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HomeMy WebLinkAbout01-5611IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANINE RAMMEL PLAINTIFF V. BRYAN RAMMEL DEFENDANT NO. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Danine Rammel, being duly sworn according to law, deposes and says~ 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that mM spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that to the penalities of 18 Pa. C.S. unsworn falsification to authorities. false statements herein are made subject Section 4904, relating to Dar e: _~_-~_~_0__~ ....... 2001 IN TH~ COURT OF COMMON PLZAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANINE RAMMEL PLAINTIFF NO. V. BRYAN RAMMEL DEFENDANT CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DilQBQ~ AND NOW, this 1ST day of August 2001, comes the Plaintiff, Danine Rammel, by and through her attorney, Daniel Pollock, Esquire, and files the following Complaint in Divorce whereof the following is a statement: COUNT I : DIVORCE The Plaintiff, Danine Rammel, is an currently resides at 205 Geary avenue, Cumberland County, Pa. 17070. adult individual who Apt.1 New Cumberland, The Defendant, Bryan Rammel, is an adult individual who currently resides at The Harrisburg State Hospital Cameron Street Harrisburg, Dauphin County, Pennsylvania. 3. The Plaintiff and Defendant were married on April 1, 1993 and separated on or about Juno 1, 1998 The Plaintiff has beon a bona fido resident of the Commonwealth of Pennsylvania for at least the prior six (6) months immediately previous to the filing of this complaint. There have been no prior actions of divorce or annulments between the parties. The Plaintiff has been advised of the availability of counseling between the parties and the right to request the Court require both parties to participate in counseling. 7. Both the Plaintiff and the Defendant are sui Juris and are citizens of the United States. 8. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANINE RAMMEL PLAINTIFF V. BRYAN RAMMEL DEFENDANT CIVIL ACTION - L,AW IN DIVORCE 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 relief requested in these papers by the Plaintiff. You may lose money, Property, or other rights important to you. When the grounds 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 Prothonotyary's office in the Cumberland County Courthouse, 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 ASSISTANCE. LAWYER REFERRAL SERVICE Office of the Cumberland County Bar 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3186 Association IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANINE RAMMEL PLAINTIFF V. BRYAN RAMMEL DEFENDANT NO. CIVIL ACTION - [,AW IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Danine Rammel~ being duly sworn according to law, deposes and says: 1~ I have been advised of the availability of counseling and understand that I may request that require that my spouse and I participate in counseling. marriage the court 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that to the penalities of 18 Pa. C.S. unsworn falsification to authorities. false statements herein are made subject Section 4904, relating to Danine Ramme 1 DANINE RAMMEL PLAINTIFF BRYAN RAMMEL DEFENDANT IN TH~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION ~- LAW IN DIVORCE AND NOW, this 1ST day of August 2001, comes the Plaintiff, Danine Rammel, by and through her attorney, Daniel Pollock, Esquire, and files the following Complaint in Divorce whereof the following is a statement: COUNT I : DIVORCE The Plaintiff, Danine Rammel, is an currently resides at 205 Geary avenue, Cumberland County, Pa. 17070. adult individual who Apt.1 New Cumberland, The Defendant, Bryan Rammel, is an adult individual who currently resides at The Harrisburg State Hospital Cameron Street Harrisburg, Dauphin County, Pennsylvania. 3. The Plaintiff and Defendant were married on April 1, 1993 and separated on or about June 1, 1998 The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the prior six (6) months immediately previous to the filing of this complaint. There have been no prior actions of divorce or annulments between the parties. The Plaintiff has been advised of the availability of counseling between the parties and the right to request the Court require both parties to participate in counseling. Both the Plaintiff and the Defendant are sui Juris and are citizens of the United States. