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Home My WebLink About02-3978In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, Plaintiff, VS. DOUGLAS J. WAGNER, Defendant. No. 2002- CIVIL TERM 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 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 at: 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, Plaintiff, VS. DOUGLAS J. WAGNER, Defendant. ) ) ) No. 2002 - ) ) CIVIL TERM ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divome proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divome Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to ~ou and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Michael S. Travis ID No. 77399 4076 Market ~treet, Suite 209 Camp Hill, PA 17011 (717) 731-9509 In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, ) Plaintiff, ) vs. ) No. 2002 - ) DOUGLAS J. WAGNER, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by her attomey Michael S. Travis, respectfully represents: 1. Plaintiff is Marion M. Wagner, who resides at 79 Hillside Circle, Camp Hill, Cumberland Cotmty, Pennsylvania, 17011, since February 2002. 2. Defendant is Douglas J. Wagner, who resides at P.O. Box 130, Tunnelton, Preston County, West Virginia, 26444, since April 2001. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 3, 1995, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that .the parties have lived separate and apart for at least two (2) years. 8. 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. 9. Neither Plaintiff nor Defendant are in the Military Service in the United States Armed Serviced. Neither Plaintiff nor Defendant are within the provisions of the Soldiers' and Sailors' Relief Act of Congress of 1940 and its amendments. 10. Plaintiff requests the court to enter a decree of divorce. 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. § 4904, relating to unswom falsification to authorities. ~Ma~ion M: Wagn~, Plai~iff ' Attorney for Plaintiff I.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, Plaintiff, VS. DOUGLAS J. WAGNER, Defendant. ) ) ) No. 2002 - 3978 ) ) CIVIL TERM ) IN DIVORCE AFFIDAVIT OF SERVICE I, Michael S. Travis, attomey for Plaintiff, in the above captioned action for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. 7001 1940 0005 8709 7077, return receipt requested, by depositing the same in the United States mail on August 20, 2002, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was received by the Defendant on August 24, 2002. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. · Complete items 1, 2, and 3. Also COmplete item 4 ii' Restricted Delivery is desired. · Print your nam~ and address on the reverse S° that we can return the card to you. · At~ach thfs card to the back of · · ~nt if S-pace permits the ma~lplece, Douglas j. Wagner P.O. Box 130 Tunnelton, WV 26444 A. Received by(PleasePdn Agent No Cert~ed Mail 1~ Express Mail Registered ~] Return Receipt for Merchandise 2. Articte Number (Copy from service label) 7001 1940 0005 6709 70~7 ~S~°rm3811~~ Rotlu~n~5~.~tDDDS 870~ 70-~7 ~02595-00-M-0952 In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, ) Plaintiff, ) vs. ) No. 2002 - 3978 DOUGLAS J. WAGNER, ) ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT 20,2002. 2. A complaint in divorce trader § 3301(c) of the Divorce Code was filed on August The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ora 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. Defendant In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, ) Plaintiff, ) vs. ) No. 2002 - 3978 ) DOUGLAS J. WAGNER, ) CIVIL TERM Defendant. ) IN DIVORCE ,W~A~I_V. ~E~R OE NOTICE OF INTENTION TO REQUEST ENTRY OF ~:~ A UlVORCE DECREE UNDER § 3501(e) 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 ifI 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 unswom falsification to authorities. Date: ~4~/Y ~2.~ In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, ) Plaintiff, ) vs. ) No. 2002 - 3978 ) DOUGLAS J. WAGNER, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT 20,2002. A complaint in divorce under § 3301(c) of the Divorce Code was filed on August 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ora 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 unswom falsification to authorities. ~fner, PJ6intiff In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, ) Plaintiff, ) vs. ) No. 2002 - 3978 ) DOUGLAS J. WAGNER, ) CIVIL TERM Defendant. ) IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY O~¢ 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 ifI 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 unswom falsification to authorities. I~arion ~ W~gner, P~ainti?f Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 , In the Court of Common Pleas of Cumberland County, Pennsylvania MARION M. WAGNER, VS. Plaintiff, DOUGLAS J. WAGNER, Defendant. ) ) ) No. 2002 - 3978 ) ) CIVIL TERM ) 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: Code. Ground for divorce: irretrievable breakdown under § 3301(c)(1) of the Divorce 2. Date and manner of service of the complaint: Complaint was mailed August 20, 2002, via United States certified mail, restricted delivery, return receipt requested to Defendant, which was received by Defendant on August 24, 2002, Affidavit of service attached hereto. 3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on December 10, 2002; by Defendant on December 5, 2002. 4. Related claims pending: No economic claims were raised. 5. Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: /~- - / ~.. 02- prothonotary: Date Defendant's Waiver of Notice in § 3301(c 'vorce was fi · /7_ - t ~_ .~z-- 3,301 (~ led w~th the l~Iichael S. Tra~s ' - Attorney for Plaintiff MARION M. WA~NER, Plaintiff, VERSUS DOUGLAS J. WAGNERr Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ,¢ ~ PENNA. NO. 2002-3978 DECREE IN DIVORCE AND NOW, ~~ DECREED THAT Marion M. Wagner AND Douglas J. Wagner ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND ., PLAI NTIFF~ , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None____,_. BY TH OTHONOTARY