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HomeMy WebLinkAbout95-06643 1 ',-:, 'j:; -> , .:'~ . ~;"i,'~ '!J~ti~!:i\~'{i ~!t ';''!.::';; ':~.,ji~ ':~'-:::;,\ ., .', "" ;, ~ -, '1.', " .~~ . ., t'- , , " . ,,-;P ,-~ , ""'." ~' p! j t.' ,'" "r, " , ('() -::r- " .." :' :,"f 1 , ;. H;, ~ .":1,- t_, .-.:"'.-..>! .';:.'.";-' l.{) 0- "-',. :">:. ". .:..' '^< , " <."," .,,;" ~t. ^ "..,- .. .. . .'.... __~...:~..w-::..t_ __:~...::<<<:_:_:..., ....:K~>**'_AlDOOICC_:_OOIlC~ . - -- l. . -. . ~ . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY . ~ * . . . . STATE OF ",' : PENNA. ! . . . . !,' ,..,."S~.LJ!:,~...L,!..,I?,~~,~~~"....,.....,..........,.................... \,1 !. '" N II, ...9.~,7,~~,~,L.. ................, 19 ~ . ,..........fl'!lJ~~JJL~~~~;;~..........,.......................... II ~ . DA,V.IP..A."..1?~!.~~~L.................,......,..,.......... II .. 8 ..DeJe,n.~!\n.L......., ...............,....... 1\ . 8 ~ A ~ 8 ~ 8 DECREE IN .. . . : DIVORCE ~ , .l~ ~ 8 ,~ .. ~ AND NOW, ....' . ... .~.l.. .. .... .. 19. ~H;I" it is ordered and ~ ~ decreed that .... ,4!l1JI,.J;:,( ,I,., ,I)JHI-Jl..P,t... .... ..,............,.. .., plaintiff, ~ ~ ~ ~ and.",.. p~y~p, ~'" p~~~~!t",."""""", "".""""",", defendant, ~ ~ are divorced from the bonds of matrimony. ~ 8 ~ . 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 e ~ been entered; $ : " ,. , ., ~~M.,. "., '" " " ". , ,. " , ,., " " " ", '~''1'''''''' ,'" "..", ........,., " ,'.............................,.., ..'/................. . / I ________ -.._________....___ ~_..._.___~_~...._~ j ii. )~_~__~____-___~~_e_-- \ I'l.. ., ," '"', $ ~ ~ ~ M ..' ~ ~ ~ ---~~ ,...:- .z. ~. .>>:. . ," ~ ~ ',' ~ ',' ~ ',' *. ',' J, ~ " ~ ',' w " ~ ., .3'dJ'~ W ~?)" ~ z. 4 ~"'-~'/"'1' J '.;o1~ 114 J",a:4/ ~ ~. .. .. . . , 'J .. 3301 (c) of the Divorce Code: by Plaintiff February 28, 1996 ; by - .. . - . IN THE COURT O~'COMMON PLEAS : CUMBERLAND COUNTY , PENNSYLVANIA NO. 95-6643 CIVIL TERM ASHLEY L. DEIMLER, Plaintiff v. CIVIL ACTION- LAW DIVORCE DAVID A. DEIMLER, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for antry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section ex) 3301 (c) ( ) 3301 (d) (1) of the Divorce Code. (check applicable aection). 2. Date and manner of service of the complaint: 11/22/95 Certified Mail 3. ,Complete either paragraph: (a) or (b). (a) Date of execution of the affidavit of consent required by Section Defendant February 28, 1996 (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: ; (2) date of service of the Plaintiff's affidavit upon the Defendant: 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached N/A " ~",~ orney f (X) Plai f ( ) Defendant .. . -- ~ . ..,.....-.-.l:.,.. .A ....:.-..:.:..t,.......-- . .---.. ~- ... .t. . ASHLEY L, DEIHLER. plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. tJ6. ~~'13 ewJ~.... CIVIL ACTION - LAW DIVORCE VB. DAVID A. DUMLER. Defendant .'. 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 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, Cumberland county Courhouse, 1 Courthouse square, Carlisle, 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. I~ 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 Cumberland county Courthouse 4th Floor, Cumberland county Courthouse 1 Courthouse Square carlisle, PA 17013 (717) 240-6200 ~ ~ . ASHLEY L. DEIMLER, IN THE COURT OF COMMON PLEAS plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . , v. . NO. . . . DAVID A. DEIMLER, . CIVIL ACTION - LAW . Defendant . DIVORCE . COMPLAINT IN DIVORCE COUNT NO. 1 1. The plaintiff is Ashley L. Deimler, an adult individual who currently resides at 404 A Hummel Avenue, Lemoyne, Cumberland county, pennsylvania. 2. The Defendant is David A. Deimler, an adult individual who currently resides at 128 Pathfinder Drive, Middletown, Dauphin County, Pennsylvania. 3. plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The plaintiff and Defendant are both citizens of the United States of America. 5. The Defendant is not a member of the Armed services of the United states or any of its allies. 6. The plaintiff and Defendant were married on April 20, 1991, in Dauphin county, Pennsylvania, 7. There have been no prior actions of divorce or annulment between the parties. 8, The marriage is irretrievably broken. ~':<.i', C'.""'-'''' :'f-.-' ;:.-;'-'.,-,'..V' ,,'~L'-,. -;~:.' ';-_~:.\' ~ ... 9. plaintiff has been advised of the availability of counselinq and that the plaintiff may have the riqht to request that the Court require the parties to participate in counselinq. 10. plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, the Plaintiff requests the Court to enter a Decree dissolvinq the marriaqe between plaintiff and Defendant. Dated: II),/f.f , PANNEBAKER AND JONES, P.C. Attorneys for plaintiff By: ~//-C"'~ PetEif' R~r, tpr, Esquire I,D. #44873 4000 Vine street Middletown, PA 17057 Telephone: (717) 944-1333 . . YERIFICATION I verifY that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.B 4904, relating to unsworn falsification to authorities. PRH:jmp AD-COMP #14487 . . ASHLEY L. DEIMLER, Plaintitt IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6643 CIVIL TERM . . . . . . . . . . . . . . CIVIL ACTION - LAW DIVORCE v. DAVID A. DEIMLER, Defendant .ROO~ O~ SlaVICB BY ClaTI~IBD HAIL Peter R. Henninger, Jr., Esquire, of the law firm of pannebaker and Jones, P.C., being duly sworn according to law, deposes and says that he did serve a copy of the complaint in Divorce in the above- captioned matter, filed on behalf of Ashley L. Deimler to the above term and number on David A. Deimler, by mailing a copy of said Complaint in Divorce by Certified Mail, Return Receipt Requested, to the last known address, that being: 128 Pathfinder Drive, Middletown, PA 17057. The original Return Receipt, as well as the receipt for Certified Mail No. Z 332 169 865 are attached evidencing the delivery of the above referred Complaint in Divorce, PANNEBAKER & JONES, P.C, Attorneys for Plaintiff Date: /';>/6 By N-h' II lU/~ p!~1~~i~inger,- Jr., Esquire I,D. #44873 4000 Vine Street Middletown, PA 17057-3596 Telephone: (717) 944-1333 , 1995. ~ " S~ORN and sUbscr~~d to befoll8 me this" day of ..!lLtU\l. .~t. , 1995, L~i 111~ (,7""" Notary Public PRH:jmp AD-PROOF #l4487 NOTARIAL SEAL JODIE M.l1. PIERCE, Notnry Public r.\l~j-j'~'c.'t:n. O.,'J;J!':fl Coun1y , f' .' \. !~"h >"', H . , . Z 332 tb'l I!!b5 ~ Receipt for Certified Mall . No Inlur.ne. Cov.rag. Provided __ Do nal UN far Inlllnlllanll Mill ISII RIYI'III I hntlO .. DAVID A. DEIHLER I :'!~!..~~~~NDER DR. sf MIDDLETOWN PA I ,...... 1 $ I, ,Cerlll.d'H !: i DelM'f~ fM ....UiCIItdDelldfy'n , 1.10 ASHLEY L. DEIMLER, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. . NO. 95-6643 CIVIL TERM . . . DAVID A. DEIMLER, . CIVIL ACTION - LAW . Defendant I DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301(c) of the Divorce Code was filed on November 21, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. Date: .;}./d. '6/9(, 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 l8 Pa. C.S. 54904 relating to unsworn falsification to authorities. ASHLEY L. DEIMLER, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6643 CIVIL TERM CIVIL ACTION - LAW DIVORCE v. DAVID A. DEIMLER, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(cl OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in 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. 54904 relating to unsworn falsification to authorities, Date: ~JG1-'l lifi , ASHLEY L. DEIMLER, plaintiff I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 95-6643 CIVIL TERM v. . . DAVID A. DEIMLER, Defendant CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301(C) of the Divorce Code was filed on November 21, 1995, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final Decree in 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. 54904 relating to unsworn falsification to authorities~ Date::J~ fie, Qlo PRH:jmp AD-CONS #14487 ASHLEY L. DEIMLER, I IN THE COURT OF COMMON PLEAS plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 95-6643 CIVIL TERM . . DAVID A. DEIMLER, . CIVIL ACTION - LAW . Defendant . DIVORCE . WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c\ OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in 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. 54904 relating to unsworn falsification to authorities. Date:~ PRH: jmp AD-WAIV #14487 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-6643 CIVIli! TEBM 8 ~; -- ":\ CIVIL ACTION -@,W_:.; ~.g DIVORCE ,'~; , I Y C'';''.' "(""I 1.11 -, ..q ..., .~;:) :. ',,' . ~;\1 , . , , . ... ASHLEY L. DBIMLER, I Plaintiff I I v. I . . DAVID A. DEIMLER, . . Defendant . . , '. ,. WAIVER OF NOTICE OF INTENTION ~~__R_EOUEST , , ENTRY OF A DIVORCE DECREE UND~E ;... I ~3301(c' OF THE DIVORCE CODE :.: t.? '-" " -, -<. (\ 1. I consent to the entry of a final Decree in 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. 54904 relating to unsworn falsification to authorities. Date: ~b.o/q(4 ..- . . :q '-. ASHLEY L. DEIMLER, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA , '", v. NO. 95-6643 CIVI~TERM . ,.." ,II"';'; "'1 )t-:-; ':ro.. :;1 }~.) ~ ,'1' 1 .! u, DAVID A. DEIMLER, Defendant CIVIL ACTION - LAW DIVORCE , ~ : . :' ) I Go WAIVER_~! N,?TICE OF INTENTION TO REOUEST . ENTRY QF A DIVORCE DECREE UNDER ~3301(C\ OF THE DIVORCE CODE .. ~. ":.' '-" (---.. , 1. I consent to the entry of a final Decree in 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. 54904 relating to unsworn falsification to authorities~ Date~f\ f&~ ctlo PRH:jmp AD-WAIV 114487