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JOHN F. MOBSLBIN,
Plaintiff
IN THB COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 15- "'t,O~ CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
v.
SUSAN B. MOESLEIN,
Defendant
NOTICB TO DBPEND 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.
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 the County Courthouse, , Pennsylvania .
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.
v.
IN THB COURT OF COMMON PLBAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
NO. CIVIL TBRM
CIVIL ACTION - LAW
IN DIVORCB
JOHN F. MOBSLBIN,
Plaintiff
SUSAN B. MOBSLBIN,
Defendant
COMPLAINT UNDBR SBCTION 3301(cl OR 3301(dl
OF TBB DIVORCB CODB
1. Plaintiff is John F. Moeslein, who currently resides at
1918 Logan Street, Apartment B, Camp Hill, Cumberland County,
Pennsylvania, since September of 1987.
2. Defendant is Susan B. Moeslein, who currently resides at
1918 Logan Street, Apartment B, Camp Hill, Cumberland County,
Pennsylvania, since September of 1987.
3. Plaintiff and Defendant have been bona fide residents in
the Commonwealth for at least six months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 2, 1990
at Harrisburg, Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the Court to enter a Decree of Divorce.
Respectfully submitted,
CLBCmBR Am) JrBARBN
By
Denn s J. S 0
31 North Second Stre t
Harrisburg PA 17101
(717) 238-1731
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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. Section 4904 relating to
unsworn falsification to authorities.
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~JOHN F. MOBSLEIN
In
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I IN THB COURT OF COMMON PLEAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
No. 95-6605 CIVIL TBRM
CIVIL ACTION-LAW
IN DIVORCB
JOHN F. MOBSLBIN,
Plaintiff
SUSAN B. MOBSLEIN,
Defendant
AFFIDAVIT OF SERVICE
I, DBNNIS J. SHATTO, BSQUIRE, do hereby certify that a true
and correct copy of Complaint in Divorce wa3 served upon the
Defendant, SUSAN E. MOESLBIN, by certified mail, restricted
delivery, return receipt requested, on the 7th day of December,
1995. The original signed return receipt, number P 492 632 160, is
attached hereto and made a part hereof.
Respectfully submitted,
31 North Second Street
Harrisburg, PA 17101
(717) 238-1731
Date: 11"'~S
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IN THB COURT OF COMMON PLBAS OF
CUMBBRLAND COUNTY, PBNNSYLVANIA
NO. 95-6605 CIVIL
IN DIVORCB
JOHN F. MOBSLBIN,
Plaintiff
SUSAN B. MOBSLBIN,
Defendant
APPIDAVIT OV CORSBHT
1. A complaint in divorce under Section 3301 (cl of the
Divorce Code was filed on November 20, 1995.
2. The marriage of plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing of 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.
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. 5 4904 relating to unsworn
falsification to authorities.
Date:
Iv.,'J/- qi'
, 1998
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J HN F. MOBSLBIN - Plaintiff
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JOliN F, MOESLEIN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6605 CIVIL
v.
,
SUSAN E. MOESLEIN,
Defendant
IN DIVORCE
WAIVER OF NOTICE or INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SBCTION 3301lcl OF THE DIVORCB 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 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. ~ 4904 relating to unsworn
falsification to authorities.
IfrU-qf'
, 1998
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JOHN F. MOESLEIN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PBNNSYLVMlIA
NO. 95-6605 CIVIL
IN DIVORCE
v.
SUSAN E. MOESLEIN,
Defendant
API'IDAVIT 01' CONSBHT
1. A complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on November 20, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing of 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.
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.
Date:
If) IJ '
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dAJ
SUSAN E.
c;?LL- (
MOESLEIN - Defendant
, 1998
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JOHN F. MOESLEIN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-6605 CIVIL
IN DIVORCE
v.
SUSAN B. MOBSLBIN,
Defendant
WAIVBJl OP NOTICR OP nll:ulTION TO DQUBST
BNTRY OP A DIVORCR DRCDR UNDRR
SRCTION 33011c) OP TBB DIVORCB CODR
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 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. S 4904 relating to unsworn
falsification to authorities.
Date:
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SUSAN B. MOBSLBIN, Defendant
, 1998
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(I't.Ist be typewritten lII'ld sutmitted in mlpH,."te)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within lIlIltter far the llBICt ArgIJnent court.
--------------------------------------------------------------------------------~~
CAPTION OF CASE
(entire ClIption IlII8t be stated in full)
KAREN H. EARLY,
I PlaintiJ!f)
VB.
DONNA and DOUGLAS HEFENFINGER
(Defendant)
No. 7176
Civil Action
1995
1. State matter to be argued (i.e.. plaintiJ!f's nDtion far new trial. defendant's
denurrer to ccrrplaint, etc.):
Defendants' Preliminary Objections
2. Identify CXlUIISel who wllJ. argue case:
Dl!ted: October 26, 1998
(a) far plaintiJ!f:
J\ddress:
Charles O. Barto, Jr., Esquire
608 North Third Rtreet
Harrisbur~, PA 17101
(b) far defendant:
Address:
RORer R. Lag,una, Jr., Esquire
32 South Bedford Street
Carlisle, PA 17013
3. I wllJ. notify all parties in writing within bID dlIys that this case has
been listed for argunent.
4. ArgIJnent court Dl!te:
December 9, 1998
Attorney farPlaintiff
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JOHN F. MOESLEIN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
SUSAN E. MOESLEIN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
95-6605 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of October, 2001, in the case
of John F. Moeslein versus Susan E. Moeslein at No. 95-6605 Civil
Term, a letter having been received from Dennis J. Shatto,
Esquire, on behalf of the Plaintiff requesting that the case be
kept open for a period of 6 months, the case will be stricken from
the purge list upon the condition that activity occur within the
next 6 months. In the event that no such activity occurs, the
case will be deemed dismissed and purged without further order of
court.
By the Court,
Dennis J. Shatto, Esquire
111 Locust Street
Harrisburg, PA 17101
For the Plaintiff
Susan E. Moeslein, Defendant Pro Se
1918 Logan St.
Apt. B
Camp Hill, PA 17011
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