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Home My WebLink About05-3895 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street CarHsle, P A David L. Guyer, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION. DIVORCE NO. 05. 3~r.5 CIVIL TERM IN DIVORCE Vickie K. Guyer Defendant 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. Wilen 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, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff By: SAlOIS mUFF, FLOWER & LINDSAY A170RNEYS.AT-LAW 26 W. High Street Carlisle, PA II I I David L. Guyer, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION. DIVORCE NO. 05 _ j '81,::' CIVIL TERM IN DIVORCE Vickie K. Guyer Defendant COMPLAINT David L. Guyer, Plaintiff, by his attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is David L. Guyer, who currently resides at 438 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266, where he has resided since 1990. 2. The Defendant is Vickie K. Guyer, who currently resides at 438 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266 where she has resided since 1990. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 5, 1979 at Marion, Pennsylvania. 5. Plaintiff filed a Complaint in Divorce ten or fifteen years ago and, upon information and belief, the complaint was purged. SAlOIS ;HUFF, FLOWER & LINDSAY AITORNEVS-ATeLAW 26 W. High Street Carlisle, PA II 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: Date: Carol J. Lindsa ID # 44693, 26 West Hi treet Carlisle, PA 17013 (717) 243-6222 SAIDlS SHUFF, FLOWER & LINDSAY ATIORNEVS-AT-LAW 26 w. Hjgh Street Carlisle. P A II VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. D~?'- - vid L. Guyer, Plaintiff Date: 7jlffl O~ ') ,~ r. -.. .';) c .,:.,~ ("; '8.... i (); .-,,) '? \9 .~ ~ ~'. -:I -"I :...0 Q , ___ /V rv" C> -;.0 ~:.:, ~ Yfy'" ~ " /CC <: ')/ <.0 O<s> ~ <?( cr-- -- ~ SAlOIS iHUFF, FLOWER & LINDSAY ATI'ORNEYS.AT-LAW 26 W. High Street Carlisle. PA David L. Guyer, Plaintiff vs. Vickie K. Guyer Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 05-3895 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, hereby certify that I served the Complaint in Divorce in the instant action on the Defendant, Vickie K. Guyer, on August 15, 2005, by mailing the Complaint to her at 438 West Main Street, Walnut Bottom, PA 17266, via Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, which is signed by the Defendant, Vickie K. Guyer. Dated: August 19, 2005 Sworn to and subscribed before me this 19t11 day of August, 2005 +' l~~__ {tMM:NW H OF PENNSYLVANIA Notarial Seal Sara J. Ensinger, Notary Public Cam"p Hill Boro, Cumberland County My Commission Expires Oct. ] 7, 2005 Member, Pennsylv~nb Association of Notaries SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: SAlOIS lUFF, FWWER & LINDSAY I.T1'ORN2VS.AT.LAW ~6 W. High Street Carlisle, PA David L. Guyer, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - LAW No. 05-3895 CIVIL TERM Vickie K. Guyer Defendant IN DIVORCE AFFIDAVIT OF SERVICE SE.~'.!D[FL ",J{.,t>-[,-i TH{~ 0EC,'/01~ . Complete Items 1,2, and 3. Also complete Item 4 If RestrIcted DelIvEll)' Is desired. .Printy~ur~~an~ ,tiddress. Dl'lthereverse so that wacan -return the cartfto you. . Attach this card 10 the back of the mailplece, or on the front If space permits. J 1. Article Addressed to: o Agent o Addressee C. Date of Delivery D. Is delivery address from 11 0 Yes If YES. enter delivery address below: D No Vickie K. GUYer 438 West Main Street Walnut Bottom, PA 17266 AUG 1 & 200; 3. .lce 'Jype er llertifIed Mall D)I<Press Mall o Reglsterecltll!Retum Receipt for Merchandise o lnsunld Mell 0 C.O.D. 4. Restrictecl DelIvOl}'1 (ExUa Fee) Ves , 2. Article Number (T"--_~. PS Form 3811, FebrUary 2D04 7003 1010 0001 1201 4544 DomeelIc Retllm ReceIpt 102595..Q24.1S40 i Q ~ () c... ~'n "::..~ "'. :? ~ l\ Y" Cf' c: ~.." ? \.-'< G'> rnc;. N -ell' ' ~r; J-~(~:' Ln \.~"}\(;? ~ " -,"",,:,"0 ~,' ~{5Ir~\ ( :::.r;; ><. (-;. p. - 1'"'- - ~. ~fi .' :;'. (.,) 0 DAVID L. GUYER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs CIVIL ACTION NO 20053895 IN DIVORCE VICKIE K. GUYER Defendant ANSWER TO COMPLAINT IN DIVORCE 1. In response to paragraph one of Plaintiffs complaint, Defendant admits the same. 2. In response to paragraph two of Plaintiffs complaint, Defendant admits the same. 3. In response to paragraph three of Plaintiffs complaint, Defendant admits the same. 4. In response to paragraph four of Plaintiffs complaint, Defendant admits the same. 5. In response to paragraph five of Plaintiffs complaint, Defendant admits the same. 6. In response to paragraph six of Plaintiffs Complaint, Defendant neither admits nor denies this allegation as she is without sufficient information to form a belief as to the truth and veracity of this assertion. 