The URL can be used to link to this page

Home My WebLink About02-3506Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, IN THE COURT OF COMMON PLEAS Plaintiff V. KENNETH R. WHITSEL, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3506 : : CIVIL ACTION - LAW : IN DIVORCE Dated: August 1, 2002 AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7000 0600 0028 3892 4599, Return Receipt Requested, on the above- named Defendant, Kenneth R. Whitsel, on July 30, 2002 at Defendant's last known address: P.O. Box 3026, Grantham, Pennsylvania 17027. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are tree and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. J Barbara Stlmple-Sullivan, Esquire /549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Postage Certified Fee Return Receipt Fee (Endorsement Required) Restt~ted Delivery Fee (Endorsement Required) Total Postage & Fees IIi Complete items 1, 2, and 3. Also complete Ilem 4 if Restricted Delivery is desired. III Print your name and address on the reverse ae that we can return the card to you. · ~ltach this card to the back of the mailpiece, er on the front if ~p-ce permits. 1. ~ticle Addressed to: RESTRICTED Form 3811. July lggg D. Is detivery addr--',=,~s diffemnt from item l? r-I y# If YES, enter delivery address below: [] N~ 3. Service Type ~.C~'tified Mail [] Express Mail ~ [] Registered [] Return Receipt for Me~ J [] Insured Mail [] C.O.D. [_4. Re?ricted Delivery? ~xtra Fee) Domeetic Return P~ EXHIBIT "A" Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, Plaintiff KENNETH R. WHITSEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. : : CIVIL ACTION - LAW : 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 ~ew C~L ~Weet ~717) 7'' °erlatM, P,I - Pl~nti~ v. :~ Defend~t ~L, .' ' 0~, 0~ ' PE~YLVANM 1. ~. CO~. ~CE ~w . rl~nti~:_ -. '"r~AIN ~. _ Mech~'CSb~g, C~f' ,s ~he~ D. ~'tsel, ~ f ~ D~O~c~ 2. °~v~a 17050. ~t220 Co~6~on~ Co~ 3. Bo~ pl~nti~and D ~sylv~h got at le~t six ~' e~end~t have been ~ ~ ~ ~ ~onths P~or to ~ling ,~ .~'~ ade ~sidents in ~e uns eo~Plain[ C°~°n~e~ o~ The PlaintilTand Defendant n COWry' Pennsylvania. The~e is 1999. One (1) minor Child born The Parties separated on Jane 21, Were tnarr/ed on Decetnber 18, 1993 1'11Lewistov~, °£th/'s rnarr/age' Daulton L. Vffhitsel, date O£birth 2002. ance with § ~ter judgment: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, Plaintiff V. KENNETH R. WHITSEL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT REGARDING COUNSELING 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 Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I undemtand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unswom falsification to authorities. Dated: Barbara Sumple-Sullivan, Esquire Supreme Court//32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, Plaintiff Vd KENNETH R. WHITSEL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, Sherri D. Whitsel, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are tree and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. Dated: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, Plaintiff KENNETH R. WHITSEL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, Plaintiff KENNETH R. WHITSEL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiffis Sherri D. Whitsel, an adult individual residing at 220 Constitutional Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Kenneth R. Whitsel, an adult individual with a mailing address of P.O. Box 3026, Grantham, Cumberland County, Pennsylvania 17027. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on December 18, 1993 in Lewistown, Mifflin County, Pennsylvania. 5. There is one (1) minor child bom of this marriage, Daulton L. Whitsel, date of birth March 7, 1999. 6. The parties separated on June 21, 2002. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plalntiffhas been advised that counseling is available and that Plaintiff has the fight to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaimiffrequests entry of a divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Sherri D. Whitsel, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; and 2 B. Awarding other relief as the Court deems just and reasonable. Dated: July~_~,~2002 , Esquire ~ Attorney for Plm'ntiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 3 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 {717) 774-1445 SHERRI D. WHITSEL, Plaintiff KENNETH R. WHITSEL, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT REGARDING COUNSELING 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 Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unswom falsification to authorities. Dated: Barbara Sumple-Sullivan, EsquLre Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, Plaintiff KENNETH R. WHITSEL, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, Sherri D. Whitsel, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are tree and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to un_sworn falsification to authorities. Dated: IN THE COURT OF COMMON pLw. AS OF CUlW!a_~D COUNTY~ PENNSYLVANIA SHERRI D. WHITSEL, Plaintiff KENNETH R. WHITSEL, Defendant CIVIL ACTION - LAW NO. 02 - 3506 IN DIVORCE PRAECIPE TO ENTER APPEARANCE To: Curt Long Prothonotary of Cumberland County Please enter my appearance on behalf of the Defendant, Kenneth R. Whitsel, in the above captioned matter. Gre Attorney for Defendant 2423 North Third Street Harrisburg, PA 17110 (717) 238-0434 Attorney I.D. 23705 pc: Barbara Sumple-Sullivan Barbara Sumple-Sullivan, Esquire Supreme Court//32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WHITSEL, Plaintiff KENNETH R. WHITSEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3506 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above referenced case discontinued. Dated: May 30, 2003 Respectfully~d, Barbara Sumpl~-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHERRI D. WH1TSEL, IN THE COURT OF COMMON PLEAS Plaintiff KENNETH R. WHITSEL, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3506 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served the foregoing Praeeipe to Discontinue, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Dated: May 30, 2003 Gregory R. Reed, Esquire 2423 N. Third Street Harrisburg, PA 17110 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317