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HomeMy WebLinkAbout06-0778 EMERY W. SEELEY, III Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Defendant : CIVIL ACTION - LAW : NO. {It 77rj : IN DIVORCE CIVIL TERM v. SALLY P. SEELEY, NOTICE 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 ate 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 ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Catlisle. 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 Bat Association 32 South Bedford Street Catlisle, PA 17013 Phone: (717) 249-3166 EMERY W. SEELEY, III Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW Defendant : NO. 0 (., - r 7 f : IN DIVORCE CIVIL TERM SALLY P. SEELEY, COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE I. Plaintiff is Emery W. Seeley, III, who currently resides at 135 I Georgetown Circle, Carlisle, Cumberland County, Pennsylvania, 17013 since November 2004. 2. Defendant is Sally P. Seeley, who currently resides at 135 I Georgetown Circle, Carlisle, Cumberland County, Pennsylvania, since November 2004. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on June 26, 1976, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction, 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiffrequests the Court to enter a Decree of Divorce. 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 unswom falsification to authorities. Date: t/"31/0C, r ~~_ Iif' . Emery W. Seeley, III, Plaintiff ANDREWS & JOHNSON By: ^ /) ,I / / , / ,/ / / r-~ '. ~., . . . ,711/0/ ;//,0);) Ronald E. Joh)1son, Esq. Attorneys fQt'Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 \',~ ~ ~ '0. ~ 1(, ...... --.j -z '- "- "":l '-, ';;- \.r.'t:?' ,~ , \ . '\ ~ ~~. \\ ,,~ - ,~ ~ ~t~ I'! ''l r-' '-J C) ::::' ~'\1 C'; c:'" ,_-::} -r'l -', rn c:.) ---------- ~ I -J ~ -" .)(11 _-,:~l ~ 'n ........~ l':? <::) \.D - . Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EMERY W. SEELEY, III Defendant : CIVIL ACTION - LAW ; NO.O!. - '1"t/' : IN DIVORCE CIVIL TERM v. SALLY P. SEELEY, AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA ) COUNTY OF CUMBERLAND ) AND NOW, this K day of February 2006, I, Ronald E. Johnson, Esquire, attorney for Emery W. Seeley, III, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at her residence at 1409 Skyview Circle, Apt B, Harrisburg, PA 17110, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt tequested. A copy ofthe return receipt card signed by the Defendant on February 10,2006 indicating service was effected is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: SWll( and subscribed to before me this day of February, 2006. rt~, NOTARIAL SEAL J SHELLY SEXTON, Notary PubliC Car/rsle Bora, Cumbedand COlir:ty My CommIssion Expire~ ,0j~!~j^__~~~~~O? , Complete items 1.. 2, and 3. Also complete item 4 jf Restricted Delivery is desired. . Print your name and address on the reverse sci that we can return the card to you. . Attach this card to the back of the mail piece. or on the front if space permits. 1. Article Addressed to: -:Jet II Y f S:,(C le~ I LfOq S. tyV: e (,J (I Y'D le- 14ft '3 UV\rrisbu"~1 ?fl h/lO 2. Article Number (Transfer from service labelj PS Form 3811. February 2004 3. Service Type 0'Certlfied Mail o Registered o Insured Mail o Express Mail Jd""Return Receipt for Merchandise DC,O,D, 4. Restricted Delivery? (Extra Fee) mas 7099 {. '(00 001t' 102595-Q2-M.154Q 5"bttr 7~ Domestic Return Receipt Exhibit A n C. r--.'"J ~-::;~ '.;;'" (J ,] .--\ i-fiE t-.'..:: -,.. :::.... :;,J r".' -..J ( , -u r:~') en - EMERY W. SEELEY, III Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW SALLY P. SEELEY, Defendant : NO. 06-778 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 7,2006. 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. S 4904, relating to unsworn falsification to authorities. Date: 'l11J 0 (, ~ \ ') ~ - m- Emery W. Seeley, III, Plaintiff n .-::,~~ t"'C f'c r'._-- c EMERY W. SEELEY, III Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW SALLY P. SEELEY, Defendant : NO. 06-778 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301( c) of the DivotCe Code was filed on February 7,2006. 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. S 4904, relating to unsworn falsification to authorities. Date: {,pI f}, .;~ tJ f"--..::' C' EMERY W. SEELEY, III Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW SALLY P. SEELEY, Defendant : NO. 06-778 CIVIL TERM : IN DIVORCE (") r....," , ,",.:U'. ::::"1 i-;, r'...:.' WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE \",) r'-,~ 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: '1/ L1 0 b C \...J '-- .i"rT- Emery W. Seeley, III, Plaintiff EMERY W. SEELEY, III Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW SALLY P. SEELEY, Defendant : NO. 06-778 : IN DIVORCE CIVIL TERM "" C-:~~) , .;.'-' :'-'1 ~J f;:i N WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE p.) "',", (>', 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. ~4904, relating to unsworn falsification to authorities. Date: (p /.~" }fli4 , I S Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EMERY W. SEELEY, III v. : CIVIL ACTION - LAW Defendant : NO. 06-778 CIVIL TERM : IN DIVORCE SALLY P. SEELEY, 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 Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: February 10.2006 bv restricted. certified mail. return receiDt reauested. 3. Date of execution of the affidavit of consent required by Section 330 I (c) ofthe Divorce Code: by the Plaintiff Julv 1.2006: by Defendant June 25. 2006. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: ~!J5/~p Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: 7) zj~ f-. ANDREWS & JOHNSON Date: 7112... , 2006 (-".\ r.. .".1 ,;-1 r,.:; ~"- 'j C,) C' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . EMERY W. SEELEY, III Plaintiff No. 06-778 VERSUS SALLY P. SEELEY Defendant DECREE IN DIVORCE -=r l/.'fJrA;"t . )tIJ, ,IT 15 ORDERED AND AND NOW, ~~lY . DECREED THAT Emery W. Seeley, III , PLAINTIFF, Sally P. Seeley AND , 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; None . . G::?P . . . . J. . . ROTHONOTARY (~,..-rt/", ~ ",I.,-:J7 b$ ~ ~ ~')e-l JI";; 17/""'.411? -I"'l ?OJ WL , . "'. '\ ". ..:~.' .. ....; ...... ." . ,..".'