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HomeMy WebLinkAbout95-04825x SFxrs a ?? ? v t }Y`v'S F.. 3 rv s tg"t ?i'Sa ?'>?ss?ta ;ji tt Ik"A'-x {?r'sti?? r4 ysr rs Y { 4 I} { fs ya 92'1' xl_ 4 ? J g 71 Y F { v k q caa s 4'? s ?4L?] 46e ?.HtIT?p f H iuf 12, i{ Y ?1 Z? a f .I ? ? H°?by 11A, I c xr r '' t ; gym' r ? t_ , KELLY H. BUSLER, Plaintiff vs. JEFFREY M. BUSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- //3'1 } CIVIL ACTION-LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGWrS 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: CUMBERLAND ODUNTY COW HOUSE, 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. COURT ADMINISTRATOR, FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 240-6200 KELLY H. BUSLER, Plaintiff va. JEFFREY M. BUSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA i i NO. 95- CIVIL ACTION-LAW i IN DIVORCE NOTICE OF AVAILABILITY OF COUl7SELIM TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce 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 Divorce 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 offices 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne 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. KELLY H. BUSLER, Plaintiff va. JEFFREY M. BUSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- CIVIL ACTION-LAW IN DIVORCE Plaintiff, Kelly H. Busler, by her attorney, Dawn S. Sunday, sets forth the following: 1. Plaintiff is Kelly H. Busler, who currently resides at 210 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Jeffrey M. Busler, who currently resides at 210 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately preceeding the filing of this Complaint. 4. Plaintiff and Defendant were married on September 28, 1990 in Frederick County, Maryland. 5. There have been no prior actions of Divorce or for annulment between the parties. 6. Plaintiff avers as the grounds upon which this action is based that the marriage between the parties hereto is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests that the Court enter a Decree of Divorce under section 3301(c) or 3301(d) of the Pennsylvania Divorce Code. COUNT II - CUSTODY 9. The prior paragraphs of this complaint are incorporated herein by reference as though set forth in full. 10. Plaintiff seeks custody of the following Childrent PRP.SM BffiIDEWZ BIAZ11 DATE NAME 210 W. Main Street, February 13, 1991 Bryce Calvin Buller Mechanicsburg, PA 17055 Lyndsay Elias eusler 210 W. Main Street, Mechanicsburg, PA 17055 April 20, 1992 McKenzie Mae Buller 210 W. Main Street, Mechanicsburg, PA 17055 December 5, 1994 The Children were not born out of wedlock. The Defendant Childrwho ores ide satt 210 W.t Mainu Street,f MechanicsburgPlaintiff PA. During the past five years and since their birth, the Children have resided with Plaintiff and Defendant at 210 W. Main Street, Mechanicsburg, PA. at 10 the Chiren is 11. The g Mother of W. Main Street, Kelly Mehanicsburgo PA curSheetis residl married to the Defendant. Main r Street, Mechanicsburg, PA. currently He is 12. rThe esiding e at 0 210 the Children married to the Plaintiff. 13. Plaintiff has not participated as a party or a witness or in another ldren y in in this or other litigation r ourcconcerning the custody the Chi 14. Plaintiff has no information of any custody proceeding concerning the Children pending in a Court of this Commonwealth. P 15. Plaintiff does not know of a person not a custody of thep Children toe proceedings who has physical c claims to have custody or visitation rights with respect to the Children. 