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HomeMy WebLinkAbout02-1343GERALD JOSEPH STEMPLE Plaintiff vs. CAROL ANN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVA/qIA NO. 2002 --/~ CIVIL TERM LAW - 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, First Floor, Carlisle, Pennsylvania 17013, Telephone: (717)-240- 6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ~%~NULMENT IS GRA/qTED, 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, Pennsylvania 17013 Telephone (717)-249-3166 GERALD JOSEPH STEMPLE Plaintiff vs. CAROL ANN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 -- ~ CIVIL TERM LAW - DIVORCE COMPLAINT The plaintiff by his attorney, MURREL R. WALTERS, III, ESQUIRE, brings this action in divorce for a Decree of Divorce from the bonds of matrimony and respectfully represents: 1. The plaintiff is GERALD JOSEPH STEMPLE, an adult individual, who currently resides at 6280 Carlisle Pike, Lot 211, Mechanicsburg, Cumberland County, Pennsylvania since 1997. 2. The defendant is CAROL ANN STEMPLE, an adult individual, has resided in Nevada for a period of time in excess of two (2) years and utilizes as her mailing address P.O. Box 242, Jackpot, NV 89825. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on August 29, 1987. 5. There have been no prior annulment between the parties. actions of divorce or for The plaintiff avers that the marriage is irretrievably broken. 7o Divorce. 8. The plaintiff requests the Court to enter a Decree of Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, plaintiff does not request that the court require the parties to participate in counseling prior to a Divorce Decree being handed down by the court. WHEREFORE, the Plaintiff prays that a Decree in Divorce be entered divorcing Plaintiff from the bonds of matrimony h~retofore existing between Plaintiff and Defendant. Re~~~~~d/' Murrel R. Walters, III, Esquire Attorney for Plaintiff 54 E. Main Street Mechanicsburg, PA 17055 (717) 697-4650 I.D. No. 24849 GERALD JOSEPH STEMPLE Plaintiff vs. CAROL ANN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 CIVIL TERM LAW - DIVORCE ~-ERIFICATION I, GERALD JOSEPH STEMPLE, verify that the statements made in this Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. GERALD JOSEPH STEMPLE Plaintiff vs. CAROL ANN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1343 CIVIL TERM LAW - DIVORCE AFFIDAVIT OF SERVICE I, MURREL R. WALTERS, III, ESQUIRE, being duly sworn according to law, depose and say that on March 21, 2002, I mailed by certified mail, restricted delivery, a true copy of the Divorce Complaint filed by GERALD JOSEPH STEMPLE, to the defendant, CAROL ANN STEMPLE. A receipt was returned to me which ~n'dicates / the Complaint was received by CAROL ANN STEMPLE o~ April 1, Said receipt is attached hereto. /~/~~/ Murrel R. Walters, III, Esquire Attorney for Plaintiff 54 E. Main Street Mechanicsburg, PA 17055 (717) 697-4650 I.D. No. 24849 that 2002. Sworn to and subscribed before me this ~9~-~ day of O~'~%~-- , 2002. Notary Public NOT/tRIAL SEAL DEBORAH L RYAN, NOTARY PUBLIC CiTY OF MECHANICSBURG, CUMBERLAND COUNTY MY COMMISSION E~RES JUNE 11, 2006 GERALD JOSEPH STEMPLE Plaintiff VS. CAROL ANN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-1343 CIVIL TERM : : LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on March 19, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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. ~ 4904 relating to unsworn falsification to authorities. Date: O~'ANN ST~.MPL~' ~ / - GERALD JOSEPH STEMPLE Plaintiff vs. CAROL AITN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-1343 CIVIL TERM : : LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on March 19, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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. § 4904 relating to unsworn falsification to authorities. Date, / 0/~-.~ ~-- GERALD J~EP~ STEMPLE / GERALD JOSEPH STEMPLE Plaintiff vs. CAROL ANN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-1343 CIVIL TERM : : LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 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 decree 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 understand 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: GERALD JOSEPH STEMPLE Plaintiff vs. CAROL ANN STEMPLE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1343 CIVIL TERM LAW - DIVORCE 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 decree 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 understand 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: GERALD JOSEPH +~TEM[PLE ~' GERALD JOSEPH STEMPLE VS. CAROL ANN STEMPLE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 2002-1343 CIVILTERM 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 §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the complaint: Via certified mail, return receipt requested on 4/1/02 Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff 10/28/02 ; by defendant 10/2 1/02 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: n/a (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with // / the Prothonotary: 1 o / 3 1 / o :2 Divo e asfil d "t Date defendant's Waiver of Notice in §3301 (c)/~7/ 7~/~/~' the Prothonotary: 10 / 3 1/0 2 Attorney for Plaintiff / Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF _~. PENNA. GERALD JOSEPH STEMPLE VERSUS CAROL ANN STEMPLE N O. 2002-1343 AND NOW, DECREED THAT DECREE IN DIVORCE ~l~, IT IS ORDERED AND , PLAINTIFf, GERALD JOSEPH STEMPLE AND CAROL ANN STEMPLE , 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 ATTEST: ~ J. PROTHONOTARY · Complete items 1, 2, and 3. Aisc complete item 4 if ~F~tricted_Delivery is desired. · Print your name and address on the reverse so teat we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. A~icle Addressed to: / qarol Ann Stemole 3 Jack~o~ N~vada 89825 A. Received by (Plea..s_e Print Cl~esrly) B. Date of Delivery C. Si~l~lure [] Agent If YES, ent~', delivery addf~,s below: [] %No 3. Service Type ~ Certified Mail [] Registered [] Insured Mail [] Express Mail [] Return Receipt for Merchandise [] CmO.D, 4. Restricted Delivery? (Extra Fee) ~ Yes 2. Article Number (Copy from service label) 7099 3220 0011 0112 0204 PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952