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Home My WebLink About06-6209 Debra Nailor, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LA W No. Dfrlo8.DQ CIVIL 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 Court House, High and Hanover Streets, Carlisle. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Debra Nailor, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VI. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LAW No. 6(p .~a.o9 CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Debra Nailor, an adult individual, who resides at 26 Clouser Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Wayne E. Nailor, Jr., an adult individual, who resides at 202 Shugart Avenue, Boiling Springs, Cumberland County, Pennsylvania 17007. 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 29, 2002 in Kings Gap, Mt. Holly Springs, 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. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & WHARE Date: October 24, 2006 L slie A. Tomeo, squire 155 South Hanov r Street Carlisle, P A 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff VERIFICATION 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 unsworn falsification to authorities. Date: /o/~ylo~ , , ~ 7(oJ~ Debra Nailor, Plaintiff t Debra Nailor, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VII. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LAW No. CIVIL IN DIVORCE CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Debra Nailor, Plaintiff do hereby certify that I this day mailed a copy of the within Divorce Complaint upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Wayne E. Nailor, Jr. 202 Shugart Avenue Boiling Springs, Pa 17007 Dated: October 24, 2006 s ie A. To 0, E quire 155 South Ha over Street Carlisle, PAl 7013 (717) 241-6070 Supreme Court LD. # 200198 Attorney for Plaintiff (") ,...., ~ (:=' "W 1:19-. ? ,;-:::> 0"' "Q -r) t:: Co :i! ~ ~~. (S1 c,;'( (-, fnf? ---\ L -o,-n .. ~ :0 N 'uO (.J1 c') (" ~ 6'" ""l 0 ;:'.I...'f. ~- -n l. ''', .:?=- m ::;;; (') i5 6"" ~ 0 6fT' ~ - --\ .S> ~ :E; ctr N :< ~ - -+- ~ Debra Nailor, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LAW No. 06- 6209 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 25, 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. ~ 4904, relating to unsworn falsification to authorities. Date: /k~.2 / ' Debra Nailor, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LAW No. 06- 6209 CIVIL IN 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 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: IJd b /0 7 / / ..,/J '1 '1 ( Debra Nailor, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LAW No. 06- 6209 CIVIL . IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 25, 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. ~ 4904, relating to unsworn falsification to authorities. Date: j4'1U J 0; 200? A' )1.1), .' 1;u'~/L U~1:-I Debra Nailor /Plaintiff Debra Nailor, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LAW No. 06- 6209 CIVIL IN 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 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: YUifL-,} 'I; 2007 I ~b '}?#Jd-<- Debra Nailor, Plaintiff Debra Nailor, Plaintiff v. Wayne E. Nailor, Jr., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA W No. 06- 6209 CIVIL IN DIVORCE PROOF OF SERVICE . Complete Items 1, 2, and 3. Also complete 11m 4 If Restricted Delivery Is desil'8d. . ,fIlItnt you~ name and address on the reverse . .. tI18t we Can return the card to you. . Milch this card to the b8ck of the mallplece, 01 on the front If space permits. 1. ~ Addresaed to: v...'lli.t l(\.O- E. ~'C>f, ~ ( . 2D 2., ~~X+ \\\Ie. ~d~ :S~'~l Po-. 1/00 t 2. JdcIe Number ,......,......... ..... ( ...form 3811, F*'-Y 2.004 3. SeMce lp 'Sit;CertIfted Mall [J Exprees MIIIl C RegI8Und ~ Recelptfor~A-tw D In8tnd MIIIl D C.O.D. 4. ~~ 0I1Iwery7 tEift,.., 7004 1350 0003 7142 7394 ...,J 00mIiIIIc AIiIum AecIlpt ~~. ,.."" c.:::> <:::;) -...J <.... )> z ~ C) ~ ~'::n r- -om :DO '.~.~ (~\ r --,.., ".... ;;~':: ~ -r! -- - .r:-- \C) .r..,~,. :.< Debra Nailor, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Wayne E. Nailor, Jr., Defendant CIVIL ACTION - LA W No. 06- 6209 CIVIL IN DIVORCE 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 ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: October 25, 2006, was served on Defendant by Certified Mail signed on October 26, 2006 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by ~ 3301(c) or The Divorce Code: by the Plaintiff, January 24,2007; by the Defendant, January 26, 2007. 4. Related claims pending: None. 5. (b) Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: January 29,2007. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: January 29,2007. Date: January 30, 2007 L ie A. Tomeo, squire '155 South Hano er Street Carlisle, PAl 7013 (717) 241-6070 Supreme Court ID No. 200198 o ~ ~.~ \Jce f"r1 f f' ~~'" (J"'l ~<-, 1.F'" """'- '";,:::--- ~~, ~~~~ )7 ~~~~ ,...." c:;:j c;::;:3 --.l <- ~ ~ ~ ~-n r11- -o~ ;~:} ~T~ :~~~ ~ {",) o -c ::;.r.: .r::- u:> if. if. if. if. if. if. if. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. if. if. if. if. Debra Nailor if. if. No. 2006- 6209 Pl~inriff VERSUS W~yTlP 1<: N~ i lor, ,Ir_ flpfpnn;:mr DECREE IN DIVORCE fe~ I ' LOO'l , IT IS ORDERED AND if. AND NOW, if. if. if. Debra Nailor DECREED THAT , PLAI NTI FF, if. if. if. AND Wayne E. Nailor. Jr. , DEFENDANT, if. if. if. if. if. ARE DIVORCED FROM THE BONDS OF MATRIMONY. if. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE if. BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ~~. if. !f. !f. if. !f. !f. !f. J. ATT '" if. '" PROTHONOTARY if. if. 1f. if. if. [t; [t; [f; if. ~'I';/1 L.... ~ ~ ??7J..~U /' -?roT ..,.- , V _ . -r -'&., (..0, Lf' f' ~ ~~~1#""tl-~ LO/fY'(? . . -., -,~,., . '-t-.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW _Debr a i LDe w Plaintiff 9 FILE NO. 0 -c3 rri VS. IN DIVORCE ' Z 3 (p 3 t► °e�� Q�r)� diLv Sf2. xy Y Defendant d 3.66 G NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the ��10. 9-day of 2-007 , hereby elects to resume the prior surname of K i N 4 and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: `f 71Qre h 2-0) 22-013 Signature //& a Y4�n a-- Sijnature of name beik resi6hed COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the ac}-/`o day of 20 13 , before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. � Notary Public hothenotary�CVW**rbM C*%#f tsrW PA My CgrMn WW t Mes the r'%t 41W