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LORETTA VAN TASS~:J.L. IN TilE COURT OF Cmll-tON rU:AS OF
Plaintiff CUl-ml~RLANIJ COUNTY, PENNSYLVANIA
NO. 95-5044 CIVIL TERM
CIVIl. ACTION - DIVORCE
vs.
ROBERT E. VAN TASSELL. 111. IN DIVORCE
Defendant
PRAECIPE TO TRfu~SMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court
for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 330.1 ,(c),
~~XxllX of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the complaint: U.S. MAIL CERTIFIED.
RETURN R.,~IPT REOUESTED MAILED ON SEPTEMBER 22. 1995. Received bv Defendant 10-5-95.
3. (Complete either paragraph (a) or (b) .)
(a) Date of execution of the affidavit of consent required by Section
336!(c) of the Divorce Code: by the plaintiff
January 19, 1996
by defendant JRnllArV 23.. 1996
(b) (1) Date of execution of the plaintiff's affidavit required by
.
,
Section 3301:d) of the Divorce Code: Nt A
(2) Date of service of the plaintiff's affidavit upon the defendant:
NtA
4. Related claims pending:Nn prnnnmfr rl~fmQ p~n~fng
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.
WAIVED BY PARTIES
.
'Ie,.lf.d': Ii / .f (., ~
Attorney for (Pl/l.~t1frr '.
_'(~..r tA-C.)
.. ..~
LORETTA VAN TASSELL,
IN 1'11~; COURT OF COMMON PLEAS OF
NO. 95 - lo'I'f CIVIL TERM
Plaintiff
V.
CIVIL ACTION - LAW
ROBERT E. VAN TASSELL, Ill,
Defendant
IN DIVORCE
NonCE TO DEFEND AND CI.AJH 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 in 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 tho marriage, you may request marriage counseling. A list of marriage counsellors
is available in the Office of the Prothonotary. Cumberland County Courthouse, Carlish'.
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' FEES
OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAH!
ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR:LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, CO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
::umberland County COl.rthouse
Carlisle, Pennsylvania 11013
(717) 240-6200
LORETTA VAN TASSELL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
NO. 95 \0 "'1 CIVIL TERM
V.
CIVIL ACTION - LAW
ROBERT E. VAN TASSELL. III,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
1. The Plaintiff, LORETTA VAN TASSELL. currently reaides at 7 Kingswood
Drive. Hechanicsburg, Cumberland County, Pennsylvania, since November of 1993.
2. The Defendant, ROBERT E. VAN TASSELL, III, currently resides at
8230 S.W. 6th Court. North Lauderdale. Florida 33068, since September of 1994.
3. The Plaintiff has been a bona fide resident in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married June 27, 1981 in Carmel, New
York.
5. There have been no prior actions of divorce or for annulment between
the parties.
6. Plaintiff avers that there are no children born of this marriage.
7. Neither the Plaintiff or Defendant are members of the United States
Armed Services.
8. Plaintiff has been advised of the availability of marital counseling
and that each may have the right to request that the Court require the parties to
participate in counseling.
9. Plaintiff avers that the marriage is irretrievably broken pursuant to
Section 3301(c) of the Pennsylvania Divorce Code Act 23.
-2-
.
,
WHEREFORE, PLaintiff requests your Honorable Court to enter a Decree
of Divorce from the bonds of matrimony.
jJ(/lut,l~ () ~A
William A. Yocum, ~ re
Attorney for the Plaintiff
3001 Market Street
Camp Hill, PA 17011
VERIFICATION
I, LORETTA VAN TASSELL, hereby verify that the facts set forth in the
foregoing Complaint are true and correct to the best of my knowledge, information
and belief and understand that false statements made herein are subject to the
penalties of PA C.S. 14904,
relating to unsworn falsification.
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0< -<"."Lillt...
Loretta Van
l/ O/'I/O.A~~ilj
Tassell
Dates: ~PfilJ.../;h 2~/Jj1 C'
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LORETTA VAN TASSELL,
Plaintiff
IN THE COURT OR COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO 95-5044 CIVIL TERM
ROBERT E. VAN TASSELL, III,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATION OF SERVICE
I, WILLIAM A. YOCUM, Attorney for the Plaintiff, do hereby certify to the
service of a true and correct copy of the Plaintiff's Complaint in Divorce which
was deposited in the United States Mail, certified, return receipt requested on
September 22, 1995 and received by the Defendant on October 5, 1995.
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'ROBERT E. VANTASSELL, III ~. SInlcITYIlI
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i 'KOBERT E. VANTASSELL, III
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LORETTA VAN TASSELL
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
95-5044 CIVI J. TERM
VS.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT E. VAN TASSELL, III
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce
Code was filed on September 21, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed [rom 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.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(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 riRhts concerninR 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. S4904 relating to unsworn falsification to authorities.
Date:
I ~:J-7:> -9 t
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,~1..l1'f Defendant
LORETTA VAN TASS ELL
Plaintiff
Vs.
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 95-5044 CIVIL TERM
CIVIL ACTION - DIVORCE
ROBERT E. VAN TASSELL, III
Defendant
AFFIDAVIT OF CONSENT
1. A
Code was filed on
complaint in divorce under Section 3301(c) of the Divorce
Seotember 21. 1995
Date
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the Complaint.
3. I consent to the entry of n 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
13301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without
notice.
2.
of property.
is granted.
I understand that I may lose rights concerning alimony, division
lawyer's fees or expenses if I do not claim them before a divorce
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 snd correct.
I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. 54904 relating to unsworn falsification to authorities.
Date: ) /11 "h If I '>, I'i IJ ?
oI:v~~ l)(J"7;;.",,,,(J(J
Plaintiff Ill. f~..d....~
IN THE COURT OF COMMON PI.F-AS m' CUMBERI.AND COUNTY. P~;NNSYI.vANIA
CIVil. ACTION - LAW
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File No.
vs.
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IN DIVORCE
:
RcJ.'o~t C \Jcll'\lA...L\pI\~:
Defendant :
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
~_ day of~ . 19_~. hereby elects to resume the
prior surname of (hID\ii\R \) LOR-wd . and gives
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this written notice pursuant to the provisions of 54 P.S. S 704.
DATE:
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Signature
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\-X/n>!Aiii. C~-vtn/jAr
Signature of name being resumed
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
On the ~Otf~ day of'i.'....A... . 19~. before me. a
Notary Public. personally appe~ 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.
1\ /\
AJcrn.YLA L,n i[in:)
Notary publ ic
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