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HomeMy WebLinkAbout01-4246 - [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii [Ii IN THE COURT OF COMMON PLEAS CFCUMBERLANDCOUNTY ST.ATE OF PENNA. HENRY W. SPIELER. No. 2001-4246 Plaintiff VERSUS II II Ii II 1\ BEVERLY A. SPIELER, Defendant DECREE IN DIVORCE AND NOW, OcYo~ 11014 Z. 001 , IT IS ORDERED AND DECREED THAT HENRY w. SPIELER , DLAI NTI FF, AND BEVERLY A. SPIELER , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; #olJl "'''' .(J~~ o PROTHONOTARY J. '" '" "''''''''''''' "'''''''''''''''' "''''''''''''''''''''''''''''''' "'''''''~'''~~ "'~"'~~"''''~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRY W. SPIELER, Plaintiff v. CNIL ACTION - LAW NO. 2001-4246 CIVIL TERM BEVERLY A. SPIELER, Defendant IN DNORCE 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: by hand delivery on July 12, 2001 3. Date of execution of the Plaintiff s affidavit of consent required by Section 3301 (c) of the Divorce Code; October 11,2001; by the Defendant; October 11, 2001. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice III S3301(c) Divorce was filed with the Prothonotary: October 11, 2001. Date Defendant's Waiver of Notice III S3301(c) Divorce was filed with the Prothonotary: October 11,2001. LAW OFFICE OF MICHAEL J. HANFT By ~t!J!r Attorney LD. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorneys for Plaintiff Date: October 11,2001 F:\User Folder\Firm Docs\Gendocs200 1 \ 1642-2praecipe. transmit. wpd 0 ", - 0 ('> -t' ;:::::: N ~ ~. -" '3 F:\User Folder\Finn Docs\Gendocs200 1 \ 1642-2divorce.complaint.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRY W. SPIELER, Plaintiff v. CNIL ACTION - LAW .-.-- NO.2001- '1.2 'f~ Cwd J v-- BEVERLY A. SPIELER, Defendant 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRY W. SPIELER, Plaintiff v. CNIL ACTION - LAW NO. 2001- l/J-t{(, BEVERLY A. SPIELER, Defendant IN DNORCE COMPLAINT IN DIVORCE AND NOW, this I ~~day ofJuly, 2001 comes Plaintiff, HENRY W. SPIELER, by and through his attorneys, the Law Office of Michael J. Hanft, and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Henry W. Spieler, who currently resides at 962 Myerstown Road, Gardners, Cumberland County, Pennsylvania 17324. 2. The Defendant is Beverly A. Spieler, who currently resides at 3231 Beverly Drive, Huntingtown, Calvert County, Maryland 20639. 3. The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing ofthis Complaint in Divorce. 4. The parties were married on December 27, 1995 in El Paso County, Colorado. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Section 3301 (c) of the Divorce Code of 1980, as amended. 6. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRY W. SPIELER, Plaintiff CNIL ACTION - LAW v. NO. 2001-4246 CNIL TERM BEVERLY A. SPIELER, Defendant IN DNORCE ACCEPTANCE OF SERVICE I, Bevtrly A. Spieler, the Defendant in the above captioned matter hereby accept service of the Complaint filed in the above captioned matter. J3~. '- Beverly A. Sp' ler . +~~ Dated: 7-/:1....0/ F:\User Folder\Firm Docs\Gendocs200 1 \1642-2acceptance.service. wpd o ~ ~ ~ co rJ t' ..p )i> --.:::> ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRY W. SPIELER, Plaintiff v. CNIL ACTION - LAW NO. 2001-4246 CNIL TERM BEVERLY A. SPIELER, Defendant IN DNORCE AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) 1. 12, 2001. A Complaint in divorce under Section 3301 (c) ofthe Divorce Code was filed on July 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 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., Section 4904 relating to unsworn falsification to authorities. Date: I D - i / ~ (!) { Sworn to and subscribed before me this I (<If) day of OrJiDu(j/ ,2001. ctJ0 rlliJc.. Notary Public <-.. Notarial Seal Denise L Nye, Notary Public South Middleton Twp" Cumberland County My Commission Expires Feb, 26. 2005 Member, Pennsylvania ASSociation of Notanes F:\User Folder\Finn Docs\Gendocs200 1 \ 1642-2affidavitconsent. wpd o o r -t' - - N . , N a ~ ~ -', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRYW. SPIELER, Plaintiff v. CNIL ACTION - LAW NO. 2001-4246 CNIL TERM BEVERLY A. SPIELER, Defendant IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(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 ri9hts 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification to authorities. Date: f D - 1/ -0 ( F:\User Folder\Firm Docs\Gendocs200 I \ J 642-2waiver.notice.wpd 0. () ("l -t- N . , N o ~ 3 t,.._ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRY W. SPIELER, Plaintiff v. CNIL ACTION - LAW NO. 2001-4246 CNIL TERM BEVERLY A. SPIELER, Defendant IN DNORCE AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) 1. 12,2001. A Complaint in divorce under Section 3301 ( c) of the Divorce Code was filed on July 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 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., Section 4904 relating to unsworn falsification to authorities. Date: If)... /1" () / Sworn to and subscribed before me this 11'f/1 day of fr'ffJer- ,2001. Cliu 1/)./) U Notary Public Notarial Seal Denise L Nye, Notary Public South Middleton Twp" Cumberland County My Commission Expires Feb. 26, 2005 Member, Pennsylvania Association of Notaries F:\User Folder\Firm Docs\Gendocs200 1\ I 642-2affidavit.consent. wpd o a ^ -r N N ~ -; .. . .. ~ . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HENRY W. SPIELER, Plaintiff v. CNIL ACTION - LAW NO. 2001-4246 CNIL TERM BEVERLY A. SPIELER, Defendant IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(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 in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: / () ; II -" I i3~ ti ~ Beverly A. ieler, Defi dant F:\User Folder\Finn Docs\Gendocs200 1 \ 1642-2waiver.notice.wpd (:) -- o ,... -r - - N . . tv ~ >