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. WHEREFORE, The Plaintiff requests this Honorable Court to enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between %he Plaintiff and the Defendant. Respectfully submitted, Daniel Pollock, Esq. Attorney for the Plaintiff Danine Rammel Daniel Pollock,Esq. 3105 Old Gettysburg Road Camp Hill, Pa. 17011 Super Ct. Id. 70315 (717) 737-7566 I verifM that the statements made in this complaint are true and correct to th~ b~t of my knowl~dg~ I understand that fai~ statements knowingly madR herein are subject to the pena]ties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities, Date DANINE RAMMEL PLAINTIFF BRYAN RAMMEL DEFENDANT IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY,PENNSYLVANIA NO. ~l - ~-(oll CIVIL TERM 1N DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Danine Rammel, Plaintiff, to proceed in forma pauperis. I, Daniel Pollock, Esq, Attorney for Ms. Rammel, proceeding in forma pauperis, certify that I believe that she is unable to pay the costs and that I am providing free legal services to Ms. Rammel. Ms. Rammel's affidavit showing her inability to pay the costs of litigation is attached hereto. Daniel Pollock, Esq. Attorney for Danine Rammel Plaintiff Daniel Pollock, Esq. 3105 Old Gettysburg Road Camp Hill, Pa. 17011 Pa. Super. Ct. Id. 70315 (717) 737-7566 DAN1NE RAMMEL PLAINTIFF BRYAN RAMMEL DEFENDANT IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY,PENNSYLVANIA NO. CIVIL TERM IN DIVORCE AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiffin the above captioned matter and becqause of my financial condition I am unable to pay the fees and costs of prosecuting this action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Danine Rammel Address: 205 Geaty Street 1st floor, New Cumberland, Pa. 17070 (b) Social Security Number: 179-48-4545 I am presently unemployed having last worked at Burger King in New Cumberland, doing customer service work, on April 24, 2001 for $7 per hour and working approximately 35 hours per week. (c) Other Income I recieved over the past 12 months is as follows: Business or profession: 0 other self employment: 0 Interest: 0 dividends: 0 pension and annunities: 0 social security benefits: $557/Mo. starting 5/1/01(S.S.D.) support payments: 0 Disability payments: 0 other than what is listed above under social security. Unemployment compensation: 0 Supplemental Benefits: 0 Workman's Compensation: 0 Public Assistance: 0 Other: 0 (d) There are no other contributions to my household support, fi.om either my estranged husband, or my children. (e) Property Owned Cash: 0 Checking account: 0 Savings account :0 Certificates of Deposit: 0 Real Estate: None Motor Vehicle: None Stocks and Bonds: None Other: none (f) Debts and obligations Mortgage: 0 Rent: $450/Mo. Loans: 0 Other expenses: Phone, Gas and electric total approximately $100/MO. (g) Persons Dependent upon for support: none currently 4. I understand that I have a continuing obligation to inform the Court of improvement of my finanicial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made herein are true and correct to the best of my knowledge. I understand that false statements made herein are made subject to the penalities of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Danine Rammel IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Danine P.~mmel : PLAINTIFF V. : Bryan R~mmel DEFENDANT : NO. 01-5611 CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DEGREE To Bryan Rammel, Defendant. You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraff~av~t to the plaintiff's affidavit. Therefore, on or after I~%/1~ , 2002 The Plaintiff can and will request the cou'rt to enter a final decree of divorce. If you do not file with the prothonotary of this Court an answer withy your signature notorized or verified or a counteraffidavit by the above date, The court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the date stated above, or the court may grant the divorce and you may lose your right to ask for economic relief. A COUNTER AFFIDAVIT WHICH YOU MAY FILE WITH THIS COURT IS ATTACHED TO THIS NOITICE. YOU MAY 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 GAN SEEK LEGAL HELP. Court Administrator's Office Cumberland County Courthouse Third Floor Rear Carlisle, Pa. 17013 (717) 240-6200 IN THE COURT OF COI~fON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Dantne l~mmel : PLAINTIFF NO. 01-5611 : Bryan Rammel DEFENDANT : CIVIL ACTION - LAW IN DIVORCE WAIVER OF THE NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DEGREE UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. I consent to the entrF of a final decree of divorce without notice. 2. I understand that I may lose rights concernin~ alimony, division of property, la~-/er's fees or expenses if I do not claim them before a divorce is ~ranted. 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. A. I understand that all marital property has been divided between the Defendant and myself according to agreement. 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: Danine Rammel Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Danine P~el : PLAINTIFF NO. 01-5611 : BrFan Rammel DEFENDANT : CIVIL ACTION - LAW IN DIVORCE WAIVER OF THE NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. I consent to the entrF of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of propertF, laser'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 prothonotarF. 4. I understand that all marital property has been divided between the plaintiff and myself according to agreement. 