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HomeMy WebLinkAbout95-05044 11 (1. j . .., - - ~ 1 ~ I " a 7 ~ J I I I I ~I ~I , ; i ::' I i " I 'l{) \ '0"; . , O~ ~: " 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. :./.) 0< -<"."Lillt... Loretta Van l/ O/'I/O.A~~ilj Tassell Dates: ~PfilJ.../;h 2~/Jj1 C' -3- '^ .... 'l ... J ~ e ~ e 'IIi !Ii Q .... ... ~ l!A .' f - r-.I ~ ~:: . ....z--' LuC'2::J_ UZOz -Oc.'>~ t::XQ'" 01-%-' I ;~.,"" t..'"lr':: ...Jv, \....tn.r.;e"Z'- =~t.~~~ ~;t.,;%''l- ..~ .....c::. <:> . . :c 0- ~ :I N - ~ g l:;~ ~~ ~ ... .. g ... II .:l~~ '04 ~~ ... ~ .. ~ :I ~ :5 p.,1I) ~ H II ~e~ H II g ~~EI . ... .-4 . III H ~p.,~ p., o-::lj:l j:l ~!ctill . &l o .>:J; ~ III ~~:jj II) ... C~!Z II) ~ I II ~ o I i . 0 ~ ~~s~ ~i ~. o E-o~ ~ . ! U U ... <CO ~ Iol > a ~ ~~~ IlI~O~1lI :3 i ... IlIUH . .' '. J 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. .) ,?"..,)l..Y /I} /iJ?~ ',. tJ V d/..4 ~ I;' (7t.., William A. YocUm _ - '1. ~ ~ I _If. _...;,., I ... wlIh 10 NCllIivI-. o ~ _ 3. ........ , ,...blQ IlINloee liar WI _ 10 _...._...~..,i-..--......- MI, retUm'd'lil ta"lfM YOU. .' O. . .._..._....._ ........., ...._._ 1. A_II. J 1.IAdchM ---, I. w.....__ ...........-..-- 2. O....lna~1lIIIwry g ~-..._.._._.._-_.....- CCIlIIllII Iar.... 1 3, Article AddrHNd 10: 411. ArtIcle....... I Z 324 521 144 'ROBERT E. VANTASSELL, III ~. SInlcITYIlI I 8230 S.W. 6th COUIlT 0"....., 0'..... . NORTH LAUDERDALE, n. 33068 1m CIl'IlfIed.q 0 COD , 0 ~ .,.. I! RMum ..... lot 7. D.. of e. IlId ... II Jllidl ~ J I J f ! I lOn/y If -"" J 'i 1 ""...- ._no DOMESnc RETURN RECEIPT Z 324 521 144 ~ Receipt for X Certified Mall _ No Insurance Coyer age Provided ~&:R 00 not use tor International Mall ISee Reverlll i 'KOBERT E. VANTASSELL, III ~ I I S"~"1 <I"'! \.. ~230 S.W. 6th COURT p" "'.I,.."",j!l~i_,~ ORTH LAUDERDALE 1'0\\"'1" '.....twctf.... ",11'<"" ;,..,.......,1.... '4,0".."".j 'N......... 't'>. 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 ~ ~l k:~~ '-' i - 1- /Jl-L. ,~ !-'''('-- ,~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 : . --Cl~~~ \J O~ \cJ~1 \ '-PlaintT(r : . . : <Jr. C I u. \ Tu.w-... \O'-ILj File No. vs. . . 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 - J this written notice pursuant to the provisions of 54 P.S. S 704. DATE: ;)/dO/q~ -) I A. '}/. 7'"1 cLoo 'f~ . ,,-", - / c...x:..ak.'J Signature ", \-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 r....' ~ ."-'..~ .~..., ~""'---"""~-'''''''',--''~- 1 "-, ----- , ": I