7. In response to paragraph seven of Plaintiffs complaint, Defendant neither admits nor denies this allegation as she is without sufficient information to form a belief as to the truth and veracity of this assertion. WHEREFORE, Defendant respectfully requests this Court: A. Enter a decree of Divorce between the parties. b. Equally distribute the real and personal property acquired during this marriage. c. Any and all other reliefthis court deems appropriate and equitable. Respectfully SUbmitt. ed, G ~~ ~~ '-c- ~~ Richard R. Gan Gan Law Offices 17 West South Street Carlisle, Pa 17013 717-241-4300 ID 68721 "-- Sw07-05 11:40 Froll\..u.nnc nT710T516 T-OS5 P.002/002 F.3~6 VERIFICATION I, VicidB](. Guyer, hereby cetIify that the liIeIs SIt forth in the toregoing A1lSWIl to ComplaiJlt are true IlIId cDrJeCt to the best of my knowledge, infonnation and belief. t r uodetsbmd tbat false slatemerrts h.eJ:ein are made subject to the p...,..A1H.... of 18 Pa. C.S.A. ~ {elating to unsworn falsification to authoritillS. ~ .....:t ~ OS l)CtLJ.. k,~u~ Vickie K.. Guyer _......, #e IfJ7tn./ -.. nIl'" ,..,.,7 It' u"t) J'Mlofl:l O\7t:\O 90 LO 0,., .-., C~ (J -Tj ~, -..J ,....J W :~j (,Yl --< SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 W. High Street Carlisle, P A 'I DAVID L. GUYER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 05-3895 CIVIL TERM VICKIE K. GUYER, Defendant IN DIVORCE PLAINTIFF'S/DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed on July 29, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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:~ () <-.7?----- David L. OOyer PLAINTIFF'S/DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 Ie) 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 in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: Ill, c; /0 S- David~~1 ---- .-' ~:?;~ C,~1 (.Jj -~:1 .._"-. ~? r0 (.i) SAlOIS SHUFF, FLOWER & LINDSAY AITORNEYS-AT-LAW 26 W. High Street Carlisle. PA II DAVID L. GUYER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -. LAW NO. 05-3895 CIVIL TERM v. VICKIE K. GUYER, Defendant IN DIVORCE PLAINTIFF'S/DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301(c) of the Divorce Code was filed on July 29. 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and beiief. 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 J C{! N () <) 0 C; t ' - \ ;}. )IUl~ Vickie K. Guyer . PLAINTlFF'S/DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERlI 3301 ee) 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 aiimony, 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 Divoree 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 to the best of my knowledge. inforrnation and belief. 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:~ '1 .* . . \J.t. I ] I (' ~i.Lt K '\.ll1Jf~\ Vickie K. Guyer ' .~ ~ ,--,'" CO) U~ -.... ,,- SAIDIS SHUFF, FLOWER & LINDSAY A1TORNEYS.AT-LAW 26 W. High Street Carlisle. P A II , lAVID L, GUYER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - LAW NO, 05.3895 CIVIL TERM ICKIE K. GUYER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD o the Prothonotary: Kindly transmit the record, together with the following information. to the Court for ntry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of e Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted ervice of the Complaint on August 15, 2005, via certified mail. Proof of service was 'led with the Court on August 19, 2005. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce ode was filed with the Prothonotary: By Plaintiff: November 15, 2005 By Defendant: November 18, 2005 4. Related claims pending: The terms of the Property Settlement and eparation Agreement dated September 30, 2005 are incorporated, but not merged, into e Decree in Divorce. 5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was led with the Prothonotary: By Plaintiff: November 15, 2005 By Defendant: November 18, 2005 SAIDIS, SHUFF. FLOWER & LINDSAY /~) I , } . Carol J. Undsay. Supreme Court ID o. 44693 26 West High reet Carlisle, PA 17013 717-243-6222 , SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS-ATeUW 26 W. High Street Carlisle, PA II CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & INDSA Y, hereby certify that on this date a copy of the attached document was served on he following individual, via first class mail, postage prepaid, addressed as foliows: Richard R. Gan, Esquire Gan & Associates 5869 Fox Street Harrisburg, PA 17112 SAIDIS. SHUFF. FLOWER & LINDSAY (- \ ' , c-- \ . ."' ated: November 18, 2005 \,.f'T' ~ ~;--,~ ----=' , ' ~;"--'-' ._J '1\ :-;1 ,) I' ~-) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . . . + + + + . . + . + . . . + . . + . . . . . . + . . . . + . . . . . . . + . . + . . . . + . + + . . . + . +'1' 'f + :Ii :+::ti+++ ++++++++ ++++++++++++++++++++++++ +++++++~ . . +++ +,.,'1'+ . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. DAVID L. GUYER No. 05-3895 VERSUS VICKIE K. GUYER DECREE IN DIVORCE AND NOW, f..'/'>V. 2. " DAVID L. GUYER 26oi:", IT IS ORDERED AND DECREED THAT , PLAINTIFF, AND VICKIE K. GUYER , 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; The terms of the Separation and Property Settlement Agreement dated September 30 2005 are incorporated, but not merged, into this Decree in Divorce. . . + . jl~ p"on'O'OT^"~ i + . ++++++++++++++++++++++++++++ +'f++++ +++++:+. + ++ +++++++++++++? . + . + . . . + + . + . . . + . + . . + . . . + . . + . + + + . + . . + . + . + . . . + . . + . + . + . + . + . . + . + . . . . . . . . . . . . + . . . . . . . . . ~ P "'7 rezrc:Yf7 ~/;I, r:.7 [f'- / / ;;;~ ~ .:t' /fT~ ~ -,P? 9;l. &':' JI ..~ . ,