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Home My WebLink About05-2765IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Leah H. Metzler, : No. Plaintiff Civil Action - Law VS. Michael L. Metzler : In Divorce Defendant 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 in divorce or annulment may be 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 the custody or visitation rights of your children. When the ground for 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. 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 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 • 1• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Leah H. Metzler, Plaintiff : No. OS - a7( S VS. : Civil Action - Law Michael L. Metzler : In Divorce Defendant COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Leah H. Metzler who currently resides at 225 East Garfield Street, Shippensburg, Cumberland County, Pennsylvania, since August 30, 2004. 2. Defendant is Michael L. Metzler who currently resides at 100 Cheyenne Drive, Apt. G, Greensboro, North Carolina, since January 13, 2005. 3. Plaintiff and Defendant have been bona fide residents in 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 August 7, 1993, at Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. I verify that the statements made in this Complaint are true and correct. 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: j-,2 -- O S ,1eah H. Metzler 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 of divorce. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Suite 3 Shippensburg, PA 17257 (717)-532-3270 _lU C r ? l { n i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA ?? 5 Leah H. Metzler, : No. 05 Civil Term Plaintiff Civil Action - Law Vs. Michael L. Metzler Defendant In Divorce AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Michael L. Metzler, of 100 Cheyenne Drive, Apt G., Greensboro, North Carolina, 27410-6501, certified mail, return receipt requested on June 1, 2005 and was accepted on delivery by Michael L. Metzler on June 6, 2005. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 r?. o- 0 v I O Q' M 0 Lin 0 C N M1 LL r 00 ce) ti LL 6 12 ?$w?orn to and subscribed this 6W day of , 7005. Notary Ic My Commission Expires: WIMMIAL SEAL DARQIE A. NEIL, NOWy F WIC w TO ?: - Tsn ..L C1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Leah H. Metzler, CIVIL ACTION - LAW Plaintiff, No. 05-2765 - Civil Term V. Michael L. Metzler, Defendant, IN DIVORCE a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301(c) of the Divorce Code was filed on May 26, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 0301(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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. Date: ?. 06-, Leah H. Metzler, Plaintiff J 1544050 i.,'z :.v C, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Leah H. Metzler, CIVIL ACTION - LAW Plaintiff, No. 05-2765 - Civil Term V. Michael L. Metzler, Defendant, IN DIVORCE a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301(d) of the Divorce Code was filed on May 26, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: dlay/ooo(p Michael L. Metzler, Defendant 1544050 IN THE COURT OF COMMON PLEAS OF' CUMBERLAND COUNTY, PENNSYLVANIA Leah H. Metzler, ) Civil Action - Law Plaintiff, ) vs. ) No. 05-2765 - Civil Term Michael L. Metzler, ) Defendant, ) In Divorce a v.m. 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: June 6, 2005 -Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, February 24, 2006; by Defendant, February 24, 2006. 4. Related claims pending: Resolved through private Agreement; 5. (a) Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 24, 2006; (b) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 24, 2006. BARLEY SNYDER LLC By. ` l M a B. Walker, Esquue Attorney I.D. #15989 247 Lincoln Way East Chambersburg PA 17201 (717)264-6494 Attorney for Defendant 1573044-1 IN THE COURT OF COMMON PLEAS s J OF CUMBERLAND COUNTY STATE OF PENNA. wk w c v Leah 14. Metzler, 05-2765 No. r Plaintiff- 7.; vel-sus i s J Michael L. Metzlet^,_ _ - - _ f ti ?f Defendans- , _ ti { o? + ` DECREE IN i : DIVORCE ' ?i ........ , 19 2Q0.6 . , it is ordered and .... M za .. L-J. AND NOW ti , , ............................... . decreed that METZLER plaintiff, ................ defendant, and .. MICHAEL. L.. MET2LER........ . ?i are divorced from the bonds of matrimony. '! to The court retains jurisdiction of the following claims which have 7 been raised of record in this action for which a final order has not yet io been entered; i ................................................................... is s J iq By Th /C tart: Attest: 6 Ii 0 Prothonotary ,7 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Leah H Me-?z\er Plaintiff Vs File No. OF - 21 h 5 IN DIVORCE M?chG I L. M ?z1er Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated 3 - , -l - p to , hereby elects to resume the prior surname of l_e.ct\n M ?}t\ rte, and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date:-/,-- a?, 09 11/.'?i 'Io A Signature ye"- A 977 ?A/J? ignature of name being sumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF /a On the _7 day of 200, before me, the Prothonotary or the notary public, personally appeared t elY above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. , Ef, ' G': _. , 35 ? ' ""`j' Notary Public Ship^,cnabijrc, PA 17257 W Commission Er,; ira? J2nuay 2,201-t n 4?1) I v - J 9--) ` Vv 2 .r P1.3 21, NX2 3 Q1 rn