16. The best interest and permanent welfare of the Children will be served by granting the relief ed sbencese Plaintiff has been the Children's primary caretaker their birth and proper provided environment. Children with a and Plaintiff lo loving, stable, c safe and has 17. Each parent whose parental rights to the Children have not tthhen Chiterminated and ldren have been h named person as parties to thiis action. of who has Mid, Plaintiff requests that the Court grant Plaintiff primary physical custody and shared legal custody of the Children, with liberal rights of partial physical custody to Defendant. RESPECTFULLY SUBMITTED# Dawn S. Sun ay, Esquire I. D. #41954 39 West Main Street Suite 1 Mechanicsburg, PA 17055-6230 (717) 766-9622 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 unworn falsification to authorities. Date Kelly us er, P aintLff - ii tq:• ? ?? ? \ l` ??O C0 _ 41 y ¦ KELLY H. BUSLER, Plaintiff Va. JEFFREY M. BUSLER, Defendant s IN THE COURT OF COMMON PLEAS OF s CUMBERLAND COUNTY, PENNSYLVANIA i NO. 95-4825 CIVIL ACTION-LAW i i i IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce, which was filed on September B, 1995 under the above-referenced term and number. g-a8 - g5" Date Jef a er, Ifffendant 210 Mech gi&PStreet caburg, PA 17055 f u. r.. , SEP 11j?kg KELLY H. BUSLERr Plaintiff vs. JEFFREY M. BUSLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA i : NO. 95-4825 CIVIL ACTION-LAW s s s IN DIVORCE OF AND lQlr this day of r 1998, upon consideration of the Plaintiff's Petition to Remove this Case from the Purge List and Reinstate Active Statue, a Rule is issued on Defendant, Jeffrey M. Busler, to show cause why the Petition filed on behalf of Plaintiff should not be granted. r WWI ? ?? BY THE OOURT, KELLY H. BUSLER, Plaintiff va. JEFFREY M. BUSLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-4825 CTVTt. AMT(W_r.ew : IN DIVORCE PETITION TO REMOVE CAM I" PURGE LIST AND REIEWMTE ACTIVE BMW Petitioner, Kelly H. Buller, by her attorney, Dawn S. Sunday, Esquire, files this Petition to remove this case from the purge list, and in support thereof states the following: 1. Petitioner is Kelly H. Buller, who currently resides at 210 W. Main Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent is Jeffrey M. Buller, who currently resides at 318 Boaler Avenue, Lemoyne, Cumberland County, Pennsylvania. 3. Petitioner is the Plaintiff in this divorce action, which was initiated by Complaint on September 8, 1995. Respondent, Jeffrey M. Buller, accepted service of the Complaint on September 28, 1995. 4. Respondent has retained representation in this matter by Robert C. Saidis, Esquire. 5. The undersigned counsel and Respondent's counsel began preliminary negotiations on an equitable distribution of the parties' assets and liabilities soon after the filing of the Divorce Complaint. Thereafter, for financial and personal reasons, the parties have continued the negotiations between themselves. 6. To the date of filing of this Petition, the parties have continued to negotiate between themselves concerning a distribution of their assets incident to the divorce and have accomplished a division of a portion of their assets. 7. Petitioner wishes to pursue these divorce proceedings to obtain a Decree in Divorce. Petitioner believes the parties will be able to resolve the property issues by agreement which will be reflected in a written Marital Settlement Agreement. 8. Petitioner believes that the slow progress of the proceedings in this case has been appropriate to the parties' personal and family considerations and that the Respondent has in no way been prejudiced by Petitioner's decision not to force the entry of a Divorce Decree Prior to this time. a"* from ?M, Petitioner requests that the the purge list and reinstate this cam active Court ?t:ttiiai divorce t p May Proceed to finalize resolution of the ammic issue and Neapectfully Submitted, Dawn 9u re ID #41954 sy, 3 9 Neat Main Street - Ste. #1 "Od (7n7?2 PA 17055-6230 I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Ap DATE LLY H. U LER, PLAINTIFF ?(1 V: 1 • 1 D ?•' ?' IU 1?1 I? ?1 ' ' li I C! ii' GJ OCT 1310 KELLY H. BUSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA va. NO. 95-4825 CIVIL ACTION-LAW s JEFFREY M. BUSLER, Defendant IN DIVORCE ORDER OF COURT AND NOM, this -Z %I t day of 0 Ll to b&-r 1998# upon consideration of Plaintiff's Motion, it is hereby ordered that the Rule, which was issued on Defendant in the above-captioned matter on September 16, 1998, to show cause why Plaintiff's Petition to Remove this Case from the Purge List and Reinstate Active Statue should not be granted, in made absolute, Plaintiffs Petition is granted, and this case is removed from the purge list and reinstated in active status. cc: Dawn