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Home My WebLink About06-18621 STACY B. WOLF, ESQUIRE ATTORNEY In NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF VANCE E. DUNKELBERGER, Plaintiff V. JACQUELYN C. DUNKELBERGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06 - CIVIL TERM IN DIVORCE 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 are warned that if you fail to do so, the case may proceed without you and a decree in 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 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 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF VANCE E. DUNKELBERGER, Plaintiff V. JACQUELYN C. DUNKELBERGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06 - I?L2? CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Vance E. Dunkelberger, an adult individual residing at RD 1, Box 103, Loysville, Perry County, Pennsylvania 17047. 2. The defendant is Jacquelyn C. Dunkelberger, an adult individual residing at RD 1, Box 101, Loysville, Perry County, Pennsylvania 17047. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on September 22, 1979, in Williamsport, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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. Section 4904, relating to unswom falsification to authorities. ewr- 2006 I/,, f r f>-. , L A i Vance E. Dunkelberger, Plain - f WOLF & WOLF ?30 , 2006 BY:? STACY B. WOLF, ESQUI Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff J Q c 3 l ?. an :? STACY B. WOLF, ESQUIRE ATTORNEY In NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF VANCE E. DUNKELBERGER, Plaintiff V. JACQUELYN C. DUNKELBERGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06 - CIVIL TERM :IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. 2006 Vance E. Dunkelberger, Plain ff STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF VANCE E. DUNKELBERGER, Plaintiff V. JACQUELYN C. DUNKELBERGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO.06- /S/ LZ CIVILTERM IN DIVORCE ACCEPTANCE OF SERVICE I, Jacquelyn C Dunkelberge , certify that I am the defendant in this matter. Furthermore, I hereby certify that on A 2006, 1 received a certified copy of the divorce complaint filed in this action. 2006 v j uel C. D nkelberger efen t t ? ? O ? S .fit < -t7 ?C' ? 7C t'? ?? v ;: ? ? t .P Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) VANCE E. DUNRELBERGER, Plaintiff Vs. JACQUELYN C. DUNRELBERGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 06-1862 CIVIL TERM IN DIVORCE ANSWER AND COUNTERCLAIM TO DIVORCE COMPLAINT Defendant, JACQUELYN C. DUNRELBERGER, by and through counsel of Andrew C. Sheely, Esquire, hereby files this Answer and Counterclaim to Plaintiff's Complaint, and respectfully states as follows: ANSWER TO DIVORCE COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. It is admitted that the marriage is irretrievably broken, and that Defendant is agreeable to submitting an affidavit consenting to the divorce without waiting for the 2 year separation period provided all marital assets are equitably divided without bifurcation, prior to the entry of divorce decree. 6. Admitted. WHEREFORE, Defendant requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. COUNT 1: E UITABLE DISTRIBUTION: CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 7. The allegations in Paragraphs 1 through and 6 including are incorporated herein and made a part hereof. 6. Plaintiff and Defendant are the owners of various personal property, real property, bank accounts, time deposits, stock, retirement assets, insurance policies, motor vehicles, jewelry and other items of personalty all acquired during their marriage. , Defendant requests that your Honorable Court equitably distribute the parties marital property, including marital debt, if any, and any such further relief as the Court may determine equitable and just, prior to the entry of a divorce decree. Respe tfully submitted, Date: May 4, 2006 rew C. Sheely, Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 2 VERIFICATION I verify that the statements made in this Answer and Counterclaim are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: May 4, 2006 'd AA 11,2?" J qu yn unkelberger CERTIFICATE OF SERVICE I, Andrew C. Sheely, Esquire, hereby certify that I am this day serving the foregoing Answer and Counterclaim of Defendant upon the following named individual this day by depositing same in the United States Mail, First Class, postage prepaid, at Mechanicsburg, Pennsylvania, addressed as follows: Stacy B. Wolf, Esquire 10 West High Street Carlisle, PA 17013 Date: May 5, 2006 (;i?'