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Home My WebLink About01-4163 ~~~~~ ~~ ~~~~~~~~ ~ ~~~~~ ~ '" '" '" '" '" '" ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF GERALD L. MANHOLLAN, PENNA. PLAINTIFF No. 01 - 4163 VERSUS GAIL A. MANHOLLAN, DEFENDANT DECREE IN DIVORCE AND NOW,~ ~, , DECREED THAT GERALD L. MANHOLLAN AND GAIL A. MANHOLLAN ARE DIVORCED FROM THE BONDS OF MATRI MONY. ;2-00, , IT IS ORDERED AND , P LA I NT IFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; None. ATTES(}~ ~ '" '" '" '" '" '" "'''''''''' "''''''' "''''''''''''''''''' '" ,-A J. PROTHONOTARY ... _ . L?' ~'" ~ /r/I{)II j~ -:;;;. ~ ~ r; /(NI'I ~... ,. .,.~. .... , .:' ..~ ,- ' ~ , . . GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01-4163 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Certified Mail, on July 9, 2001. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the pennsylvania Divorce Code: by Plaintiff on October 12, 2001 and by Defendant on October 15, 2001. (b) (1) Date of execution of the Section 3301 (d) of the Divorce Code: filing and service of the plaintiff's respondent: Not applicable. affidavit required by Not applicable: (2) Date of affidavit upon the 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: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary. Octoberl~ , 2001 Date Defendant's Waiver of Notice in Section 3301 (C) Divorce was filed with the Prothonotary. October2V 2001 Andrew C. Sheely, E quire Attorney for Plaint ff o ~ o s.; -otr rnp'" ~f:~- 0~') ~C:~~ 2';0 ~O >,- Z ::< o (') -+ N -C.. ..n G + '> '-::? :-> ..-oi j"'v ~::: "R :'T'J (J1 ~ ....0 :< Andrew C. Sheely, Esquire 127 S. Mark~t Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (FaX) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01 - '-{/~3 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 against 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 with your children. When the grounds 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. 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, PENNSYLVANIA 17013 (717) 249-3166 BY Andrew C. sheely, E PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Mark~t Street P.O. Box 95 Mechanicsburg, PA 17055 PA TD NO. 62469 717-697-7050 (Phone) 717-697-7065 (FaX) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant : 01 - ~1~3 CIVIL TERM IN DIVORCE COMPLAINT 1. Plaintiff is GERALD L. MANHOLLAN, an adult individual who currently resides at 35 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is GAIL A. MANHOLLAN, an adult individual who resides at 21 Lois Lane, Mechanicsburg, Cumberland County, pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 1, 1993 ln Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. Plaintiff avers that he is the innocent and injured spouse, and that the Defendant has offered such indignities to Plaintiff so as to render his condition intolerable and life burdensome. 10. This action is not collusive. 11. The parties separated on December 24, 1998. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Date: July 0 , 2001 Andrew C. Sheely, squire Attorney for Plaintiff PA 1D No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 2 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: JUlY~, 2001 &4aj/l~,~~ ~rald L. Manhollan Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01 - CIVIL TERM IN DIVORCE AFFIDAVIT Gerald L. Manhollan, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ~4d/.I/:f(~ Ge aId L. Manhollan 7/~/G(tJO ) o __ ~r. c: <-- ~ c,.s ~, N " N N t "-, ~ ~ ~ ~ ~ \ Pi :~\ - ? \ U\ ':- v,.\ c, \ C7 c \ \ ~\ \r \ ~ rt ~ " 'N - ' - '" ..;:::, - "'Q --c: Andrew C. Sheely, Esquire 127 S. Market Street - P.O. Box 95 Mechanicsburg, PA 17055 PA 1D NO. 62469 717-697-7050 (Phone} 717-697-7065 (Fax} GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01-4163 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that he caused a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon Gail A. Manhollan, by Certified Mail, Restricted Delivery, Return Receipt Requested, as indicated by the attached receipt cards, on July 9, 2001. !!:!!l~ SWORN to and subscribed before me this II rh day of July, 2001. a~~7ht1~ Notary Public My Commission Expires: NOTARW: SEAL ANN W. MARllN. Notary Pubnc i8t\1CSDUrgSoro. 