S. Sunday, Esquire - Counsel for Plaintiff /,) • J r • 9 P Robert C. Saidis, Esquire - Counsel for Defendant y nl;:Wlv Ul"UV6 a JJ ?,r?i:??Ua1IJ BY THE COURT, KELLY H. BUSLER, Plaintiff Vs. JEFFREY M. BUSLER, Defendant t IN THE COURT OF COMMON PLEAS OF s CUMBERLAND COUNTY, PENNSYLVANIA t i No. 95-4825 CIVIL ACTION-LAW s s s IN DIVORCE RAM MIS W=CN To MAKE RULE To SNOB cum ADS== Kelly H. Buller, by her undersigned counsel, respectfully moves this Court to make absolute the Rule to Show Cause which was issued in the above-captioned matter on September 16, 1998, and in support states the following: 1. Plaintiff, Kelly H. Busler, Case from the Purge List September 10, 1998. filed a Petition to Remove this and Reinstate Active Status on 2. Jeffreey?r Bu16, 1998, this ller, to show Court cause issued Plaintiff's Pettition should not be granted, returnable fifteen (15) days from service. 3. On September 21, 1998, counsel for Kelly H. Buller served a copy of the Rule at counsel for Jeffrey M. Buller by regular mail. The Certificate of Service is attached as Exhibit A. 4. indicated Defendant's Rather than answer Plaintiff's Petition# Defendant's counsel in an active statue by letter dated September 22, 1998, a true and correct copy of which is attached as Exhibit B. fiHIPWORE, Kelly H. Buller requests that this Court make the Rule to show Cause absolute and grant the Petition to Remove this case from the Purge List and Reinstate Active Status. 1 u..-dr- Dawn S. Sunday, Esau re v Attorney for Plaintiff Kelly H. Buller ID #41954 39 West main street - Ste. #1 Mechanicsburg, PA 17055-6230 (717) 766-9622 KELLY H. BUSLER, s IN THE COURT OF COMMON PLEAS OF Plaintiff s CUMBERLAND 00UN7Ye PENNSYLVANIA i vs. s NO. 95-4825 CIVIL ACTION-LAW s JEFFREY M. BUSLER, s Defendant s IN DIVORCE CMIFICATB OF SERVICB I certify that I served a true and correct copy of the Petition to Remove this case fran the Purge Lint and Reinstate Active Statue, and the Order of Court issuing a Rule thereon in the above-captioned matter on the Defendant, Jeffrey M. Bueler, on a? I /99.P by First Class Mail, postage pre-paid, to Defendant's attorney, Robert C. Saidis, Esquire at the following address: Saidis, Guido, Shuff and Masland 26 West High Street P. O. Box 560 Carlisle, PA 17013 The statements made in the certification are subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. ????,.?? Dam m 8. sun ay, Laqu CJ &Yh- 4 Low Offices SAIDIS, SHUFF & MASLAND A Palll I111 It IN At. I-i*14MAI ION Sliko John it 26 well 111811 Slreel r Poll Ofllec 11111t 500 21114 Market Sweet . Itttben C. Soldis Carlisle, Pennsylvania 17011.2956 camp 11111.1'A 17011 efennrey S. Shulf Telephone: (717) 241.6222 r Focshnlle: (717) 241-64116 TelelduNre: (717) 771.7405 07 Albert 11, Masland I!mulL s8sm?dcznnlhtc.cam Fausimile: (717) 771.74 bhnna J. Ddly Itichord 1'. Mlslilsky 1 James 8. Reid. Jr. Keply'Ib CarlWe Scull 1), klo(lrc Karl M.I.edehoh'n September 22, 1998 Mark W, Allshnuse Dawn S. Sundayt Esquire 39 West Main Street 17055 Mechanicsburg, Rel Busier V. Busier No. 95-4625 Dear Dawnt 1 have received have no objection tto this case being cont nued inman Active Status• Very truly yours, /SAI , HUFF & MASLAND f Ro ert C. Saidis RCS/rlm cc: Jeffrey Busier P i 11'nllrfed ma Cis it I,W Adracalr Up IIK Holland Iland 0 1ital Adracoor A I'rnnrylunl® sq,rmr road kwdilyd Arracr I ) it, I'. I bJ uiI., t?'t cry' _ - C-k P C 0 KELLY H. BUSLER, plaintiff Va. JEFFREY M. BUSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-4825 CIVIL. ACTION - LAW IN DIVORCE 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 upon filing of Affidavits of Consent without notice. 2. 1 understand that I may lose rights concerning alimony, division of properly, lawyer's fees or expenses if I do not claim them before a divorce Is granted. 3. 1 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 alter it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date i 1 Ci 1 '? i ?? "rl[I Curtis R. Long Prothonotary office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor (?..5'- 'ygo25 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND'RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573