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Home My WebLink About01-4236 ,.~ ~ ~ IN THE COURT OF COMMON PLEAS ~ ...~ ~.~ ~ " ~ ~.~ ~.~ ~ ~ ~.~ ~.~ ~ "'!i, ~ ,.~ ~ ,.~ ~ ~ If..~ ~ ~.~ ,., ~ ~ ~.~ ~ ~.4! ~ ~.~ ~~'.,. ~ 1f..1 ,~.. ~ ~.~ ~ ~ ~.~ ~ ~ ~ ~.~ ~ ~.4! ~ If..~ i ...~ ~ '.' ~ '.' ~ '.' ~ '.' ~ ~ '.' ~ ~ ~ '.' J. * '.'!i, ~ ~ '.' OF CUMBERLAND COUNTY ~ STATE OF PENNA. ~ ~ ~l ~ Prothonotary ~ ~ ~ v ~ ,~~~~~,~~~_~~~~~_~~~~~,_~~/v,.__,~..~.., ~ .-'~:' .~:..~+:..~:. .~+:. .~:. .~+:..~+:. .~+:..~+:..~+:. .~+:..~+;. .~+} .~+:. .~+:. {+:. .:+:. {+;. .:+:..:+;..:+:. .:+:. .=~;..:+;..:+;. .=+;.-:+;. .:+;. .:+;. $ ~ '.' ~ '.' ~ '.' ~ '.' ~ '.' , _Vic;~i"J..h.~aA:z; N O. ...q.~._.~...4.~.;36..........._.....2UOl ~ '.' nP~aintif,L ~\ ~l '.' Versus Civil Action - Law In Divorce James M. Manz ~ '.' , nu:oet,enda:n.t ~ '.' , ~ '.' ~ '.' DECREE IN DIVORCE AND NOW, .~. .-~\2~ . .-~.~. . . ., .-~ it is ordered and ~ '.' ~ ... ~ ... ." ... ,', ~ ~ ~." decreed that.... :Vicki. .L.. Manz... . ... .. .... .... .......... .., plaintiff, and. . . . . . . . . . . . . ..:r~~~~. ~.-. .~~~~ . . . . . . . . . . . . . . . . . . . . . . . . . . " 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; t)ar .) .................~................................../..................., -/ . ... ,8; . . .. .......................... ~. . . . ''l' . . . . . . . . . . . . . . . . . . . . By T,he #~ ,/ Au.." 0 ~ ... ~ '.' ~ v ~ '.' ~ ~.." ~ f.''' ,', ~ ~ '.' ~ ~.4! ~ ~ ~ /?,r:'" ~~I! - ;::/"r _ <,/~}Up;'~ rv It? ,~rj, · /rl,lr el I()! ["", el ," ~ ' VICKIE L. MANZ PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA Vs. No. ot - "'~Jb C~u~l~~ JAMES M. MANZ DEFENDANT : CIVIL ACTION - LAW : 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 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. 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: Office of the Prothonotary Cumberland County Court House One Courthouse Square Carlisle, Pennsylvania 17013-3387 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYERS 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 Carlisle, P A 17013-3387 Liberty Avenue 717-249-3166 PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYL VANIA VICKIE L. MANZ Vs. No. D/- '123(., ~ --r~ DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE JAMES M. MANZ COMPLAINT IN DIVORCE COUNT I AND NOW, comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows: 1. Plaintiff is VICKIE L. MANZ, who currently resides at 30 HUNTER LANE, CAMP HILL, PA 17011. 2. Defendant is JAMES M. MANZ, who currently resides at 601 S. WEST 19TH STREET, CAPE CORAL, FLA 33991 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 25, 1986. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the right to request that the Court require the parties to participate in counseling, and after being so advised, Plaintiff does not desire counseling. 7. The Plaintiff avers as the grounds upon which this action is based are that: (a) The Defendant has offered such indignities to the person of her, the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome; and; (b) The marriage between the parties hereto is irretrievably broken. WHEREFORE: Plaintiff requests the Court to Enter a Decree in Divorce. Respectfully submitted, DATE 1- r-p/ By ?JJ~ AMES M. BACH Attorney At Law Attorney I.D.# 18727 352 S. Sporting Hill Rd. Mechanicsburg, P A 17050 (717) 737-2033 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein made are subject to penalties of 18 P A. C.S. 94904, relating to unsworn falsification to authorities. DATE: '7- J- p I ~ d/7l~ VICKIE L. MANZ (PLAINTIFF) VICKIE L. MANZ PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA Vs. No. JAMES M. MANZ DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on March 15, 1999 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 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. e.s. 94904 relating to unsworn falsifications to authorities. Date: 7- f- (/' / ~~ o?:~ Plaintiff VICKIE L. MANZ PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYL VANIA Vs. No. JAMES M. MANZ DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) D I do not oppose the entry of a divorce decree. (b) D I oppose the entry of a divorce decree because (Check i, ii, or both): (i) D The parties to this action have not lived separate and apart for a period of at least three years. (ii) D The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) D I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. (b) D I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in the Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P A. C.S 4909 relating to unsworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this Counter-Affidavit. ;00 1t~ '" -..0 '" L cS_ - ....j ~ ....... "" ~ -..l d~0 08B ( I ~~ ~-r ~ o - 8 c::;T : , w v.J -0 ~ ~. ) G VICKIE L. MANZ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-4236 CIVIL TERM JAMES M. MANZ Defendant : IN DIVORCE ACCEPTANCE OF SERVICE DOCUMENT I, James M. Manz, of601 S. West 19th Street, Cape Coral, Florida 33991, do hereby acknowledge that I have received a true and correct copy of the Complaint in Divorce, together with a Notice to Defend and Claim Rights, Plaintiffs Affidavit and Defendant's Counter-Affidavit, on July 17, 2001. I certify that this information is true and correct. Date: -1- I ? - () I (f I! {X IJ o - .