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Home My WebLink About05-5785 , VINCENT LEE WISE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA " V. :CIVIL ACTION - LAW :DIVORCE MELANIE LYNN WISE Defendant :NO. 05- 57'?) CIVIL TERM 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 right 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 in the Office of the Prothonotary, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with DisabiIities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. . . VINCENT LEE WISE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA V. :CIVIL ACTION - LAW :DIVORCE MELANIE LYNN WISE Defendant ;NO. 05- :Fl is CIVIL TERM COMPLAINT UNDER && 3301(c) and (d) OF THE DIVORCE CODE The plaintiff, Vincent Lee Wise, by his attorneys, the Family Law Clinic, sets forth the following cause of action for divorce: 1. Plaintiff is Vincent Lee Wise, who currently resides at 452 North Pitt Street, Carlisle, Cumberland County, Pennsylvania, 17013, since August 2005. 2. Defendant is Melanie Lynn Wise, who currently resides at 31 Sheryl Drive, Newville, Cumberland County, Pennsylvania since approximately March 24, 2005. 3. Plaintiff and Defendant have been bona fide residents of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant have lived separate and apart since March 2005. S. Plaintiff and Defendant were married in Mt. Holly Springs, Cumberland County, Pennsylvania on July 20, 2000. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. . . 8. 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. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: JIll-luxe) I I e gal Intern ~! {41 e-f2J&~ THO ;ACE ROBERT . RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 Phone: (717)243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this Complaint 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: I { (7/ () ,,; , - 0.f..11.Io ,,~j- X. 1v?<-.~ VINCENT LEE WISE Plaintiff ,-...Cl ~~.~~ C:.~" .:.n q -~ 1 __I -::? -- <-:'? o -1'1 :J=l-;1 ;~~~ ~~ ~~~f1 c-'i [I' -' VINCENT LEE WISE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA V. :CIVIL ACTION - LAW :DlVORCE MELANIE LYNN WISE Defendant :NO. 05- 578'S- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Vincent Lee Wise, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certify that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date: 1//7~5 I l -~ . . : JfJmii;::- c1~ 7 Doogl~J. Boo~ki" , .' Certified Legal Intern F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 Phone: (717)243-2968 Fax: (717) 243-3639 ,---- o S ......' C,:'1 .;:::,') <.r' - _.,. C:' "',,:;: Sc;;. ~i I -' (), -, ...... -r::-1" i:rl?:: ....,;-1\ ':J\./ >.~ ,.'.. '-'\~~ 4:) ~~,,' -'" ,,::i C') - , 'i, VINCENT LEE WISE, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE MELANIE LYNN WISE, Defendant NO. 05-5785 CERTIFICATE OF SERVICE I, Douglas James Boorstein, hereby verify that I am a competent adult and that I served a true and correct copy of the above captioned Complaint for Divorce under 23 Pa. C.S. SS330I(c) and 3301(d) on Melanie Wise by depositing a copy ofthe same in the United States mail, certified number 7005 0390 0003 2632 5003, restricted delivery, return receipt requested on the 14th day of November, 2005 addressed as follows: Ms. Melanie Wise 31 Sheryl Drive Newville, P A 17241 Sender's receipt no. 7005 0390 0003 2632 5003 is attached hereto and incorporated by reference. On the 17th day of November, 2005, domestic return receipt number 7005 0390 0003 2632 5003 was delivered to the Family Law Clinic, bearing the signature Melanie L. Wise and showing a date of service of November 16, 2005. The return receipt is attached hereto and incorporated by reference. F AMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 .. 'I m o o Lll U.S. Postal Service," CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) ru m ...n ru Postage 37 ;,.341' 1.7st 3.:)0 .qJ- ) m o D Return Receipt Fee D (Endorsement Required) D Restricted DeI!vmY Fee rr- (Endorsement Required) m o Total Postage & Fees $ Certified Fee Lll o entTo ~ s",i,-A-,fJ,f<---ff2.d~--.u)-~------------________________ ~;;:-;~+;r;l!---~-_~=--____________________n__ " '-1'2L.uJtJdA_' f7.-q I '7.;1. tj / r"S Form 3800 Juno=> 2007 See Reverse lQr lnslnJctlon!l SENDER: COMPLETE THIS SECTION COMPLErE THIS SECTION ON DEL/VERY A. Signature o . Complete jtems 1, 2, and 3. Also complete ~em 4 If Restricted Delivery is desired. . Print your name and address on the reverse 80 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: C. Date of Delivery x Dyes :l"INo m,,-, n/~ u.)