0Umbeft~ Coun , My Comml6sIon ExplI'8S Sepl29. ZOOi , d~ ~DD3 , \ . ," ." t t SENDER: CQMPLE7,? THIS SECTION . Complete items 1, 2, and 3, Also complete item 4 if Restricted Delivery is desired, . Print your name and address on the reverse so that we can return the card to you, . Attach this card to the back of the mailpiece, or on the front if space permits, 1, Article Addressed to: D, Is delivery addr ss different from item 1? If YES, enter delivery address below: o Agent o Addressee DYes o No o Express Mail o Return Receipt for Merchandise ~ Yes 2, Article Number (Copy from service label) 55- 7099 3220 0011 0108 ?~4? PS Form 3811 , July 1999 Domestic Return Receipt 102595.00.M.0952 ru ::r rr1 ru U.S. Postal Service .' CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) . L I1E€#Ati\OOB!$.G' f'~i'fOOlo 11 an I Postage $ $,0.57 .' L, ! .}----- 0055 Certified Fee 16 ;.!. ;1,.). Postmark Return Receipt Fee Here (Endorsement Required) HI,IJIJ ,---- Restricted Delivery Fee (Endorsement Required) $ H:1I 07/06/20ul Total Postage & Fees Mechanicsburg Main Post Office MECHANICSBURG, Pennsylvania 170553459 (717)697-4641 03:45:30 PM 07/06/2001 . otJ CJ r-"l CJ r-"l r-"l CJ CJ Sales Receipt -______ ___ Product Sale Unit DescrIPtion Oty Price --.~----- - - --~------_._- MECHANICSBURG PA 17050 First-Class . Return ReceiPt Certified Label Serial #: Final Price $0,57 $1,50 -0 $2,10 J 993220001101082342 --- Issue PVI: $4,17 CJ ru ru Name (Please Print Clearly) (To be completed by mailer) rr1 Gail A. Manhollan IT" sireei.- Ap-i.- No:;-o-'-POEiox-No: - -.---. .____m n nn._ '__'_'n m - --- mm.n. n.', n_" IT" _ _. '.n?).1g.L~m1_~I!gn.nmmnmmmmn___nm_nmnn___m..n_n. CJ City, State. ZIP+ 4 ['- Mec' pa 17050 Total: Paid by: Check $4,17 $4,17 I . . .. "'. - . . 811 1#: Cl6i'k: 1000200334299 16 . Thank you fer' your' Ucb 1,',ess ~ o G\ (" ?> ~ lJ'l w vJ f'J ~ f {' C.:.} c, Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01-4163 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 6, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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. 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: /0 It ~ /200 I ~dJ/p~(l~ Gerald L. Manhollan ---------------' 0 0 0 C -"1 :?: 0 -c r::1 ,-, [f+Ui -\ ;Z.' N Z C, ~ ~~~ :.:>~ ~C:~ ~" Z?-~ -""' '7 \....,/ ...0 C ~ ~ U"l :;Q ..r=- -< - --- Andrew C. Sheely, Esquire 127 S. Market Str~et P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01-4163 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301 (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 decree 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. DATE: /LJ;f2h~/ , ~d/~~~~ Gerald L. Mabhollan --------..-- ,.~.~,----------- o C 7" ~~: ~ii 2-:1---- 2:,(':; PC Z ~ 0' ':-::> ,~..., -t r--..) ,- ,~ s: '-P. :.n .r::- ".------ - Andrew C. Sheely, Esquire 127 S. Marxet Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01-4163 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 6, 2001. I acknowledge that I received a copy of the divorce complaint on July 9, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: /(j~ /s-- () / 0 0 c- s:: -:::> -0 c C? .W rn r~". -f . ' z::;:\ N 2:~~. ~r, .,- ~(~: ~ ~G -2.- .=(\ ~D >~; ':~:i ~ :..n J.:::: S- ::2. -------_..-~-_.."-- Andrew C. Sheely, Esquire 127 S. Market Str~et P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (FaX) GERALD L. MANHOLLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GAIL A. MANHOLLAN, Defendant 01-4163 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301 (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 decree 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to the authorities. DATE: /t).'-/j-- 0) Gail A. Manholl -~/a-tlct~ 0 0 ~; ,:::> ;:?1 f~~ (-:> Z ....-4 Z N en :-~-.:-. co. ~:.. A....... t~ ):';r'-'.' ~lS \.0 ' " .-' c:: --=4 ~ :J1 -';'.::-. ::.D .... -<