-1 ',-,;:, ~ Q o ~- --0 c' f\\ 'f:r., z,--::.' %(~-, (pc.' ....L- <1(~ r::;.c ,-- -..-~.. c:; ':2: t", yC ~ ,,:j o - r" d ~ r " ::.1': c:'" ,p "~\ ~.:l - -- - , . J:;. p )> ). .---------- "-------.------- ) . , .I VICKI L. MANZ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. : NO. 01-4236 CIVIL TERM JAMES M. MANZ Defendant : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: JAMES M. MANZ VICKI L. MANZ, the PLAINTIFF, intends to file with the Court the attached Praecipe to Transmit Record on or after SEPTEMBER 17,2001, requesting that a final Decree in Divorce be entered. ~~~ JAMES M. BACH Attorney for Plaintiff NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: JAMES M. MANZ You have been sued in an action for Divorce. You have failed to answer the Complaint or file a counter- affidavit to the Plaintiff's affidavit. Therefore, on or after SEPTEMBER 17,2001, the PLAINTIFF can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court, an answer with your signature notarized or verified or a counter-affidavit by the above date, the Court can enter a final Decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce, and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDA VIT, WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS A TT ACHED TO THIS NOTICE. 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 17013-3387 717-249-3166 0 0 C) c: '-q ? 0 ~ -ace ~..," f1l r,-, . , Z"';" ;:-) :2r- '" ~ ~?:. --l ~ C ~ J;: I"" ~+- ~ 0 - :;;- c:: - .-' ..--\ z: C'" -1> ~ :0. \.0 -<.. ------------- ----------"".--- ---...------ VICKI L. MANZ PLAINTIFF vs. JAMES M. MANZ DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4236 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE BY MAIL PURSUANT TO PA. R.CP. 1920.4 (a) 0) (ii) JAMES M. BACH, Esquire, being duly sworn according to law, deposes and says that he is the Attorney for PLAINTIFF, and that he did mail a true and correct copy of a Complaint under Section 3301(d) of the Divorce Code of 1980, along with a Notice to Defend and Claim Rights, by registered/certified mail, return receipt requested, deliver to addressee only, to the DEFENDANT, on Tuly 17, 2001. SENDER: COMPLETE 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: :k'r.. me.s (11. fY/ 0../1 Z. -r4 Sr. (P () IS. uJ e..s r J 9 CJ.l"e C.,a~ 'I t:: L 33991 . /?e?- M. BACH An ey J.D. No. 18727 352 outh Sporting Hill Road Mechanicsburg, P A 17050 717-737-2033 C. Signature X C. o Agent o Addressee DYes o No 3. Service Type ~ Certified Mail o Registered o Insured Mail o Express Mail 0( Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) DYe".' 2. Article Number (Copy from service label) 7v()O ;" 70 Ot)()f 95;0 g-f?O Y PS Form 3811 , July 1999 Domestic Return Receipt 102595.00.M.0952 o -- ......., ',CO,,\ 'CJ tV o c ~ -J"'" r" fh Z-r' Z~~-- '!l <2: r;.C .._"~ "'2(-;' be' 71'::':- -7 ..<:..- :2 ..-~~ ~ -.... - - .::,\ ~::Q -<.. s::" \,0 VICKI L. MANZ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO . 01 - 423 6 JAMES M. MANZ 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. GROUNDS FOR DIVORCE: Irretrievable breakdown under Section ( ) 3301 (c) or ( X ) 3301 (d) (1) of the Divorce Code. (Check applicable section.) 2. DATE AND MANNER of service of the Complaint: Service accepted by Defendant July 17,2001 (See enclosure marked Exhibit "AU and Certified Mail Receipt). 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 by Defendant (b) 1. Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code July 9, 2001. 2. Date of service of the Plaintiff's Affidavit upon the Defendant: July 17, 2001. 4. RELATED CLAIMS PENDING: NONE 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, a copy of which is attached, if the Decree is to be entered under Section 3301 (d) (1) (I) of the Divorce Code: August 17, 2001 by ordinary mail, postage prepaid. By: ~ ~ ~ ~ES M. BACH, ESQUIRE Attorney I.D.# 18727 Attorney for Plaintiff 352 S. Sporting Hill Rd. MECHANICSBURG, PA 17050 (717)737-2033 December 26, 2001 DATE: g 0> (~ -' -, I ~:~ 0 -. -orG r'q rn rr' ::'-') Z:c' i'0 zc;,. ~~~. --- ~~) ::c,... -- --:;,... ~(} PC: -7 c.- ..<- -< '-0 ----~