[<u../ .3. / ~-t W~ '11~V~1 pI'! /7;). </1 , ~" .., '" \. \:, :.l~\p~er to addressee f;7t 3. Service Type j:!fCertified Mall o Registered o Insured Mail o Express Mall iZl-Return Receipt for Merchandi$e DC.O.D. 4. Restricted Delivery? (Extra Fee) $Ves 2. Article Number rr"'nsfsrfromservlc8/abe!) 7.!!tl5 iJ3~L) oOcJ3 2-03.;;.. 5003 PS Form 3811, February 2004 Domestic Return Receipt 102595-Q2-M-1540 i --\ ~, fi; -/ Lr" ,-" .;:, (-'') '- ~ )? Vincent L. Wise, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Melanie L. Wise, Defendant : NO. 05-5785 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !l3301(c) OF THE DIVORCE CODE I. 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 3!/L-//fJf/ / / P2~//~J X---W -VlA Vincent L. Wise, Plaintiff C) C. C) -n .:..:J -';"-' i':': C') -,'.J r".~ 1',,) Cf. Vincent 1. Wise, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Melanie 1. Wise, Defendant : NO. 05-5785 CIVIL TERM AFFIDAVIT OF CONSENT l. A Complaint in Divorce under 99330I(c) of the Divorce Code was filed on November 7,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 94904, relating to unsworn falsification to authorities. Date :3 } /II / 0 0 / I '~~J:/ ~ ~~ Vincent 1. Wise: Plaintiff "",' ,:.') .';1 =-.:1 ,- Ii., C,,) r',,'t p-..: (}: Vincent L. Wise, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE Melanie L. Wise, Defendant : NO. 05 - 5785 CIVIL TERM CERTIFICATE OF SERVICE I, Lauren McHale, Certified Legal Intern, Family Law Clinic, hereby certify that I served a copy of Plaintiffs Affidavit of Consent and WaiveT of Notice ofIntention to Request Entry of a Divorce Decree Under ~3301(c) of the Divorce Code on Melanie L. Wise, residing at 31 Sheryl Drive, Newville, PA 17241, by depositing a copy of the same in the United States mail, postage prepaid on April 5, 2006. JUJLut111/ nUe Lauren McHale Certified Legal Intern r~ t -Walsh, Esq. ng Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C" ?~ "'1 , '- c:~ VINCENT 1. WISE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MELANIE 1. WISE, Defendant : NO. 05-5785 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under SS 3301(c) ofthe Divorce Code was filed on November 7,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. S4904, relating to unsworn falsification to authorities. Date5 -,;13 -0 cp fik/(uz;; rJI. (A). 1,io , M lame 1. Wise, Defendant ~-, c;:"' c.~~" c,... ---. r,,) w o -" .-1 ~F ~~J ""~ _.._~ '~;f~~ ..~ ~r," ~n .< ,,) J;:" N VINCENT L. WISE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MELANIE L. WISE, Defendant : NO. 05-5785 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. 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 ofthe 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. g4904 relating to unsworn falsification to authorities. Date'"')- ,::y--\- UG vQ4iDo..iill & ( ~-) I ~Q / Melanie L. Wise, Defendant -0 ',"7::- c~::.:> 0-' f'....., 0) ~, 'j -n :;-1 L-r; :,::-np ('f~ .,-) '"-:-'( r--..' ~ C) , ;,rrl ~~ r-.,) VINCENT L. WISE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION- LAW : IN DIVORCE MELANIE L. WISE, Defendant : No. 05- 5785 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under S3301(c) ofthe Divorce Code. 2. Date and manner of service of the complaint: Served on defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by defendant on November 16, 2005. 3. Date of execution of the affidavit of consent required by S3301 (c) of the Divorce Code: by plaintiff- March 14,2006; by defendant- May 23, 2006. 4. Related claims pending: none 5. Date plaintiffs Waiver of Notice was filed with the Prothonotary: March 31, 2006. Date defendant's Waiver of Notice was filed with the Prothonotary: May 23, 2006. sin/DC:> , Date 4 . /i ~ eith ickman Certified Legal Intern ~, JLu Anne Mac onald-Fox, E Supervising Attorneys F AMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, PAl 7013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff r....' '-" r) '-11 :::J l';:ip ~,C: 1""',) r""':" if. if. if. if. if. if. if.if. if. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY if. STATE OF if. if. VTNCF.N'P T. _ WISP. , if. if. if. if. Plaintiff if. VERSUS if. if. MF.T.ANTP. T.. WISE, Defendant if. if. AND NOW, DECREED THAT AND PENNA. No. 5785 2005 DECREE IN DIVORCE T~;L , e ?:3rA,A I ,;.ad, IT IS ORDERED AND VINCENT L. WISE , PLAINTIFF, MELANIE L. WISE , DEFEN DANT, 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; if. if. if. if. if. NONE ATTEST'a . .~ r ~ PROTHONOTARY if. if. if. if. if.if. if. if. if. if.'t; if. if. if. if. if. if.if.if. "'if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. if. J. if. if. if. -h 2- /fr"" ~ 9r?''1/'~ .7'.:/ Z. ~ ~.~ ~,'I-? .... . . " " .. \. . '\, I' ,