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: BrFan Rammel Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Danine ~mmel : PLAINTIFF NO. 01-5611 Bryan P~mme 1 DEFENDANT : CIVIL ACTION - LAW IN DIVORCE Affidavit under Section 3301 (d) of the DIVORCE CODE 1. The Parties to this action separated on or about July 30, 1998 and have continued to live separate and apart for a period of at least two years. 2. The Marriage is irretrievably broken. 3. 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. 4 All issues concerning the division of property, Alimony, and the responsibility of Lawyers fees have been agreed to by the parties 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. Defendant IN THE COURT OF COLSON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANINE HAM~EL : PLAINTIFF NO. 01- 5811 BRYAN RAI~dEL DEFENDANT : CIVIL ACTION - LAW IN DIVORCE Affidavit under Section 3301 (d) of the DIVORCE CODE 1. The Parties to this action separated on or about July 30, 1998 and have continued to live separate and apart for a period of at least two years. 2. The Marriage is irretrievably broken. 3. 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. 4 All issues concerning the division of property, Alimony, and the responsibility of Lawyers fees have been agreed to by the parties Date: 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. Danine Hammel Plaintiff IN TIlE COURT OF COItiON PLEAS OF CUHBERLAND COUNTY, PENNSYL VAN I A Danine ~el : PLAINTIFF NO. 01-5611 : Bryan DEFENDANT : CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE To BrFan ~mmel : Danine Rsmmel intends to file with the court the attached Praecipe to Transmit Record on or after ~2~ ~ 2002 requesting that a final decree in divorce be entered: aniel Pollock, Esq. Attorney for the Plaintiff, Danine Rammel IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Danine Rammel : PLAINTIFF NO.0! -5611 : Vo Bryan Rammel DEFENDANT : CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. Check either (a) or (b) ~/~a. I do not oppose the entry of divorce ___b. I oppose the entry for divorce for the reaons checked off below Non- 1. The parties have lived separate and apart for at least ~wo years ~ of 18 Pa. C.S. authorities. DATE 2. The Marriage is not irretrieably Broken 2-1/~eck either a or b __4~_a. I do not wish to make any claims for economic relief. I understand that I may lose rights concerning Alimony, division of property, Lawyer's fees or expenses, or other important rights. ..... b. I wish to make a claim for economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counteraffidavit are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalities 4904 regarding unsworn falsification to Bryan Rammel NOTICE: If you do not wish to contest the entry of a divorce decree nor make any claim for economic relief you need not file this counteraffidavit. ' IN THE COURT OF COMMON PLEAS OF The NINTH JUDICIAL DISTRICT OF PENNSYLVANIA Danine ~mmel : PLAINTIFF : V. : Bryan ~mmel DEFENDANT : NO. 2001- ~'~)~ CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. The ground for divorce: SECTION 3301 (C) OF THE DIVORCE CODE x. SECTION 3301 (D) OF THE DIVORCE CODE 2. (a). (b). (c). Date Complaint filed: September 27,2001 Date of service of the complaint: February 8,2002 Manner of service of the complaint: __x__.Certified mail, restricted delivery to and return reciept signed by defendant's agent. .First Class mail- not returned, certified mail refused, 15 days have elapsed. Date of mailing: Date certified mailing refused: Personal service by sheriff and /or deputy sheriff .Personal service by competent adult other than sheriff(Affidavit attached) Acceptance of service(Copy attached) .By publication pursuant to Order of Court (Copy of Order attached) 3. (a). Affidavit of Consent required by Section 3301(c) of the Divorce Code. Date of execution: Plaintiff April 30,2002 Defendant May 3, 2002 Date of Filing: Plaintiff May 23, 2002 Defendant May 23, 2002 (b) Plaintiff's affidavit required by Sectiion 3301(d) of the Divorce Code: Date of execution:April 30,2002 Date of Filing: May 23, 2002 Date of Service upon defendant: April 30, 2002 Manner of service:Personal 4. Related claims pending: None: all issues of property have been resolved between the parties. 5. (a). Date of service of the notice to intention to file praecipe to transmit, a copy of which is attached: April 2002_ 30, Manner of service: Personal (b). Date waiver of notice to file praecipe to transmit was filed with the Prothonotary: May 23, 2002 By Plaintiff: April 30, 2002 By Defendant: May 3, 2002 I verify that the statements made within this praecipe are true and correct. I understand that false statements made herein are made subject to the penalities of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date Daniel Pollock, Esq. Attorney for the plaintiff Daniel Pollock 3105 Old Gettysburg Road Camp Hill, Pennsylvania 17011 Super. Ct. Id. No. 70315 (717) 7S7-7566 IN THE COURT Of COMMON OF CUMBERLAND COUNTY STATE Of VERSUS PENNA. PLEAS AND NOW,__ DECREED THAT DecrEe IN DIVORCE , ~:~_~, IT IS ORDERED AND PLAINTIFF, , DEFENDANT, aRE DIVORCED FROM THE BONDS OF MATRIMONY. 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 BEEN ENTERED; ATTEST: PROTHONOTARY