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Home My WebLink About06-2240 GERALD BERTRAND A. WALTZ, JR, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ()~- ,)d/6 ~ SHANNON PHELAN, Defendant CIVIL ACTION - LAW ACTION 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 verification 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 at the Cumberland County Courthouse, 1 Courthouse Square, 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 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 or 800-990-9108 ~ Elizabeth A. Hoffman, Esquire 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 BERTRAND A WAL T2, JR. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. SHANNON PHELAN, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Bertrand A Waltz, Jr., an adult individual whose current mailing address is 43 Oak Avenue, Camp Hill (Cumberland County), Pennsylvania 17011. 2. Defendant is Shannon Phelan, an adult individual whose current mailing address is Cumberland County Prison, 1101 Claremont Road. Carlisle (Cumberland County), Pennsylvania 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint 4. Plaintiff and Defendant were married on April 18. 2004, in Las Vegas, Nevada. 5. Plaintiff and Defendant have two children: Keeghan M. Waltz DOB 4/23/2002 Maddach E. Waltz DOB 12/11/2003 6. There has been no prior action for divorce or annulment between the parties. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 8. Defendant is not a member of the Armed Services. 9. Plaintiff avers that the ground on which the action is based is the marriage is - irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a Decree in Divorce dissolving the marriage between the parties pursuant to Section 3301 (c) of the Divorce Code of 1980, as amended. Respectfully Submitted, ~4.~ Eliza th A. Hoffman, squire Attorney for Plaintiff 106 Walnut Street Harrisburg, PA (717) 236-2956 ID #71000 2 ~ VERIFICATION I verify that the information provided in the attached document is 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.C.SA 34904, relating to unsworn falsification to authorities. Date: 1/5100 I cJ2uJ alt Bertrand A Waltz, Jr. r; BERTRAND A. WAL T2, JR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. SHANNON PHELAN, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE CERTIFICATE OF SERVICE I, the undersigned person, do hereby certify that a true and correct copy of the Complaint in Divorce was personally delivered to the following person: Shannon Phelan Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 Date: Courtney Waltz Law Office of Elizabeth A. Hoffman 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 (~,., ~ . _' ,"'" ,.,.,,>J ('~, ?-- r --i -S--. """ v-J .,- -:---.., r---,' ~,.~ 4- -+- -- ~ " '-" " .~-" ~ -, ,..-.", \~\ " ,;.; -- BERTRANDA. WALTZ, JR., Plaintiff v. SHANNON PHELAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0(, - ~-</O C ,;/1 CIVIL ACTION - LAW ACTION IN DIVORCE CERTIFICATE OF SERVICE I, the undersigned person, do hereby certify that a true and correct copy of the Complaint in Divorce was personally delivered to the following person: Date: 4ri I olP1. ;;?(){}~ Shannon Phelan Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 Courtney Waltz Law Office of Elizabeth A. Hoffm 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 t--.:) C:::::J <:= ......J ..." rr; co I CD o "Tl ::rt r-nl1 :-0 r; '}U , " . .~~ t.:'" ~_.~ =.j~'j ~~ ~ ,p:...l!I' ~..~ ~ 9? v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 0& - d~io (7/(/// CIVIL ACTION - LAW DIVORCE BERTRAND A. WALTZ, JR. Plaintiff SHANNON PHELAN Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 21, 2006. 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. 94904 relating to unsworn falsification to authorities. Date: bJ./S- /D7 tv0 S annon Phelan .J/A S's* /qr7i- ~b""c5"*2.~ ~ 0 e;::.? -n ---' -n r'1 c;:? , CO :=- v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. tJ& - ~.t./tJ G v' // BERTRAND A. WALTZ, JR. Plaintiff SHANNON PHELAN Defendant CIVIL ACTION - 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 div9rce 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/:/D7 ~~ Shannon Phelan o r;: ~?:':...:~ ~ ::3 -n jl\ cD , Cf.) q, .-\ --r' ~ -',\ .. (1 n~ -;;\:7 '~-~.(~i'j ~ .~;~~?:\~ C;? ~ :;:' :;;.c;. - v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 0& - ~;/ I/o ~\v/I BERTRAND A. WALTZ, JR. Plaintiff SHANNON PHELAN Defendant CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 21, 2006. 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. 94904 relating to unsworn falsification to authorities. Date: d 15" /01 ~ Bertrand A. Itz, Jr. .SS:tJ; ;Zo!::'-- t,~ - 5//r s ~ t::::' c::::> --J -n rn co , co ~ :::;i ..-n ft'ir -ntiJ. ':O),cr , :i~^:-/. c_\5~J~ -...{ '''r="", ~o :..<. '?? s:- - v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. Ou-~d"iO C!ivi ( CIVIL ACTION - LAW DIVORCE BERTRAND A. WALTZ, JR. Plaintiff SHANNON PHELAN Defendant 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 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: ~/r:- /01 -) . /",,-..) ~5 ........l -" {"'I-I CO \ CO :?: - o .,., s:!:u r11 roo' -<J \-r\ .)0 .;.~~ (~j~? ~'-'f . ", "r '.f:~~~2\ ~~:l ~ :2, Cf? .c" - BERTRAND A. WALTZ, JR. Plaintiff v. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. ()~_ 2~~.- C!vr'/ CIVIL ACTION - LAW DIVORCE SHANNON PHELAN Defendant 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. Grounds for divorce: Irretrievable breakdown under section 3301 (c) of the Divorce code. 2. Date and manner of service of the Complaint Service effectuated bv Hand Delivery . 3. Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by Plaintiff February 5, 2007; by Defendant February 5,2007. 4. Related claims pending: None 5. Date plaintiffs Waiver of Notice was filed with the Prothonotary: February 8, 2007. Eliza eth A. Hoffman, squire Attorney for the Plaintiff o c~ :t.-~ -;..-; '.. \ ~ c::::- ......,I -n r>1 CO \ CO o -'11 :?-r\ ff'1h~ -:~C ~~j (~) ~ {.,;~~~ -. . ~.""'.. "~ Cf) . . J;'" - IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY if. PENNA. if. STATE OF if. if. if. - 0;, !,and /I. )zhJl~J No. 0(, - ,;)240 if. if. if. if. -5lCd</<-h' ~_k"- if. DECREE IN DIVORCE AND NOW, ~ t:J ~, DECREED T:T ~.-h'A.Ft.c/ // )~/t? /(2 I ~-. AND S~A-/L{')rl rpk-fa-F<- IT IS ORDERED AND if. if. , PLAI NTI FF, if. if. , DEFENDANT, if. if. if. if. if. if. if. if. ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE if. BEEN RAISED OF RECORD IN TH IS ACTION FOR WHICH A FI NAL ORDER HAS NOT if. YET BEEN ENTERED; if. AJo~ J. if. if. PROTHONOTARY 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. _ ~ ") ~ ~ /I.. {Jl- r::f' t' ~ p/;-~ ~-rr,) LO- ~.C" . . . .-