~)(}.) Date alen R. Waltz, Esquire 28 South Pitt Street , Carlisle, PA 17013 (717) 245-9688 Attorney for xxxx ~ < ~ II Sean Detwiler, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-2278 CIVIL TERM Angela Detwiler, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (f) 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. O. r. , L./ M <-<>^<e_+ "" +k e~+r '6 A.. 1J."..- 'tJ n'J 4' ,....... s ^~+ p('~J :_+ 1;: +;...,~ s...,tc''C-- c. k:1 J. ~'-<f'f'4 c~ w-,L..~../u-- s+..+... I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING i \J UNSWORN FALSIFICATION TO AUTHORITIES. ; II I~n I (lL) Dae I ~ f7f'a ~ d-RnLL r / ~Detwiler " Sean Detwiler, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-2278 CIVIL TERM Angela Detwiler, Defendant : 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: Certified, Returned Receipt mail delivered on or about May 10, 2005. 3. Date of execution of the Affidavit of Consent required by ~3301 (c) of the Divorce Code. - ~ By Plaintiff: I:l.CCrYI lJ?r I), Jets By Defendant: J\)o,,,,m tx? :70 I Jef.h 4. Related claims pending: None. Date the Waiver of Notice in ~3301(c) divorce was filed with the Prothonotary: By Plaintiff: f)(l!fYlh,.', /J, Jt.X:tBy Defendant: r\'?cemttcr)) ,.iU))'~ , , ) ?~~~~~~~~~~~~~~~~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + ,+ .+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + .:+ . . Of :+ . + ;+::+.:+ ~ ~. ~:+:+~~:+~+:+~~~~++~~:+~:+~++~~+.+.+.+.+.++:++~:++++:++++++:++++:+++~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. Sean Detwiler, Plaintiff No. OS'-J.{d7F! VERSUS lln'Je1", nprwilpr, Defendant DECREE IN DIVORCE AND NOW, . 7;~ 1'1 , 2005_, IT IS ORDERED AND DECREED THAT Sean Detwiler .' PLAINTIFF, AND Anqela Detwiler , DEFENDANT, ARE DIVOFlCED 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 OU:;J T~~ . ~ , ~ 'lpeO'"O"OTA"' ++++++~+.++:++++++.~+++.~++:+.+~+..++ + + + + + + + + + + + + + + + + + + J. ~) k!7 .J? /f:T-'PY4" 7,;;!L. ~~ ;;?/7~w'~) f~?/ 5"C /;>/ '1;"/ ')., "'/ G ,.- - . "/1' -' c..;. - -.' .