? V Andrew C. Sheely, Esqu" e o 7i f 7 cm ] r L7 f I, Pamela L. Purdy Attorney ID No. 85783 308 N. 2"d St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff VANCE E. DUNKELBERGER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-1862 CIVIL TERM JACQUELYN C. DUNKELBERGER, CIVIL ACTION - LAW Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly withdraw the appearance of Stacy B. Wolf as counsel for the Plaintiff, and enter the appearance of Pamela L. Purdy on behalf of Plaintiff, in the above matter. Stacy B. Wo# U PA I.D. No. Wolf & Wolf 10 West High Street Carlisle, PA /1.701f3 Dated: Lob lo Pamela L. Purdy U PA ID No. 85783 308 N. 2^d St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 Date: r ,ot, CERTIFICATE OF SERVICE The undersigned hereby certifies that on the iday of (L4 2007 a true and correct copy of the foregoing document was served by first- class mail, postage prepaid, upon the following: Stacy B. Wolf, Esq. Wolf & Wolf 10 West High Street Carlisle, PA 17013 Andrew C. Sheely, Esquire PO Box 95 Harrisburg, PA 17055 a4ka-1-f Pamela L. Purdy 0 ?'-} ? (? C:.v ? ? t.,.. ?i" ' J r... f ? II.l. flw? -_ .. -?,. .? -' ---1 VANCE E. DUNRELBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JACQUELYN C. DUNRELBERGER, 06-1862 CIVIL TERM Defendant IN DIVORCE MOTION FOR APPOINTMENT OF DIVORCE MASTER Jacquelyn C. Dunkelberger, Defendant, hereby moves this Honorable Court to appoint a Master with respect to the following claims: (X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite and in support of the motion states: (X) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Costs and Expenses (1) Discovery is complete as to the claims for which the appointment of a master is requested. (2) The Defendant has appeared in this matter and is represented by the undersigned attorney. (3) The statutory grounds for divorce are mutual consent (3301(c)). (4) The divorce action is not contested. No agreement has been reached as to distribution of marital assets. No further claims are pending as of this date. (5) The case does not involve complex issues of law, with the exception of dividing Plaintiff's military retirement benefit. (6) The hearing is expected to take less than one (1) day. (7) No additional is relevant to this motion. DATE: July L- , 2007 40'e/i/ (2 SL,-R drew C. Sheely, Esq re Attorney for Defendant ORDER APPOINTING MASTER AND NOW , 2007, , Esquire, is appointed master with respect to the following claims: Equitable Distribution By the Court: J Y CERTIFICATE OF SERVICE I, Andrew C. Sheely, Esquire, hereby certify that I am this day serving the Motion for the Appointment of the Divorce Master upon the following named individual this day by depositing same in the United States Mail, First Class, postage prepaid, at Mechanicsburg, Pennsylvania, addressed as follows: Pamela Purdy, Esquire 308 North Second Street Suite 200 P.O. Box 11544 Harrisburg, PA 17108 Date: July 2%4, 2007 Andrew C. Shee squire 7 . -%Y 7 t 7- -'1 i a.. Jig i 1, ` ..r VANCE E. DUNKELBERGER, Plaintiff VS. JACQUELYN C. DUNKELBERGER, Defendant s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 06-1862 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF DIVORCE MASTER Jacquelyn C. Honorable Court to claims: (X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pi Dunkelberger, Defendant, hereby moves this appoint a Master with respect to the following (X) Distribution of Property ( ) Support ( ) Counsel Fees ?ndente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims for which the appointment of a master is requested. (2) The Defendant has appeared in this matter and is represented by the undersigned attorney. (3) The statutory grounds for divorce are mutual consent (3301(c)). (4) The divorce action is not contested. No agreement has been reached as to distribution of marital assets. No further claims are pending as of this date. (5) The case does not involve complex issues of law, with the exception of dividing Plaintiff's military retirement benefit. (6) The hearing is expected to take less than one (1) day. (7) No additional is relevant to this motion. DATE: July 2JI 2007 (2 &? , M drew C. Sheely, Esq re Attorney for Defendant ORDER APPOINTING MASTER r AND NOW s , 2007, Esquire, is appointed iq?tTe7j with respect to the following claims: Equitable Distribution By t Cour ? ? J e? ii. LiJ - cti Ar CERTIFICATE OF SERVICE I, Andrew C. Sheely, Esquire, hereby certify that I am this day serving the Motion for the Appointment of the Divorce Master upon the following named individual this day by depositing same in the United States Mail, First Class, postage prepaid, at Mechanicsburg, Pennsylvania, addressed as follows: Pamela Purdy, Esquire 308 North Second Street Suite 200 P.O. Box 11544 Harrisburg, PA 17108 Date: July 211, 2007 A9 ?1" Andrew C. Shee squire C) ? 4 I \ Pamela L. Purdy, Esquire Attorney for Plaintiff Attorney ID No. 85783 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff VANCE E. DUNKELBERGER, Plaintiff V. JACQUELYN C. DUNKELBERGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1862 CIVIL TERM IN DIVORCE PRAECIPE TO WITHDRAW DIVORCE COMPLAINT Plaintiff Vance E. Dunkelberger, by and through his counsel, Pamela L. Purdy, Esquire, respectfully requests that his Divorce Complaint filed on March 30, 2006, be withdrawn. Respectfully Submitted, Pamela L. Purdy Date: ?Oecp 6 r K Attorney for Plaintiff CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing document was served by first-class mail upon the following: Andrew C. Sheely, Esquire 127 South Market Street PO Box 95 Mechanicsburg, PA 17055 P'?'4t. Pamela L. Purdy Dated: korc'A 61 L4021 r-.4 C= -77 "T3 { r