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Home My WebLink About05-5820 TIMOTHY H. WELLS, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA VS. * NO. OS - S?'?l] Gtv?h ANGIE R. WELLS, * CIVIL ACTION - LAW 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 IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA 17013. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 TIMOTHY H. WELLS, Plaintiff vs. ANGIE R. WELLS, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * * NO. dS - SPav * * CIVIL ACTION - LAW * IN DIVORCE COMPLAINT COUNT I - DIVORCE UNDER 43301(c) or 43301(d) OF THE DIVORCE CODE 1. Plaintiff is Timothy H. Wells, who currently resides at 1102 Ridge Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Angie R. Wells, who currently resides at an unknown address in West Virginia or Maryland. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 8, 1998 in Hamburg, Pennsylvania. 5. The parties are the parents of no minor children. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. Plaintiff has been advised that counseling is available and that he may have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued. 10. The cause of action and sections of the Divorce Code under which Plaintiff is proceeding are: (a) §3301(c). The marriage of the parties is irretrievably broken; and (B) §3301(d). The marriage of the parties is irretrievably broken and, at the appropriate time, Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at least two (2) years. 11. Plaintiff respectfully requests This Honorable Court enter a Decree of Divorce. WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order dissolving the marriage between Plaintiff and Defendant. Dated: //- 7- 0? Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.C. j Timothy J. o1g?an, ire 130 West Church Street Dillsburg, PA 17019 (717) 432-9666 I.D. 4 77944 VERIFICATION I, Timothy H. Wells, verify that the statements made in this Complaint 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. CS. §4904, relating to unsworn falsification to authorities. Date: TIMOTHY WWELLS Plaintiff a r+ _7 i G> r ? v, ? TIMOTHY H. WELLS, Plaintiff VS. ANGIE R. WELLS, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * NO. 05-5820 CIVIL TERM * CIVIL ACTION - LAW * IN DIVORCE ACCEPTANCE OF SERVICE I accept service of Plaintiffs Complaint in Divorce in the above-captioned matter, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Date: , '_. - - o S a• ? 1 Angie R. Wells Ma?? ; n?? > ca t,? y as ? o ? rt }1 } ,^c t 1i Print Address s of 36q 23W Print Phone Number OFFICIAL SEAL LINDA M. GRABNER LNO?TARY PUBLIC STATE OF IWNOIS Y ISSIO N EXPIRES JULY 22, 2006 TIMOTHY H. WELLS, Plaintiff VS. ANGIE R. WELLS, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * * NO. 05-5820 CIVIL TERM * * CIVIL ACTION - LAW * IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on November 8, 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. 3 Date Timothy H:' ells Plaintiff c " S1 1 Cr3 TIMOTHY H. WELLS, Plaintiff VS. ANGIE R. WELLS, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * * NO. 05-5820 CIVIL TERM * * CIVIL ACTION - LAW * IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. 3 - 13 - 0(? Date Timothy H. ells Plaintiff n Y C n - .„ „ ,. ,: S C am { Cp ? TIMOTHY H. WELLS, Plaintiff VS. ANGIE R. WELLS, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * * NO. 05-5820 CIVIL TERM * * CIVIL ACTION - LAW * IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on November 8, 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Date Angie . Nt ells Defendant C"i ;""-o ?v ? ` "^? ?? i j'C } {?] " .,... L, '?;f?' .. 7s*._ C-fit ?° ,? ?l .. f??y + 1 ?? . - y TIMOTHY H. WELLS, Plaintiff VS. ANGIE R. WELLS, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * * NO. 05-5820 CIVIL TERM * * CIVIL ACTION - LAW * IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date Angie R. Wells Defendant *--? ? ?:? L -il U- =? -t "s ;? -,??:. . ?? , ,4 _:??_ ,' }T1 `-1 ?'t .? Curtis R. Long Prothonotary office of the Vrotbonotarp Cumbertanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor QS -51; Z6 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573