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HomeMy WebLinkAbout06-4133 Johnson, Duffie, Stewart & Weidner By: Elizabeth D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff HEATHER VAN TASSELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 6L-LJI.J.J (!/;>t.L T<;/2-j CIVIL ACTION - LAW IN DIVORCE v. JONATHAN J. VAN TASSELL, Defendant 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 Telephone: (717) 249-3166 Johnson, Duffie, Stewart & Weidner By: Elizabeth D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff HEATHER VAN TASSELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. N--l./{.l? dc."LY~ CIVIL ACTION - LAW IN DIVORCE v. JONATHAN J. VAN TASSELL, Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Heather Van Tassell, by and through her attorneys, . Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Jonathan J. Van Tassell: 1. The Plaintiff is Heather Van Tassell, an adult individual, residing at 851 Brian Drive, Enola, Cumberland County, Pennsylvania 17025. Plaintiff's Social Security Number is 200-68-6482. 2. The Defendant is Jonathan J. Van Tassell, an adult individual, residing at 4183 Grouse Court, Apartment 114, Mechanicsburg, Cumberland County, Pennsylvania 17050. Defendant's Social Security Number is 177-23-0063. 3. The Plaintiff and Defendant were married on August 27, 2005 in Mechanicsburg, Cumberland County, Pennsylvania. 4. Both Plaintiff and Defendant have been a bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The parties separated on or about May 13, 2006. 7. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests your Honorable Court enter a Decree in Divorce. JOHNSON, DUFFIE, STEWART & WEIDNER By: ~~ Eliza th D. Snover :273842 VERIFICA TlON I, Heather Van Tassell, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge. information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A 94904, relating to unsworn falsification to authorities. Date: I f}{) 1kc&h( YaJ;;~ ~o GO Heather Van Tassell .' ' '" Johnson, Duffie, Stewart & Weidner By: Elizabeth D. Snover LD. No. 200997 30 I Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff HEATHER VAN TASSELL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. (}('-'-I/33 v. CIVIL ACTION - LAW JONATHAN J. VAN TASSELL, IN DIVORCE Defendant AFFIDA VIT HEATHER VAN TASSELL, 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 by the court. 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: <-rlf)()~ I y Heather Van Tassell ~ iQ :::u 1 -- ft. ~ ...... 0 ........ ~ \) D ~ lJ 1 ~ j ,. '. ~, C) " r t, '"Q -- I" r~ c. ~ ... Johnson, Duffie, Stewart & Weidner By: Elizabeth D. Snover J.D. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0,6 - If /3g HEATHER VAN TASSELL, v. JONATHAN J. VAN TASSELL, CIVIL ACTION - LAW IN DIVORCE Defendant RETURN OF SERVICE The undersigned makes the following return of service: The Complaint in Divorce was mailed to the Defendant, Jonathan J. Van Tassell, on July 25,2006 at his residence of 4183 Grouse Street, Apartment 114, Mechanicsburg, PA 17050. A copy of the signed return receipt indicating service was completed on July 26, 2006 by certified mail is attached hereto. I, Elizabeth D. Snover, certify that I am a competent adult not a party to the action. I verify that the statements made in this affidavit and return of service 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: 07-2/- ~ {, JOHNSON, DUFFIE, STEWART & WEIDNER By: EI~er~ . ~ ~. . OIl..... IllIm8 1. 2, and 3. A/IIo COfTIIIlelit .., 411 RestrIcted DelIwry Is deeInId. . MIl your Il8IIIll and eclclIW8 on the 1'8\/1II1I8 .1hlII we ClIl1l8lUm the card to you. . MIlch thle card to the. b8ck of the rnallpIeoe, . on the front II op&C8 permlts. t. ~Ad4!JUr'to: hy'~flQfill<1:] !hq /r;S$e-{ / * g -.3 'fJr6uSt: (J<<V+ A..ja1+/Ut.A.+ I(If 'f'l.tdIL>\,~k<'j Pi... !JtlSI) [JAgeoil [J C.OoleCII~ o .... s" 3. SIMce 1Wle 1Ii ~ Mol [J Elopo.- Mol tJ ""G' T.d [J RoIum IlIcoIpl for _....... [J ~ Moll [J C.O.D. 4. -.Lll.d DoIIvory'I jEldIa Feel [J ... ~ ~~5D DDD3 ~SDl ~lSS ~ ....1 (") ~ .-~\ ~ HEATHER VAN T ASSELL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-4133 Civil Term v. CIVIL ACTION - LAW JONATHAN J. VAN TASSELL, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 21,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. 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 , 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 above 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:~aY~ 2~" UO~ ~~\~QQ Heather Van Tassel, Plaintiff :285487 - 1 - r-<) _.; (.:-'~ HEATHER VAN TASSELL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 06-4133 Civil Term v. CIVIL ACTION - LAW JONATHAN J. VAN TASSELL, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 21, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. 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 I division of property I 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904 relating to unsworn falsification to authorities. Date: n tJo d 7J,:.)O(y ---- . Van Tassell, Defendant :285489 - 1 - ~.:. \ ,~ ~-j -n :;--1 j~.i 1"." _I ~) f'<\ (P ( \ - Johnson, Duffie, Stewart & Weidner By: Elizabeth D. Snover I.D. No. 200997 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA NO. 06-4133 HEATHER VAN TASSELL, v. CIVIL ACTION - LAW JONATHAN J. VAN TASS ELL, IN DIVORCE 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: Defendant was served via Restricted Delivery U. S. Mail on July 26,2006. Return of Service was filed August 1, 2006. 3. Complete either Paragraph A or B A. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff October 26, 2006; by the Defendant October 8, 2006. B. (1) Date of execution of the Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the Plaintiff's affidavit upon the Defendant: \ . - 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d) (1) (i) of the Divorce Code: Waiver of Notice signed by Plaintiff on October 26,2006 and filed concurrently herewith. Waiver of Notice signed by Defendant on October 8, 2006, and filed concurrently herewith. JOHNSON, DUFFIE, STEWART & WEIDNER By: ~.~.j~-~~~ Efj;~~~~;n~ :286745 Enclosures (") C -".. "'~ -cJ Co '1"1 r-~~ Z~:r: ~;i~. r;:c., t~= 5 <-< f"-.) ~ c:::> 0" Z o -< N 1.0 ~ ~~ ~9 06 7:!-r; X.." Q-- L_~ ~ ~ -0 :x - .. -.J lii liiliilii 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. if.if.if.if.if.if.liiif.if.if. if. if.if.if.if. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. HEA'lHER VAN TASSELL, Plaintiff No. 06-4133 VERSUS JaWmAN J. VAN TASSELL, Defendant DECREE IN DIVORCE AND NOW, ~ t. t. t."M '0 e..(' ~ , lOO(P, IT IS ORDERED AND DECREED THAT HEA'lHER VAN TASSELL , PLAI NTI FF, AND JaWmAN J. VAN TASSELL , DEFEN DANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; if. if. if. if.if.if. if.if. if. ~:t:~:+::+::+:ff.:f.ff.ff.ff.:f.ff. :f.ff. ff.ff.ff.ff. ff.ff.~ ff.~ ff.ff.ff.ff.ff.ff.ff.ff. 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. if. if. if. if. if. J. (~O"~..,,;<~ ~) ~:2- ~ ~ 'Jr:? 1-e/ ~ ~9 ~~? -r'f} ?c? tt; - C/ ;. . ..' , : \'... - ..